Figure 7-1a in the LTA (Appendix K) shows the traffic distribution; Figure 7-1b shows the project driveway traffic distribution to provide additional clarity on the local distribution of trips on the streets immediately adjacent to the project site; Figure 7-2a and Figure 7-2b in the LTA (Appendix K) show the overall traffic and driveway traffic volumes; and Figure 7-3 shows the Near-Term + Proposed Project traffic volumes. Figure 3.15-2 of this EIR depicts the conceptual circulation plan for the project.
Near -Term (Year 2025) Conditions and Scenarios
As described in Section 6.0 of the LTA (Appendix K), for Near-Term conditions (Interim Year 2025), the extension of Discovery Street from Bent Avenue/Craven Road to Twin Oaks Valley Road (four -lane arterial) is assumed to be complete by Year 2025. This network change is adjacent to the project study area and is included in the SANDAG Year 2025 interim year scenario model. Per the City of San Marc os Capital Improvement Program, this capital improvement project is funded with target completion in Fall 2023. However, it should be noted that based on a comparison of base year and Year 2025 forecast volumes, this roadway extension affects traffic volumes on existing portions of Discovery Street and Craven Road but does not substantially affect traffic patterns within the study area.
To forecast future traffic volumes for Near-Term (Interim Year 2025) conditions, the SANDAG Series 14 Model was utilized. The forecasted ADT volumes were then used to calculate peak hour volumes based partially on the existing relationship between ADT and peak hour volumes.
Several other traffic engineering principles and factors such as the K -factor (the proportion of daily volume that occurs during the peak period) and D-factor (the directional split of the traffic volumes) were also considered in the forecast analysis (App endix K). The forecast volumes were also checked for consistency between intersections, where no driveways or roadways exist between intersections, and were compared to existing volumes for accuracy.
As outlined in Section 8.0 of the LTA (Appendix K), Intersection #3 (Via Vera Cruz/Grand Avenue/SR-78 EB Ramps) and Intersection #7 (Pacific Street/Linda Vista Drive) are calculated to operate at LOS F in the near-term scenario without the proposed project. For segment operations in the near-term without the proposed project, Segment #9 (Linda Vista Drive: Rancho Santa Fe to Pacific Street), #12 (San Marcos Boulevard: Pacific Street to Las Posas Road), and #13 (San Marcos Boulevard: Las Posas Road to Via Vera Cruz) are calculated to operate at LOS E or F.
For the near-term with project scenario, with the addition of project traffic Intersection #3 and #7 are calculated to continue to operate at LOS F, and the project would result in a substantial effect to both of these intersections.
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Table 8–1b in Appendix K presents the 95th percentile peak hour queue lengths for intersection turn pockets where the Project adds traffic within the study area for the Near-Term with Project condition. As shown in Table 8–1b, all Near-Term without Project peak hour queues are contained within existing turn pockets except for intersections #1, #3, #5, #8 and #10.
For the near-term plus project segment operations scenario, with the addition of project traffic, segments #9, #12, and #13 are calculated to continue to operate at LOS E or F. However, the project -related increase in volume to capacity ( V/C) ratio for these street segments already operating at unacceptable LOS would be less than the threshold of 0.02, and therefore the project is not calculated to result in substantial effects to the study segments and no improvements would be required.
Please refer to Table 8 -1a (Near-Term Intersection Operations) and 8-1b (near-term intersection queuing); and Table 8-2 (Near -Term Street Segment Operations) in Appendix K, which show intersection and street segment operations both with and without the proposed project.
Horizon Year (Year 2050) Conditions and Scenarios
The Year 2050 street network in the SANDAG Series 14 forecast model includes changes to the roadway system in the vicinity of the study area including the planned extension of McMahr Road between San Marcos Boulevard and Discovery Street. For the purposes of the analysis in the LTA (Appendix K), this network addition is assumed in the long -term traffic volumes forecast but no changes to the study area roadway geometry or intersection control were assumed.
To forecast future traffic volumes for Horizon Year (Year 2050) conditions, the SANDAG Series 14 Model was utilized. The forecasted ADT volumes were then used to calculate peak hour volumes based partially on the existing relationship between ADT and peak hour volumes. Several other traffic engineering principles and factors such as the K-factor (the proportion of daily volume that occurs during the peak period) and D-factor (the directional split of the traffic volumes) were also considered in the forecast analysis (see Appendix K for definitions). The forecast volumes were also checked for consistency between intersections, where no driveways or roadways exist between intersections, and were compared to existing volumes for accuracy.
As noted in the previous section, completion of the extension of McMahr Road between San Marcos Boulevard and Discovery Street was assumed in the traffic volume forecast. Traffic volumes associated with the project as described above, under Project Trip Distribution and Assignment, were added to Year 2050 baseline traffic volumes to arrive at Year 2050 + Project traffic.
As outlined in Section 10.0 of the LTA (Appendix K), Intersections #2 (Las Posas Road/Grand Avenue), #3 (Via Vera Cruz/Grand Avenue/SR-78 EB Ramps), #6 (Rancho Santa Fe Road/Linda Vista Drive), #7 (Pacific Street/Linda Vista Drive), and #10 (Las Posas Road/San Marcos Boulevard) are calculated to operate at LOS E or F in the Horizon Year Scenario without the project. For segment operations, Segment #6 (Pacific Street: La Mirada Drive to Linda Vista Drive), #9 (Linda Vista Drive: Rancho Santa Fe Road to Pacif ic Street), #12 (San Marcos Boulevard: Pacific Street to Las Posas Road), and #13 (San Marcos Boulevard: Las Posas Road to Via Vera Cruz) are calculated to operate at LOS E or F in the Horizon Year Scenario without the project.
In the Horizon Year plus project intersection analysis, Intersections #2, #3, #6, #7, and #10 are calculated to continue to operate at LOS E or F. Based on the established Level of Service Standards outlined in Section 3.15.1, Existing Conditions, the project is calculated to result in a substantial effect on Intersections #3 and #7, while
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project-related change in delay at Intersections #2 and #10 is below the threshold of 2.0 seconds. For the Horizon Year plus project segment operations, with the addition of project traffic segments #6, #9, #12, and #13 are calculated to continue to operate at LOS E or F. Based on the established Level of Service Standards, the project is calculated to result in substantial effects to segment #6, while project related increase in V/C ratio at segments #9, #12, and #13 operating at LOS E or F is below the 0.02 threshold.
Traffic Signal Warrants
Based on the analysis shown in Table 8 –1 in Appendix K , Linda Vista Drive/South Pacific Street intersection is calculated to operate at LOS F in the near -term with Project conditions. Traffic signal warrant analysis has been completed to determine if a signal would be warranted at that intersection under future conditions.
Warrants were prepared for the Near-Term with Project scenarios. As outlined in Chapter 4C, “Traffic Control Signal Needs Studies,” of the 2014 California Manual on Uniform Traffic Control Devices (California MUTCD), the peak hour warrant (Warrant 3) was analyzed.
The lane configurations at Linda Vista Drive/South Pacific Street are as follows:
▪ South Pacific Street (southbound): 1 shared left/thru/right-turn lane ▪ Linda Vista Drive (westbound): 1 left turn lane, 1 thru lane, 1 right turn lane ▪ South Pacific Street (northbound): 1 shared left/thru/right-turn lane ▪ Linda Vista Drive: 1 left turn lane, 1 thru lane, 1 right turn lane Linda Vista Drive (westbound/eastbound) is the major street at this location.
Warrant 3 consists of two categories. The need for a traffic shall be considered if the criteria in either of the two categories are met. Category A requires three conditions to be met for the same 1 hour of an average day: (1) minor street delay exceeding 4 vehicle -hours, (2) minor street volume exceeding 100 vehicles per hour, and (3) total entering volume at the intersection exceeding 800 vehicles. Category B plots the AM and PM entering volumes on a linear graphic (Figure 4C-3 of the MUTCD) to determine if the volumes exceed the allowable thresholds. For the signal warrant to be met, either Category A or B must be satisfied.
Table 13–5 in Appendix K illustrates the two categories and summarize results for the Linda Vista Drive/South Pacific Street intersection under Near -Term with Project scenarios. Both Category A and Category B are satisfied under the Near-Term with Project scenario.
Threshold No. 1. Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
The project site is located in an infill area with numerous bicycle, pedestrian, and transit facilities, as discussed above. Class II bike lanes are provided on Las Posas Road, from SR-78 to San Marcos Boulevard (both sides); Grand Avenue, from Rancho Santa Fe Road to Las Posas Road (both sides); Linda Vista Drive, from Rancho Santa Fe Road to Pacific Street (north side); and San Marcos Boulevard, from Pacific Street to Via Vera Cruz (both sides). Pedestrian sidewalks are generally provided throughout the a rea, with pedestrian crossings located at intersections surrounding the project site. The site is also served by existing transit.
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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 well-developed commercial area along Las Posas Road immediately opposite the project site can serve the shopping and dining demand of future residents within easy walking distance. Schools, parks, and other facilities are also walkable/bik eable from the site. As discussed in Section 3.15.1, the project site is adjacent to bus stops serving two separate routes with connections to SPRINTER service at Palomar College Station.
As described above, in the Near-Term With Project scenario, with the addition of project traffic Intersections #3 and #7 are calculated to continue to operate at LOS F, and the project would result in a substantial effect to both of these intersections and roadway improvements would be required. Fo r the near -term plus project segment operations scenario, with the addition of project traffic, segments #9, #12, and #13 are calculated to continue to operate at LOS E or F. However, the project-related increase in V/C ratio for these street segments already operating at unacceptable LOS would be less than the threshold of 0.02, and therefore the project is not calculated to result in substantial effects to the study segments and no improvements would be required.
As described above in the Horizon Year With Project scenario, the project is calculated to result in a substantial effect on Intersections #3 and #7, while project-related change in delay at Intersections #2 and #10 is below the threshold of 2.0 seconds. Roadway improvements would be required to address effects on Intersections #3 and #7. For the Horizon Year plus project segment operations, with the addition of project traffic segments #6, #9, #12, and #13 are calculated to continue to operate at LOS E or F. Based on the established Level of Service Standards, the project is calculated to result in substantial effects to segment #6, while project related increase in V/C ratio at segments #9, #12, and #13 operating at LOS E or F is below the 0.02 threshold.
To address the Near -Term with Project and Horizon Year with Project effects described above, t he following transportation improvement s proposed by the LTA (Appendix K) would be required by condition of approval and incorporated into the proposed project to ensure adequate pedestrian, bicycle, and transit facilities are provided consistent with City policies and guidelines :
Provide a 6-foot sidewalk and Class II buffered bike lane along the project’s frontage on Pacific Street.
Provide a 12-foot urban trail (shared use path) along the project’s frontage on Linda Vista Drive.
Provide a 12-foot urban trail (shared use path) along the project’s frontage on La Mirada Drive.
Provide transit stop amenities including bench, shelter, and trash can at the southbound stop at the intersection of Las Posas Road/ La Mirada Drive located on the southwest corner of the intersection.
Provide a bus turnout for this stop along the project frontage.
The following roadway improvements proposed by the LTA (Appendix K) would increase performance to acceptable or pre-project conditions under each scenario.
Intersection #3. Via Vera Cruz/Grand Avenue/SR -78 EB Ramps – Provide a fair share contribution for a dedicated southbound right turn lane on the SR -78 eastbound off -ramp. Given that this intersection operates at LOS E or worse under existing conditions and the deficiency is not directly caused by the Project, a fair share contribution is appropriate.
With the construction of a dedicated southbound right -turn lane, the intersection is calculated to operate at substantially better than pre-Project conditions in both Near- Term and Long-Term scenarios as shown in Table 13–1 and Table 13–2 of Appendix K.
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Appendix O of Appendix K contains the Near -Term + Project and Long -Term + Project Improvements Intersection Analysis worksheets for all intersection improvements discussed in this section. The project fair share of 7.1% was calculated based on the project traffic effects at Intersection #3.
Intersection #5. Las Posas Road/La Mirada Drive – Provision of the recommended two-way left-turn on La Mirada Drive would provide additional functional storage for eastbound left -turn queues under 95th percentile peak queueing conditions. This would allow additional vehicle stacking to occur in the center turn lane without impeding eastbound through or righ t-turning traffic. Restripe the eastbound (La Mirada Drive) intersection approach to provide two left turn lanes and one shared through/right -turn lane and provide necessary signal modifications to accommodate new striping. This improvement will provide additional capacity and storage area for left turning traffic , which will reduce queues and, in conjunction with the recommended two -way left turn lane on La Mirada Drive, improve accessibility for existing and proposed Project driveways.
The overall intersection LOS will continue to be acceptable LOS D or better in both Near-Term and Long-Term scenarios as shown in Table 13–1 and Table 13–2 in Appendix K. Table 13–3 in Appendix K provides the Near-Term and Long-Term queue analysis illustrating the reduced queues provided by this improvement.
Intersection #7. Pacific Street/Linda Vista Drive – Provide a traffic signal. with the following lane geometry:
▪ Southbound – one left turn lane, one shared through/right turn lane ▪ Westbound – one left turn lane, one shared through/right turn lane ▪ Northbound – one left turn lane, one shared through lane, one/ right turn lane ▪ Eastbound – one left turn lane, one through lane, one right turn lane The traffic signal should provide protected left -turn phasing for all approaches. The traffic signal would provide LOS C or better operations under Near-Term with Project and Long-Term with Project conditions as shown in Table 13–1 and Table 13–2 of Appendix K.
Intersection #8. Las Posas Road/Linda Vista Drive – This intersection operates at acceptable LOS D or better with the addition of Project traffic and does not require improvements to enhance the LOS. However, iIn conjunction with the Urban Trail to be provided on Linda Vista Drive, align the intersection of Las Posas Road/Linda Vista Drive and to align with the proposed cross-section of Linda Vista Drive between Pacific Street and Las Posas Road. Tthe existing shared through/right-turn lane on the westbound approach will be converted to right turn only. The curb along the southwest corner of the intersection will also be revised to improve intersection alignment. This entails removal of the existing eastbound right -turn lane. No changes will be made to the southbound or northbound approaches. The following lane geometry is proposed:
▪ Southbound – one shared through/right-turn lane, one through lane, one left-turn lane ▪ Westbound – one right-turn lane, one through lane, one left-turn lane ▪ Northbound – one shared through/right-turn lane, one through lane, one left-turn lane ▪ Eastbound – one shared through/right-turn lane, one through lane, one left-turn lane Tables 13–1 and 13–2 in Appendix K also show Near-Term and Long-Term intersection operations for Las Posas Road/Linda Vista Drive under the proposed conditions. As shown in Tables 13 –1 and 13–2 of Appendix K, this intersection would continue to operate at acceptable LOS D or better under the proposed conditions including Project traffic.
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The project would be required to provide adequate on -site circulation for passenger vehicles, heavy vehicles, bicyclists, and pedestrians. Internal circulation within the project site, as well as proposed off-site improvements is shown in site plans subject to City review (see Figure 2-5, Conceptual Site Plan, in Chapter 2 of this EIR), and would be designed to comply with the following recommendations of the LTA, as required by conditions of approval:
▪ All access points shall provide adequate driveway sight distance. ▪ Any driveways located on La Mirada Drive or Linda Vista Drive should be located as far from Las Posas Road as practically allowable with other site constraints. ▪ The easterly driveway on Linda Vista Drive should be limited to right turns only given its proximity to Las Posas Road. The analysis presented in this report assumes that the easterly driveway on Linda Vista Drive is limited to right turns.
▪ The easterly driveway on La Mirada Drive may provide full access turning movements if queued vehicles at Las Posas Road do not interfere with access. Improvements are proposed in Section
13.4 of Appendix K to provide additional capacity and storage area to left turns from eastbound La Mirada Drive to Las Posas Road, thus minimizing queues and potential interference with any Project driveways.
▪ If appropriate, driveways to Las Posas Road should be limited to right turns only. The sole access point on Las Posas Road is proposed to be emergency-access only. ▪ Provide a two-way left-turn lane on La Mirada Drive, between Pacific Street and Las Posas Road, to facilitate turning movements to/from Project driveways.
Project compliance with applicable plans is outlined below.
SANDAG’s San Diego Forward: The 2021 Regional Plan
The proposed 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 in a manner that would reduce VMT (see below), and the project would incorporate safe access to/from the project site and surrounding roadways. The proposed project would also not preclude the development of any specific improvement projects identified in the Regional Plan to reduce regional congestion.
As described in Section 3.15.2, Regulatory Setting, there are no CMP -specific requirements associated with this project.
City of San Marcos Bikeway Master Plan
Goals of the master plan are to 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 is to connect the City’s trails to bicycle facilities to complete a safe and enjoyable trail and bikeway system. As outlined in Chapter 2 of this EIR, the proposed project would construct or preserve space for the portions of proposed bicycle facilities on Linda vista Drive from Pacif ic Street to Las Posas Road immediately adjacent to the project site.
Implementation of the project would not conflict with the City’s Bikeway Master Plan.
The project would implement the following active transportation improvements:
▪ Provide a 6-foot sidewalk and Class II buffered bike lane along the project’s frontage on Pacific Street ▪ Provide a 12-foot urban trail (shared use path) along the project’s frontage on Linda Vista Drive ▪ Provide a 12-foot urban trail (shared use path) along the project’s frontage on La Mirada Drive
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Additionally, as part of the project, additional pedestrian connectivity would be provided along three of the adjacent street frontages. Along South Pacific Street and Linda Vista Drive, adjacent to the project site, sidewalks would be added in the existing travel lane, in order to avoid biological impacts adjacent to the designated open space on site. Where development is proposed on site, an expanded trail would be provided. On La Mirada Drive, a complete urban trail system (shared use path) would be prov ided along the entire length of the road. along the project frontage. The proposed urban trail would be up to 12 feet wide (please refer to Figure 2-5).
City of San Marcos General Plan – Mobility Element
As outlined in Section 3.10, Land Use and Planning, of this EIR, the project would be consistent with applicable goals of the City’s General Plan Mobility Element. The proposed project would promote sustainability through locating residential uses on an underutilized infill site proximate to existing schools, markets, parks, transit, and shopping centers. VMT would be reduced by sustainably locating residential uses in this infill area. In addition, the project would be required to comply with Title 24 requirements and would include amenities such as electric vehicle charging stations, installation of electric or solar water heaters, implement a Transportation Demand Management plan, reduced landscaping water use, and plant trees. Additionally, the proposed 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 internal circulation network for the proposed project would not include any hazardous design features or incompatible uses. The proposed project would include circulation amenities and improvements such as an interconnected mobility system for bicycles, pedestrians, and vehicles in order to provide residents with safe movement within the project site; as well as secondary emergency access, connections to existing roadways within the within the vicinity of the project site, and access to regional arterial and highway networks and SPRINTER/Breeze transit services.
City of San Marcos Municipal Code
The project would include a total of 927 parking spaces. Of the spaces, 234 would be designated for the proposed rowhomes, 254 spaces would be designated for the proposed villas, 359 spaces would be designated for the proposed apartments, and 80 spaces wou ld be provided for the proposed affordable flats. Under existing conditions, on-street parking on adjacent streets is limited to Pacific Street and La Mirada Drive. On-street parking is prohibited on both sides of South Las Posas Road and along the project frontage on Linda Vista Drive.
For the affordable rental housing, which would be deed restricted for 55 years, the project meets the requirements of Section 65915, subdivisions (b) and (c). The applicant is therefore requesting the application of the parking ratios set forth in Section 65915(p)(1) be applied to the affordable rental project. Therefore, the project would comply with the required parking ratios for multifamily dwelling units and affordable housing projects, as shown in the parking summary calculations in Figure 2-5 and as outlined in Table 2-4 in Chapter 2 of this EIR.
The project would provide 4 more parking spaces than required. Of the 234 spaces provided for the rowhomes, 202 would be garage spaces and 32 would be uncovered. Of the 254 spaces provided for the villas, 216 would be garage spaces and 38 would be uncovere d. Of the 359 apartment units, 172 would be garage spaces and 187 would be uncovered. The 80 parking spaces provided for the affordable flats would be uncovered. A minimum of 5% of parking spaces required would be equipped with EV charging stations or as otherwise required by CALGreen, whichever is more significant. Per the City’s Municipal Code, residential projects that provide required uncovered parking shall assign parking spaces by dwelling unit. Spaces shall be clearly marked to denote assigned parkin g.
For the convenience of tenants and guests, parking spaces shall be located as close as possible to the unit or
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common facility it is intended to serve (City of San Marcos 2022). The project would comply with these requirements outlined in the City’s Municipal Code.
For the reasons stated in the analysis above, impacts are determined to be less than significant.
Threshold No. 2: Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
As discussed above, CEQA Guidelines Section 15064.3 replaces LOS with VMT as the appropriate metric to be used in assessing a project’s transportation related impacts. Under CEQA Guidelines Section 15063.4(b)(1), VMT exceeding an applicable threshold of significance may indicate a significant impact, although, development projects within 0.5 miles of a major transit stop are presumed to cause a less than significant transportation impact . A “major transit stop” includes a site containing an existing rail or bus rapid transit station, or the intersection of two or more major bus routes based on frequency of service intervals (PRC Section 21064.3.).
NCTD provides public transportation within the City and the County of San Diego for Coaster rail service, SPRINTER light rail service, and Breeze bus service. SPRINTER service operates between Escondido and Oceanside, with connections to Interstate 5 and the Coaster rail service operating out of the City of Oceanside. The NCTD operates the Palomar College Station SPRINTER and Breeze transit station located approximately 0.6 miles from the proposed project’s La Mirada Drive entrance. Therefore, the project site falls just outside the 0.5 -mile threshold under CEQA Guidelines Section 15064.3 subdivision (b). However, it should be noted that two Breeze bus service stops along South Las Posas Road, including the Las Posas Road and Linda Vista Drive bus stop and the Las Posas Road and La Mirada Drive bus stop, are located along the project site’s eastern border.
Because the project site is located just beyond 0.5 miles from a major transit stop, and in compliance with the City’s, a quantitative VMT analysis has been prepared for the project (Appendix J).
Vehicle Miles Traveled Analysis
As described under Section 3.15.1, for new land use developments that do not meet any of the screening criteria, the VMT metrics and thresholds outlined in the City TIAG, are used to determine whether the proposed project would result in significant transportation related impacts. Since the project proposes residential land uses, based on the City TIAG, this EIR evaluates whether the project VMT per resident would exceed a significance threshold of 15 % below the existing countywide average VMT per resident. Because the proposed project is estimated to generate ADT greater than 2,400 (a total of 2,694 ADT), the project’s residential VMT per resident was estimated using the SANDAG regional travel demand model as recommended by the City’s TIAG.
The requirement to prepare a detailed transportation VMT analysis applies to all land development projects except for those that meet at least one of the provided screening criteria outlined below. A project that meets at least one of the screening criteria listed below would be considered to have a less-than-significant impact due to the project or location characteristics.
Small Projects (less than 10 daily vehicle trips)
Affordable Housing (100% deed restricted)
Local Serving Retail and Public Facilities (50,000 square feet gross floor area or less) Adjacency to High-Quality Transit
Map-Based Screening (projects located in VMT efficient areas; limited to projects generating fewer than 2,400 ADT)
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Based on the project site location, land use characteristics, and trip generation of the project, none of the above listed screening criteria are applicable and therefore a detailed VMT analysis is required. Consistent with City guidelines, the SANDAG regional travel demand model was used to estimate the project’s VMT per resident. The SANDAG Series 13 Travel Demand Model (also known as ABM 1) is the latest model available from SANDAG that can be run with land use overrides, which is required by the City of San Marcos TIA Guidelines for projects generating greater than 2,400 ADT . SANDAG Series 14 (ABM 2) is the latest published and approved model for VMT data, however, the ABM 2 model cannot be run for development projects that require land use overrides to produce project VMT information because the necessary scripts/procedures were not developed. Another update to the regional model (ABM 2+) is currently in development that will be able to run land use overrides . This update was adopted in December 2021 but the capability of running land use overrides currently remains unavailable .
Therefore, in this interim period, the ITE Transportation Capacity and Mobility Task Force recommends VMT modeling that requires land use overrides use the ABM 1 model due to ABM 2’s limitations. “[T]he use of ABM 1 for VMT analysis for those projects that require a model run and involve land use overrides … provide[s] the best available data.”3 VMT data should then only be compared with regional averages within the same model version.
Accordingly, the project’s transportation engineers (LLG) customized the SANDAG Series 13 model to reflect the proposed project land uses. Table 3.15 -7 shows the results of the Project VMT analysis. Based on the model outputs, the SANDAG region’s average VMT per resident is 17.5, while the Project’s VMT per resident was calculated at 10.8 VMT per resident. Based on the City’s TIAG, the applicable threshold of significance is 15% below the region average of 17.5, or 14.9 VMT per resident. Because the proposed project VMT per Resident is 10.8, which is 38% below the regionwide average VMT per resident the proposed project VMT is below the significance threshold of 15% below the regionwide average or 14.9 VMT per Resident. Therefore, VMT impacts would be less than significant, and no mitigation is required.
Table 3.15-7. Project VMT Findings
Metric
Regionwide
Average a
Significance
Threshold
(15% below
Average)
Project
VMT a
Project
VMT Over
Threshold
% of Project
VMT Over
Significance
Threshold
Transportation
Impact?
(Over Threshold)
VMT per
Resident
17.5 14.9 10.8 — — No
Source: Appendix J.
Notes: VMT = vehicle miles traveled.
a Regionwide Average and Project VMT per Resident from SANDAG Series 13 Base Year 2012 Travel Demand Model, customized to include proposed Project land uses.
The relatively low project VMT reflects, in part, the moderately high employment density in the vicinity attributable to the surrounding commercial and light industrial land uses and correspondingly, the proximity of multiple employment opportunities, which results in reduced VMT. In addition, the well-developed commercial area along South Las Posas Road immediately opposite the project site is within easy walking distance and would serve the shopping and dining demand of future residents, further contributing to a reduced VMT per resident. Moreover, as discussed in Section 3.15.1, the project site is adjacent to bus stops serving two separate routes with connections to SPRINTER service at Palomar College Station, further contributing to reduced VMT per resident. Bradley Park, a 24-acre park offering baseball diamonds, a soccer field, a playground, picnic areas is located across from the site’s southwestern corner, providing recreation within walking distance. It should also be noted that the project is
3 Use of ABM 1 and ABM 2 for SB 743 Related VMT Analysis in the Interim Until ABM 2+ is Completed [White paper]. San Diego, CA: ITE Transportation Capacity and Mobility Task Force – SB 743 Modeling Subcommittee, 2020.
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providing 68 affordable units, approximately 15% of the total units, which typically generate lower VMT than market rate housing; the analysis assumed all of the housing units would be market rate housing and did not take any reductions for the affordable housing units (Appendix J).
In summary, the proposed project would promote sustainability through locating residential uses on an underutilized infill site proximate to existing employment, entertainment, schools, markets, parks, transit, and shopping centers. As a result, VMT would be reduced by sustainably locating residential uses in this infill area. In addition, the project would be required to comply with Title 24 requirements and would be required to implement a Transportation Demand Management Plan, further reducing VMT. Furthermore, the project site is located adjacent to transit service with stops located near both the north and south ends of the project site along South Las Posas Road. The proposed project would upgrade the existing stop along its frontage with enhanced amenities (minimum of bench, shelter, and trash can) and include clear and direct access to bus stops in the site design. As the results of the project VMT comparison indicate that the project VMT per resident is below the significance threshold, impacts are determined to be less than significant.
Threshold No. 3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves, or dangerous intersections) or incompatible uses (e.g., farm equipment)? The project site is located in an infill area bounded by Las Posas Road, Pacific Street, La Mirada Drive, and Linda Vista Drive. Under existing conditions, on-street parking on adjacent streets is limited to Pacific Street and La Mirada Drive. On-street parking is prohibited on Las Posas Road and Linda Vista Drive. The project will be served by three driveways located on La Mirada Drive and one driveway on Linda Vista Drive.
All proposed circulation improvements would be designed in accordance with the City’s roadway design standards to ensure proper safety requirements are met. The internal circulation network for the project would not include any hazardous design features or incompatible uses. All driveways would provide for full turning movements. An emergency-only access is proposed on Las Posas Road, and no day-to-day project traffic would be allowed through this driveway. The project would include circulation amenities su ch as an interconnected mobility system for bicycles, pedestrians, and vehicles in order to provide residents with safe movement within the project site; as well as secondary emergency access, connections to existing roadways within the vicinity of the project site, and access to regional arterial and highway networks and SPRINTER/Breeze transit services. All final project plans are subject to review and approval by the City and the San Marcos Fire Department, and all roadway improvements implemented as part of the project would be designed consistent with City policy and guidelines, as discussed above under Threshold No. 1.
Additionally, the project proposes to upgrade the existing bus stop along its frontage with enhanced amenities and include clear and direct access to the adjacent bus stops located near both the north and south ends of the site along Las Posas Road. Furthermore, considering the proposed residential uses for the project site, no incompatible uses, such as farm equipment or motorsport vehicles , would be operated on site during project construction or operation. As such, impacts related to design features and incompatible uses would be less than significant.
Threshold No. 4: Would the project result in inadequate emergency access? As described in response to Threshold No. 3, the project would be served by three driveways located on La Mirada Drive, and one driveway on Linda Vista Drive. All driveways would provide for full turning movements. An emergency- only access is proposed on Las Posas Road, and no day-to-day project traffic would be allowed through this driveway.
Thus, the proposed project would provide four points of entry, as well as one emergency only access way, and each would be designed to meet the design requirements codified in the California Fire Code.
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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). 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 FPP prepared for the project (Appendix N to this EIR) determined that San Marcos Fire Department could provide emergency response to the project site within its internal 7-minute response time from SMFD Stations 1 and 2, and Vista Fire Department Station 4 could provide an approximate 7-minute response to the project site and would respond per mutual aid agreements, if needed.
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), and entryway gate access for first responders (Chapter 5 of the California Fire Code, Section 503.6). All final project plans and the VMT Analysis prepared for the proposed project (included as Appendix J to this EIR) 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 des ign standards to ensure proper safety requirements are met. Therefore, it impacts related to emergency access would be less than significant.
3.15.5 Mitigation Measures
As analyzed in Section 3.15.4, implementation of the proposed project would result in less than significant impacts relative to transportation and , therefore, no mitigation is required under CEQA .
3.15.6 Conclusion
The proposed project would provide for residential land uses in an infill area, taking advantage of the site’s location near transit, retail, employment, schools, parks, and other uses. The proposed project would be consistent with programs, plans, ordinan ces, and policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities and, therefore, related impacts would be less than significant.
As described under Section 3.15.1, under CEQA, LOS or other measures of vehicle capacity or traffic congestion (i.e., traffic delay) are no longer considered in evaluating whether a significant impact on the environment would occur; and therefore, the LOS analysis referred to in this sectio n and outlined in Appendix K to this EIR, is for informational purposes only. Similarly, trip generation rates and distribution information related to the LOS analysis also is presented for information purposes only. Section 13.0 of the LTA (Appendix K) explains that Intersection #3 (Via Vera Cruz/Grand Avenue/SR-78 EB Ramps [Near-Term and Long Term]), Intersection #7 (Pacific Street/Linda Vista Drive [Near-Term and Long Term]), and Street Segment #6 (Pacific Street: La Mirada Drive to Linda Vista Drive [Long-Term]) are calculated to operate at unacceptable LOS with a substantial effect due to traffic generated from the project. However, implementation of intersection and roadway improvements outlined in the LTA (Appendix K), and compliance with applicable regulations related to transportation and circulation , would ensure potential impacts related to road hazards and emergency access would be less than significant.
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As outlined in the VMT analysis prepared for the project (Appendix J to this EIR), based on the model output of the SANDAG regional travel demand model run customized with the project land uses, the project’s VMT per resident is less than 15% below the reg ionwide average. The project therefore results in less than significant impacts related to traffic and transportation, and no mitigation is required.
Existing Traffic Conditions
Pacific Project EIR
FIGURE 3.15-1SOURCe: Linscott Law & Greenspan, 2022
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR
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Conceptual Circulation
Pacific Project EIR
FIGURE 3.15-2SOURCE Lundstrom Engineering and Surveying, Inc., 2023 *Please remember
to update the
document path.
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3.16 - TRIBAL CULTURAL RESOURCES
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3.16 Tribal Cultural Resources
This section describes the existing tribal cultural resources of the proposed Pacific Specific Plan Project (proposed project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed 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 Historic Resources (CRHR) or a local historic register, or 2) determined by the City, at its discretion to treat the resources as a tribal cultural resource (PRC Section 5024.1). Cultural resources are further analyzed in Section 3.4, Cultural Resources, of th is environmental impact report (EIR).
The analysis in this section relies, in part, on the Cultural Resource Inventory Report for the Pacific Project, City of San Marcos, California, ( Cultural Resources Report) prepared by Dudek in December 2022. 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 Cultural Resources Study is included as Appendix D to the 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
No. 1 – Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a site,
feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
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
A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.
Potentially
Significant
Less than
Significant
Less than
Significant with
MM-TCR-1 to MM-
TCR-4
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3.16.1 Existing Conditions
The undeveloped project site is relatively flat and dominated by invasive shrubs and grass. Although undeveloped, the project site reflects a history of disturbance. Vegetation is disturbed by an abundance of invasive and weedy plant species, and unpaved roads crossing the project site are visible on historic aerials since 1980 (Appendix C).
The project area of potential effect (APE), as analyzed in the Cultural Resources Report, includes the entire
33.2-acre project site. The project APE is located at the northwest corner of Las Posas Road and Linda Vista Drive and is surrounded primarily by industrial and commercial uses.
The information herein describes the existing archeological context of the project site. It also provides information on the outreach and consultation efforts with local Tribes, as required by existing regulations.
Methodology
South Coastal Information Center Records Search
Dudek requested a records search from the South Coastal Information Center ( SCIC) for the project APE and a 1-mile buffer on March 13, 2021. SCIC responded with the results of the records search on March 16, 2021. The records search revealed that 69 previous cultural resources studies have been completed within 1 mile of the project APE (Appendix D). Seven of these previous studies intersect the current project APE. One of the previous studies completed consisted of a records search, archival review, and a pedestrian survey of the entire current project APE. This study identified no cultural resources within the project APE.
The SCIC records search also revealed that no cultural resources have been recorded within the project APE. The records search did identify 19 cultural resources and two historic addresses within 1 mile of the project APE (see Table 2, Resources within 1 Mile of Project APE, in Appendix D). The closest resources to the project APE are P-33- 011663 and P-33-012735, both consisting of highly disturbed prehistoric artifact scatters located 0.4 miles from the project APE.
Native American Heritage Council and Native American Outreach Letters Dudek requested a Native American Heritage Council (NAHC) search of the Sacred Lands File on March 12, 2021, for the project APE and a 1 -mile buffer. The Sacred Lands File consists of a database of known Native American resources. These resources may not be included in SCIC database. The NAHC replied on March 24, 2021 , and reported that the Sacred Lands File did not identify any known Native American cultural resources within the project APE or the surrounding 1-mile buffer (Appendix D). The NAHC additionally provided a list of Native American tribes and individuals/organizations with traditional geographic associations that might have knowledge of cultural resources in this area.
Outreach letters were mailed on March 30, 2021 , to all Native American group representatives included on the NAHC contact list (Appendix D). These letters attempted to solicit additional information relating to Native American resources that may be impacted by the project. Native American representatives were requested to define a general area where known resources intersect the project APE. To date, two responses have been received. The first response is from the Rincon Band of Luiseño Indians stating the project site is located within the Band ’s specific Area of Historic Interest, and requests a survey of the property, a professional tribal monitor during the survey, a copy of the final study for review and comment, and request for further consultation with the City. The second
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response is from the Viejas Band of Kumeyaay Indians, stating the project site has cultural significance or ties to the Kumeyaay Nation and recommends notifying the San Pasqual Band of Mission Indians, requests all National Environmental Policy Act /CEQA/Native American Graves Protection and Repatriation Act laws be followed, and requests immediate contact of San Pasqual Band of Mission Indians on any changes or inadvertent discoveries. No other communications between Dudek and the tribes has occurred since then.
In compliance with Assembly Bill 52 and Senate Bill 18, the City, as lead agency, is responsible for conducting government to government consultation with pertinent tribal entities. This EIR will be revised to include information obtained through consultation, as it becomes available.
3.16.2 Regulatory Setting
State
California Register of Historical Resources and the California Environmental Quality Act CEQA requires that all private and public activities not specifically exempted be evaluated against the potential for environmental damage, including effects to historical resources. Historical resources are recognized as part of the environment under CEQA. The act defines historical resources as “any object, building, structure, site, area, or place that is historically significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (PRC Section 5020.1[j]).
Lead agencies have a responsibility to evaluate historical resources against the CRHR criteria prior to making a finding as to a proposed project ’s impacts to historical resources. Mitigation of adverse impacts is required if the proposed project will cause substantial adverse change. Substantial adverse change includes demolition, destruction, relocation, or alteration such that the significance of a historical resource would be impaired. While demolition and destruction are fairly obvious significant impa cts, it is more difficult to assess when change, alteration, or relocation crosses the threshold of substantial adverse change. The CEQA Guidelines provide that a project that demolishes or alters those physical characteristics of a historical resource tha t convey its historical significance (i.e., its character-defining features) is considered to materially impair the resource’s significance. The CRHR is used in the consideration of historical resources relative to significance for purposes of CEQA. The CRHR includes resources listed in or formally determined eligible for listing in the National Register of Historic Places and some California State Landmarks and Points of Historical Interest. Properties of local significance that have been designated under a local preservation ordinance (local landmarks or landmark districts) or that have been identified in a local historical resources inventory may be elig ible for listing in the CRHR and are presumed to be significant resources for purposes of CEQA unless a preponderance of evidence indicates otherwise.
Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the CRHR (PRC Section 5024.1; 14 CCR 4852), which include the following:
▪ It is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States ▪ It is associated with the lives of persons important to local, California, or national history ▪ It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values ▪ It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation
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Senate Bill 18
The Traditional Tribal Cultural Places Bill of 2004 (Senate Bill 18) requires local governments to consult with Native American tribes during the project planning process. The intent of this legislation is to encourage consultation and assist in the preservation of “Native American places of prehistoric, archaeological, cultural, spiritual, and ceremonial importance”. The purpose of this consultation is to protect the identity of the cultural place and to develop appropriate and dignified treatment of the c ultural resource. The consultation is required whenever a General Plan, General Plan Amendment, Specific Plan, Specific Plan Amendment, or Open Space Element is proposed for adoption. As part of the planning process, California Native American tribes must be given the opportunity to consult with the lead agency for the purpose of preserving, mitigating impacts to, and identifying cultural places.
Assembly Bill 52
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 tribal cultural resources (TCRs). PRC Section 21074(a) defines TCRs and states that a project that has the potential to cause a substantial adverse change to a TCR is a project that may have an adverse effect on the environment. A TCR is defined as a site, feature, place, cultural landscape, sacred place, or object with cultural value to a California Native American tribe that is either (1) listed or eligible for listing in the CRHR or a local register of historical resources, or (2) determined by a lead agency to be a TCR.
Native American Historic Resource Protection Act
State law addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are disco vered during construction of a project; and establishes the NAHC to resolve disputes regarding the disposition of such remains. In addition, the Native American Historic Resource Protection Act (PRC Section 5097 et seq.) makes it a misdemeanor punishable b y up to 1 year in jail to deface or destroy a Native American historic or cultural site that is listed or may be eligible for listing in the CRHR.
California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act) (25 USC Chapter 32), enacted in 2001, requires all state agencies and museums that receive state funding and that have possession or control over collections of human remains or cultural items, as defined, to complete an inventory and summary of these remains and items on or before January 1, 2003, with certain exceptions. The California Repatriation Act also provides a process for the identification and repatriation of these items to the appropriate tribes.
California Health and Safety Code Section 7050.5
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. California Health and Safety Code, Section 7050.5, requires that if human remains are discovered in any place other than a dedicated cemetery, no further disturbance or excavation of the site or nearby area reasonably suspected to contain human remains can occur until the County Coroner has examined the remains (Section 7050.5b). If the coroner determines or has reason to believe that the remains are those of a Native American, the coroner must contact the NAHC within 24
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hours (Section 7050.5c). The NAHC will notify the most likely descendant, and with the permission of the landowner, the most likely descendant may inspect the site of discovery. The inspection must be completed within 24 hours of notification of the most l ikely descendant by the NAHC. The most likely descendant may recommend means of treating or disposing of, with appropriate dignity, the human remains, and items associated with Native Americans.
Local
City of San Marcos General Plan
Conservation and Open Space Element
The Conservation and Open Space Element of the City ’s General Plan contains several policies pertaining to the protection of archaeological and historic resources. The following goals and policies apply to the project (City of San Marcos 2012):
Policy COS -2.5: Continue to review future development proposals to ensure that cultural resources (including prehistoric, historic, paleontological, and Senate Bill 18 Tribal resources) are analyzed and conserved in compliance with CEQA requirements.
Goal COS-11: Continue to identify and evaluate cultural, historic, archaeological, paleontological, and architectural resources for protection from demolition and inappropriate actions.
Policy COS -11.1: Identify and protect historic and cultural resources including individual properties, districts, and sites (e.g., archaeological sites) in compliance with CEQA.
Policy COS -11.2: Prohibit the demolition or removal of a historic structure without evaluation of the condition of the structure, the cost of rehabilitation, and the feasibility of alternatives to preservation in place including but not limited to relocation, or reconstru ction off site , and/ or photo-preservation.
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning, of this EIR. As detailed in Section 3.10.4, Project Impact Analysis, the project is consistent with the applicable General Plan goals and policies pertaining to tribal cultural resources.
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 No. 1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources
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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.
3.16.4 Project Impact Analysis
Impacts to tribal cultural resources that may result from ground disturbing activities associated with the proposed project are analyzed below.
Threshold No. 1: Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the si ze 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.
Under California’s Assembly Bill 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.
To date, no TCRs have been identified that would be impacted by project implementation. However, tribal consultation with the City is ongoing, and this EIR will be updated upon conclusion of tribal consultation.
As described above, outreach letters were mailed on March 30, 2021 , 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 representativ es were requested to define a general area where known resources intersect the project APE. To date, two responses have been received. The first response is from the Rincon Band of Luiseño Indians stating the project site is located within the Band ’s specific Area of Historic Interest, and requests a survey of the property, a professional tribal monitor during the survey, a copy of the final study for review and comment, and request for further consultation with the City. The second response is from the Vie jas Band of Kumeyaay Indians, stating the project site has cultural significance or ties to the Kumeyaay Nation and recommends notifying the San Pasqual Band of Mission Indians, requests all National Environmental Policy Act /CEQA/Native American Graves Pro tection and Repatriation Act laws be followed, and requests immediate contact of San Pasqual Band of Mission Indians on any changes or inadvertent discoveries. City Assembly Bill 52 and Senate Bill 18 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).
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Implementation of previously identified mitigation in Section 3.4 of this EIR (MM-TCR-1 through MM-TCR-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 Mitigation Measures
Implementation of mitigation measures MM-TCR-1 through MM-TCR-4 outlined in Section 3.4 of this EIR would be required to ensure any potential impacts to unknown and unanticipated TCRs would remail less than significant.
3.16.6 Conclusion
For reasons described in Section 3.16.4, Project Impact Analysis, implementation of mitigation measures MM-TCR- 1 through MM -TCR-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 proposed Pacific Specific Plan Project (proposed 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:
▪ Pacific Multi-Family Water and Sewer Study by Vallecitos Water District, November 17, 2022 (Appendix L) ▪ Preliminary Drainage Study, prepared by Lundstorm Engineering and Surveying, Inc., February 24, 2023 (included as Appendix E to this EIR).
▪ Storm Water Quality Management Plan, prepared by Lundstrom Engineering and Surveying, Inc., August 15, 2022 (revised February 16, 2023) (included as Appendix G 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
No. 1. Require or result in the relocation or construction of new or expanded water, wastewater treatment or
storm water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant environmental effects.
Less than
Significant
Less than
Significant
Less than
Significant
No. 2. Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry and multiple dry years.
Less than
Significant
Less than
Significant
Less than
Significant
No. 3. Result in a determination by the wastewater
treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s
projected demand in addition to the provider’s existing commitments.
Less than
Significant
Less than
Significant
Less than
Significant
No. 4. Generate solid waste in excess of State or local standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of solid waste reduction goals.
Less than
Significant
Less than
Significant
Less than
Significant
No. 5. Comply with federal, state, or local management
and reduction statutes and regulations related to solid waste.
Less than
Significant
Less than
Significant
Less than
Significant
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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 proposed project.
Water
The project site is located within the Vallecitos Water District (VWD) for water services (Appendix L). According to the City of San Marcos (City) 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 19 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 5,234,000 acre -feet/year for 2020, the MWD UWMP concludes that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2040 under normal, single dry, and multiple dry water years (MWD 2016).
The MWD water demands through normal, single dry year, and multiple dry years are shown in Table 3.17-2.
Table 3.17-2. MWD Water Demands
Average Year
Dates 2020 2025 2030 2035 2040
Total Demands (AFY) 5,219,000 5,393,000 5,533,000 5,663,000 5,793,000 Single Dry -Year
Dates 2020 2025 2030 2035 2040
Total Demands (AFY) 5,234,000 5,409,000 5,549,000 5,679,000 5,808,000 Multiple Dry -Years
Dates 2020 2025 2030 2035 2040
Total Demands (AFY) 5,199,000 5,450,000 5,601,000 5,732,000 5,865,000 Source: MWD 2016.
Notes: AFY = acre-feet/year.
San Diego County Water Authority ( SDCWA or Water Authority ) is the largest member agency of MWD. SDCWA ’s 2020 UWMP was approved on May 27, 2021. SDCWA’s mission is to provide a safe and reliable supply of water to its 24 member agencies serving the San Diego region, which includes VWD. SDCWA is San Diego County’s predominant source of water, supplying from 75% to 95 % of the region’s water needs (SDCWA 20 21). The population within the Water Authority’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 develo p 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 San Diego Association of Governments (SANDAG)
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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 Water Authority’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 Water Authority’s total water demands are projected t o 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 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 12-inch lines in Linda Vista Drive and Pacific Street, and 8-inch lines in La Mirada Drive and South Las Posas Road.
Wastewater
The project site is located within the VWD for sewer services (Appendix L). The VWD currently has a wastewater system that has a total liquids treatment capacity of 12.45 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 . R ecycled water from MRF travels through a 24 -inch pipeline and is sold to the Carlsbad Municipal Water District and Olivenhain Municipal Water District. The Carlsbad Municipal Water District is contracted 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-MG Mahr Reservoir. Of the total 54 MG within the reservoir, 32 MG is allocated to Carlsbad Municipal Water District, and 16 MG 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 one MGD is conveyed for disposal. Under wet weather c onditions, VWD would manage flow via the Mahr Reservoir to ensure flows to Encina Water Pollution Control Facility would not exceed 2.5 MGD.1 According to VWD’s Master Plan, when the pipeline is at capacity, Carlsbad Municipal Water District has agreed to permit VWD 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 on all sides of the project site. There are 8-inch gravity sewer lines in Pacific Street and La Mirada Drive, a 15-inch sewer line in Linda Vista Drive, and parallel 10-inch and 18-inch sewer lines in South Las Posas Road. These gravity sewers all convey flow to South Las Posas Road where they are conveyed south to San Marcos Boulevard and eventually to District Lift Station No. 1.
1 Despite a total capacity of 3 MGD in the failsafe pipeline, permitted wastewater flows are determined by acceptable depth to - diameter ratios to ensure infrastructure longevity and functioning systems. This means that maximum flows to Encina Water Pollution Control Facility will be less than 3 MGD.
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Storm water Drainage
Storm w ater arrives on site via natural rainfall only. Rainfall runoff from the site typically only occurs during a significant storm event. Water that does accumulate on site generally drains in a south -easterly direction toward the northwest corner of Linda Vista Drive and South Las Posas Road. This drainage is collected in a corrugated meatal pipe riser that drains to an 11-foot by 7-foot reinforced concrete box in South Las Posas Road, and eventually flows downstream and discharges to San Marcos Creek. The remainder of the site surface drains to the surrounding streets. All surrounding streets drain via gutter flow to the same corner ( South Las Posas Road and Linda Vista Drive) where runoff is collected by a pair of curb inlets that drain into the same 11-foot by 7-foot reinforced concrete box in South Las Posas Road. There is no off-site run-on to the project site.
Solid Waste
Solid waste disposal in the City is provided by a private franchise hauler, EDCO Waste and Recycling (EDCO), a private waste collection and recycling company that handles all residential, commercial, and industrial collections within the City (City of San Marcos 2012a). Waste collected by EDCO is hauled to the Escondido Resource Recovery Transfer Station. Waste is then transported to the Sycamore Sanitary Landfill in Santee, while recyclable materials are processed at the Escondido Resource Recovery Transfer Station (City of San Marcos 201 2a). The project site would be serviced by EDCO.
The Escondido Resource Recovery Transfer Station has a permitted daily maximum capacity of 2,500 tons . Solid waste is consolidated here and trucked to a landfill for disposal. The transfer station is permitted to operate 7 days per week, 24 hours per day (County of San Diego 2008). The Sycamore Sanitary Landfill has a daily permitted throughput of 5,000 tons/day of solid waste, a remaining capacity of approximately 113,972,637 cubic yards, and an anticipated closure date of 2042 (CalRecycle 2019a).
Electrical and Natural Gas
Electricity and natural gas would be provided by San Diego Gas & Electric (SDG&E) (City of San Marcos 2012 a).
SDG&E provides energy service to an estimated 3.3 million consumers through 1.3 million electric meters and approximately 800,000 natural gas meters in San Diego County and southern Orange County (City of San Marcos 2012a). Electrical facilities throughout the City include a combination of aboveground and underground electrical distribution lines and utilities structures. Electricity to the project site would be provided by electrical distribution lines traversing seven SDG&E overhead utility poles located on La Mirada Drive between South Pacific Street and South Las Posas Road and underground electricity distribution lines that currently service to numerous properties on the north side of La Mirada Drive. SDG&E maintains a natural gas distribution system within La Mirada Drive, South Las Posas Road, Linda Vista Drive, and Pacific Street, which the project would connect to.
Telecommunications
Telecommunications services to the project site may be provided by various distributors . 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. Existing AT&T and Cox telecommunication lines surrounding the project site. Existing overhead pole line on La Mirada Drive between South Pacific Street and South Las Posas Road includes four AT&T poles. Cox Communications cables are attached to five of the SDG&E poles on La Mirada Drive between South Pacific Street and South Las Posas Road.
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3.17.2 Regulatory Setting
Existing federal, state, and local regulations related to water supply, wastewater, and solid waste that are applicable to the proposed 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 is required to monitor water quality and conform to regulatory requirements of the Clean Water Act.
Resource Recovery and Conservation Act
The Resource Recovery and Conservation Act Subtitle D focuses on state and local governments as the primary planning, regulating, and implementing entities for the management of non -hazardous solid waste, such as household solid waste and nonhazardous industrial solid waste. Subtitle D provides regulations for the generation, transportation, and treatment, storage, or disposal of hazardous wastes.
State
Urban Water Management Plans
Urban water purveyors are required to prepare and update a UWMP every 5 years. The UWMPs address water supply, treatment, reclamation, and water conservation, and contain a water shortage contingency plan. Local UWMPs are supplemental to the regional plans prepared by MWD. The Water Conservation Bill of 2009 (SBX7 -7) requires each urban retail water supplier to develop an urban water use target and an interim urban water use target. Notably, SBX7-7 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 its 2015 USMP, and their Board of Directors adopted it 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’s 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 as 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 2022 building standards code
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became effective on January 1, 2023. The mandatory standards require the following measures that relate to utilities and service systems (24 CCR Part 11):
▪ Mandatory reduction in indoor water use through 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
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 , stricter water conservation, 65% diversion of construction and demolition waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar- reflective roofs. CALGreen’s more rigorous Tier 2 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 s 939 and 341
In 1989, Assembly Bill (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 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.
AB 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 the year 2020, and annually thereafter. In addition, AB 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 pr ograms are identified in the individual jurisdiction Source Reduction and Recycling Element and Household Hazardous Waste Element and are intended to r educe costs, streamline administration of programs, and encourage a coordinated and planned approach to integrated waste management.
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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, 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 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 Landscape . 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 General Plan
The General Plan Conservation and Open Space Element includes one goal regarding water supply that is applicable to the proposed 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 proposed 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.
Policy COS-10.1: Promote the curbside recycling program to divert residential refuse from the landfills.
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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 proposed project (City of San Marcos 2012a):
Goal LU-8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
Policy LU -8.1: New development shall pay its fair share of required improvements to public facilities and services.
Policy LU-8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities.
Goal LU-13: Water Service and Supply: Manage and conserve domestic water resources by reducing water usage and waste on a per capita basis, to ensure an adequate water supply for existing and future residents.
Policy LU-13.1: Work closely with local and regional water providers to ensure high quality water supplies are available for the community.
Policy LU-13.2: Actively promote water conservation programs aimed at reducing demand.
Policy LU -13.3: Encourage exploration and use of deep underground wells to reduce reliance on treatable water.
Goal LU-14: Wastewater: Ensure a wastewater system for existing and future development.
Policy LU-14.1: Work closely with local service providers to ensure an adequate wastewater system for existing and future development is in place.
Policy LU -14.2: Ensure development approval is directly tied to commitments for the construction or improvement of primary water, wastewater, and circulation systems.
Goal LU-16: Solid Waste: R educe the amount of waste material entering regional landfills with an efficient and innovative waste management program.
Policy LU -16.1: Work closely with local service providers to ensure adequate solid waste disposal, collection, and recycling services.
Policy LU-16.2: Increase recycling, composting, source reduction, and education efforts throughout the city to reduce the amount of solid waste requiring disposal at landfills.
Goal LU-17: Utilities and Communications: Encourage provision of power and communication systems that provide reliable, effective and efficient service for San Marcos.
Policy LU-17.2: Require all new development and redevelopment to provide the technology to support multiple telecommunications facilities and providers such as multi -media products, wireless technologies, and satellite communications.
Policy LU-17.3: The City shall prohibit above ground utility equipment within any of the pedestrian pathway and street frontage areas. All above ground utilities shall be placed either within; “wet closets”
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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 pla ns for both public and private street frontages and prior to submittal of building permits.
Policy LU -17.4: Require utility location to be shown on all site development plans at the time of development/project application.
The proposed 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 CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to utilities and service systems would occur if the project would:
Threshold No. 1: Require or result in the relocation or construction of new or 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.
Threshold No. 2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years.
Threshold No. 3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.
Threshold No. 4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.
Threshold No. 5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
3.17.4 Project Impact Analysis
Threshold No. 1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication s facilities, the construction or relocation of which could cause significant environmental effects.
Water
The proposed project development would be served by VWD. Multifamily residential sites in the VWD are typically served by on-site private water systems, which consist of separate fire and domestic systems. Private fire systems typically supply on -site fire hydrants and building fire sprinkler systems and require a backflow preventer at the connection to the public water system.
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The project site lies completely within VWD’s existing 855 Zone. Water service to existing development in the area is from connections to the 855 Zone, which includes 12-inch lines in Linda Vista Drive and South Pacific Street, and 8-inch lines in La Mirada Drive and South Las Posas Road.
The 2018 VWD Master Plan based its ultimate water demand planning on the City’s approved General Plan land use designations, which for the project site is Industrial. Table 1 in the Water and Sewer Study prepared for the project (Appendix L) provides the a verage water demand generated both under the density planned for the 2018 Master Plan and with the proposed project. This table shows that the proposed project would increase the projected average water demand from the 2018 Master Plan land use by 73,703 g allons per day (gpd), from 26,552 gpd under the Industrial use, to 100,255 gpd under the proposed residential use (Appendix L).
Water service for potable residential use and fire service to the project site would be provided by VWD. The project would connect to existing 12-inch water lines in Linda Vista Drive and South Pacific Street. Additionally, the project would connect to and upsize approximately 1,458 feet of existing 8-inch ACP to 12-inch PVC along La Mirada Drive from South Las Posas Road to Pacific Street. Water connections are provided in three separate systems suppling the proposed residential areas independently. An 8-inch fire main water line and a 6 -inch domestic potable water line would connect the proposed condominiums to existing water mains in La Mirada Drive and South Pacific Street.
Water would connect to the proposed villas and rowhomes via a connection underneath each driveway entering at La Mirada Drive and the second connection at South Pacific Street. The proposed apartments would provide an 8- inch fire main water line and 6-inch domestic potable water line connecting underneath the driveway to existing infrastructure in La Mirada Drive and a second fire connection in South Las Posas Road. One water main connection would be made for the proposed affordable units. An 8-inch fire main and 6-inch domestic potable water line would connect the affordable units to an existing water main in Linda Vista Drive.
As described in Section 3.17.1, Existing Conditions, 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 Water Authority’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 deve lop 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 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 Water Authority’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 Water Authority’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 was prepared by Vallecitos Water District (VWD) for the proposed project in November 2022 and is included as Appendix L to this EIR. This study determined that the project site would be served by the District 855 Zone resulting in static pressures ranging from 132 pounds per square inch to 141 pounds per square inch, and that this water pressure would be adequate to meet all domestic and landscape requirements for the proposed project. The estimated total water use for the proposed project is 100,255 gpd. As concluded in Appendix L, VWD currently has water capacity available to serve the project as proposed with the conditions outlined in the Water and Sewer Study.
As outlined in Section 3.12, Population and Housing, of this EIR, development of 449 residential dwelling units at the project site would generate approximately 1,388 people. Although not all residents of the development would be new to the City of San Marcos, residential development on the project site would still result in unplanned growth for the City, as a residential land use for the project site was not accounted for in the City’s General Plan since the
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project site is zoned for Industrial use. Development of the project is unlikely to directly induce further population growth in the area. This is because the area surrounding the project site is already developed. Further, because the proposed project sit e is in an infill area with existing roads and utilities, no indirect impacts associated with the extension or construction of roads or expansion of public utilities are expected to occur as a result of the proposed project. The City of San Marcos is forec asted to grow from 98,915 persons in 2020 to 109,095 persons in 2035, which is a population increase of 10,180 (SANDAG 2013). Additionally, SANDAG allocated 3,116 housing units to the San Marcos area for the 2021–2029 Housing Element Cycle (SANDAG 2020). Approval of the proposed project would help the City accommodate the substantial population growth projected to occur within the City and the need for housing. Additionally, the City of San Marcos charges fees to process plans submitted for residential proj ects and to finance the provision of important services that are needed to accommodate housing and population growth.
Fees and exactions are used to finance public facilities, including water and sewer infrastructure.
Therefore, due to the location of the project site in an urbanized area that is currently served by existing facilities, and based on the information outlined above, the proposed project would not require or result in the relocation or construction of new water facilities that could cause significant environmental impacts to water services. Impacts would be less than significant.
Wastewater
As described above, the project proposes development of 449 residential units, which would increase the intensity of uses on the project site and result in increased wastewater generation. A Water and Sewer Study was prepared by Vallecitos Water District for the proposed project and is included as Appendix L to this EIR.
Similar to water generation, the 2018 VWD Master Plan based its ultimate wastewater generation planning on the City’s General Plan land use designations, which for the project site is Industrial. Table 4 in Appendix L provides the average wastewater flow generated both under the density planned for the 2018 Master Plan and with the proposed project. This table reflects that the project would increase the projected average wastewater generation from the 2018 Master Plan land use assumptions by 55,637 gpd, fr om 23,233 gpd under the existing Industrial land use designation to 55,637 gpd under the proposed project.
The Water and Sewer study modeling results show that no deficiencies were identified under the currently approved density under peak wet weather flows during ultimate build-out conditions of the project. Lift stations are sized for peak wet weather flow with manufacturer’s recommended cycling times for pumping equipment. Since the proposed project is not located in a sewer shed that is served by a lift station, there would be no lift station upgrade requirements for this project (Appendix L).
There are existing gravity sewer lines on all sides of the project site, including 8 -inch gravity sewer lines in South Pacific Street and La Mirada Drive, a 15-inch sewer line in Linda Vista Drive, and parallel 10-inch and 18-inch sewer lines in South Las Posas Road. These gravity sewers all convey flow to Las Posas Road where they are conveyed south to San Marcos Boulevard and eventually to District Lift Station Number 1. Sewer service would connect to three separate sewer systems within the project site. The proposed condominiums would provide two 8-inch connections to the existing 8-inch sewer main in La Mirada Drive. The proposed apartments would connect an 8- inch sewer line to the either existing 10 -inch or 15 -inch sewer main in South Las Posas Road. The proposed affordable units would connect one 8-inch sewer line to the existing 15-inch line in Linda Vista Drive (Appendix L).
Buildout of the proposed project would generate approximately 55,637 gpd of wastewater (Appendix L).
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Wastewater generated by the proposed project would be treated by the Meadowlark Water Reclamation Facility.
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 proposed project, and therefore new wastewater treatment facilities would not be needed.
The City requires that VWD provide a letter of Sewer Availability for proposed developments within VWD. VWD conducted a sewer study for the proposed development to determine whether the current infrastructure is sufficient to accommodate the development project, and/or to provide recommendations for capital improvements to provide service. As concluded in the Water and Sewer Study (Appendix L), the District currently has sewer capacity available to serve the project as proposed with conditions outlined in t he Water and Sewer Study. T he applicant would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District 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 proposed project is not anticipated to exceed current capacities or significantly impact existing wastewater treatment systems. Further, to the extent the proposed 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, etc.), and would not cause significant environmental effects. Therefore, impacts relative to wastewater services would be less than significant.
Storm water Drainage
Development of the proposed project would increase the impervious area on site and increase stormwater runoff in comparison to existing conditions. However, as described in Section 3.9 of this EIR, storm drainage components recommended by the Preliminary Drainage Study (Appendix E) 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.
Storm w ater arrives on site via natural rainfall only. Rainfall runoff from the site typically only occurs during a significant storm event. Storm water that does accumulate on site generally drains in a south -easterly direction toward the northwest corner of Linda Vista Drive and South Las Posas Road. This drainage is collected in a corrugated meatal pipe riser that drains to an 11-foot by 7-foot reinforced concrete box in South Las Posas Road, and eventually flows downstream and discharges to San Marcos Creek. The remainder of the site surface drains to the surrounding streets. All surrounding streets drain via gutter flow to the same corner ( South Las Posas Road and Linda Vista Drive) where runoff is collected by a pair of curb inlets that drain into the same 11 -foot by 7-foot reinforced concrete box in South Las Posas Road. There is no off -site run -on to the project site. Per Municipal Separate Storm Sewer System Permit requirements, stormwater flows on site would be conveyed to biofiltration basins and underground storage systems throughout the project site, where water would be treated prior to being discharged. The project has considered stormwater flows and designed the grading plan to direct all surface runoff to catch basins in private drives and drive a isles. Once captured, stormwater would be conveyed through a series of pipes and storm water quality facilities and conveyed to the existing box culvert in South Las Posas Road. Treated runoff would f ollow the same drainage pattern as currently exists. 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 proposed project would incorporate appropri ate design of on - and off -site drainage facilities and would prepare and implement Best
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Management Practices in accordance with a stormwater pollution prevention plan during construction and Stormwater Quality Management Plan , for post-development.
Implementation of all recommendations from the Preliminary Drainage Study and SWQMP 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, etc.), and has not been identified to cause significant environmental effects. Therefore, impacts would be less than significant. Please refer to Section 3.9 for additional discussion related to drainage.
Electric Power
As discussed in Section 3.5 of this EIR , implementation of the proposed 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 HVAC) would be provided by SDG&E. The amount of electricity used during construction of the proposed 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 2.49 million kilowatt- hours of electricity per year. For comparison, the existing Industrial land use/zoning is estimated to use approximately 14.02 million kilowatt-hours of electricity per year (Appendix B). Therefore, implementation of the proposed project would result in the consumption of less electricity than compared to development under the existing zoning. Additionally, the project would be required to implement, as applicable, the City’s Climate Action Plan Consistency Checklist measures that would reduce operational electricity consumption, including PDF-GHG-5 (install electric or solar water heater).
The project would be required to include various on -site features and measures to reduce the proposed project’s energy consumption, which includes incorporating zero net energy features into the building design and developing consistent with every mandatory project de sign feature in the Climate Action Plan Consistency Worksheet. The project would be built under the 2019 Title 24 standards or newer standards. 2019 Title 24 homes would use about 53% less energy than those under the 2016 Title 24 standards. Additionally, the project would be required to install smart meters and programmable thermostats, cool roof materials, efficient lighting in all buildings and light control systems, where practical, which would reduce lighting energy by 20%.
Electricity would be provided by SDG&E. Electrical facilities throughout the City include a combination of aboveground and underground electrical distribution lines and utilities structures. The proposed project would require constructing private utility lines to connect to existing electrical lines in the area. Additionally, construction of the project proposes undergrounding of approximately 1,400 feet of existing overhead power line at the northern boundary of the project site, along La Mirada Drive.
Undergrounding this transmission line is not anticipated to result in a significant environmental effect.
Undergrounding would generally reduce aesthetic impacts and improve public safety within an already urbanized
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area. Construction impacts associated with undergrounding would be temporary and would occur within the existing right-of-way. Associated construction activities would be addressed through City conditions required of the project.
In summary, although electricity consumption would increase at the project site over current, vacant conditions , electrical power consumption is expected to be less than that of an industrial development under the site’s current land use/ zoning designations. Residential development on site is not expected to exceed existing capacity of servicing infrastructure. Undergrounding of existing infrastructure may be required but would not result in a significant impact. Therefore, implementation of the proposed 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 proposed project. The proposed residential uses are to use approximately 3.27 million kilobtus (kBTU) of natural gas per year, equivalent to 32,669 therms of natural gas per year. For comparison, the existing Industrial land use/zoning is estimated to use approximately 14.28 million kBTU of natural gas per year equivalent to 142,810 therms of natural gas per year (Appendix B). Therefore, the proposed projec t would consume less natural gas when compared to development under the existing zoning. Further, the project would be required to implement project design feature(s) and comply with green building standards to reduce energy consumption.
As described above, natural gas would be provided by SDG&E. SDG&E maintains a gas distribution system within La Mirada Drive, South Las Posas Road, Linda Vista Drive, and Pacific Street, which would serve the project site.
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 proposed project would not require or res ult in the relocation or construction of new or expanded natural gas facilities, and impacts would be less than significant.
Telecommunications
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and othe r 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 proposed or anticipated for the proposed project. Due to the existing infrastructure served in the surrounding project area, the proposed project would not result in impacts associated with the construction or expansion of telecommunications, and impacts are determined to be less than significant.
Threshold No. 2: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As discussed in response to Threshold No. 1, the proposed project would be served by VWD. Per the Water and Sewer Memorandum (Appendix L), the proposed project is anticipated to use an estimated 100,255 gpd of water, including an estimated open space water use of 3,620 gpd. This equates to approximately 114 acre-feet/year.
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 5,234,000 acre-feet/year in 2020, the MWD UWMP demonstrates that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2040 under normal, single dry, and multiple dry water years (MWD 2016). The
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114.6-acre-feet/year demand generated by the project would present an insignificant increase in water demand relative to the annual water demand projected by the MWD’s UWMP.
Further, the project site would be developed in compliance with the California Green Building Code , which implements water efficiency standards for appliances and fixtures. Compliance with CALGreen would further reduce project water usage in combination with VWD and MWD’s ongoing water conservation practices. As concluded in Appendix L, VWD currently has water capacity available to serve the project as proposed with the conditions outlined in the Water and Sewer Study. The project would be required to pay a ll applicable Water and Wastewater Capital Facility Fees in affect at the time service is committed in accordance with the District rules and regulations.
Compliance with these regulations and conservation measures will ensure sufficient water supplies are available to service the proposed project. Impacts to available water supplies would be less than significant.
Threshold No. 3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
As discussed under Threshold No. 1, wastewater generated by the proposed project would be treated by MRF. MRF has a capacity of 5 MGD, with a wet weather treatment capacity of 8 MGD , and treats wastewater at 0.25 MGD .
The proposed project is estimated to generate 55,637gpd of wastewater, or approximately 1.49% of the MRF 5 MDG capacity. It is expected that the MRF would be able to adequately treat wastewater flows from the project.
As described above, sewer facilities to serve the project would require the construction of private on-site sewer lines connecting to the public system at one or more locations. As concluded in Appendix L, V WD currently has sewer capacity available to serve the project as proposed with the conditions outlined in the Water and Sewer Study. As discussed in the Water and Sewer Memorandum (Appendix L), the applicant of the project would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations. With implementation of City and VWD requirements for sewer service, and considering the scope of existing and proposed infrastructure, the proposed project is not anticipated to exceed current capacities or significantly impact existing wastewater treatment systems. Therefore, impacts relative to the provision of wastewater services would be less than significant.
Threshold No. 4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Construction of the proposed project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, packing materials, and plastics. Operation of the proposed project would represent an increase in intensity of uses and generation of solid waste on the project site compared to existing conditions. Solid waste generated by the project would be serviced by EDCO, and solid waste would then be transferred to Sycamore Landfill. According to CalRecycle, the facility has a daily per mitted 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 2019b). 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 proposed project was estimated using CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019 b). It is estimated that the project ( 449 units) would generate approximately 5,491.27 pounds of solid waste per day (12.23 pounds per household). This does not consider any waste diversion through recycling. According to CalRecycle, the City of San Marcos has a disposal
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rate target of 8.9 pounds per person per day. If the City meets this target, the City is considered in compliance with the 50 % diversion requirement of AB 939. The most recent data from CalRecycle identifies the annual per capital disposal rate is 5.4 pounds per person per day (CalRecycle 201 9b). 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 proposed 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 impacts related to solid waste are determined to be less than significant.
Threshold No. 5: Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
As described in response to Threshold No. 4, the proposed 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 21440 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 Mitigation Measures
Impacts to utilities and service systems would be less than significant, and no mitigation is required.
3.17.6 Conclusion
Project implementation would result in an increase in the need for water, wastewater, stormwater, electrical power, natural gas, telecommunications, 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
This section of the Environmental Impact Report (EIR) evaluates the potential impacts associated with wildfire for the proposed Pacific Specific Plan Project ( proposed project ). This section presents the existing conditions, regulatory framework, impacts of the proposed project on the environment, and proposed mitigation measures to mitigate any identified significant wildfire -related impacts. Fire protection services for the pr oject have been addressed in Section 3.13, Public Services.
The analysis herein relies on the following technical studies and supporting documentation:
▪ Fire Protection Plan for the Pacific Project, prepared by Dudek, February 2023 (Appendix N to this EIR) Table 3.18-1 summarizes the wildfire analysis, by threshold.
Table 3.18-1. Wildfire Summary of Impacts
Threshold of Significance
Project -
Level
Impact
Cumulative -
Level Impact
Significance
Determination
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
No. 1. Substantially impair an adopted emergency
response plan or emergency evacuation plan.
Less than
Significant
Less than
Significant
Less than
Significant
No. 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
No. 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
No. 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
The entirety of the project site lies within the local responsibility area as a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) by the California Department of Forestry and Fire Protection (CAL FIRE ) and High Fire Hazard Severity Zone, as designated by the City of San Marcos in the City’s General Plan Safety Element. The Fire Protection Plan (FPP) prepared for the project (included as Appendix N to this EIR), and the analysis herein, follow the fire hazard determination made by the City.
The project site is located in an urban setting and is considered an infill site. The project site is currently vacant , has no existing impervious areas , and site surface conditions generally consist of rolling unimproved earthen terrain, with native grasses and vegetation. The project site is immediately bordered by S outh Las Posas Road to
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the east, Linda Vista Drive to the south, La Mirada Road along the northern boundary and Pacific Street abuts the property’s western boundary.
Surrounding land uses include industrial uses to the north, south, and west, and commercial uses to the east, specifically the Grand Plaza shopping center is located directly across South Las Posas Road. The 24-acre Bradley Park is located across from the project site’s southwestern corner. Residential uses are located to the south and west of Bradley Park. Surrounding land uses outside of the immediately adjacent industrial and commercial land uses include designated parks, single and multifamily residenti al, and schools/educational facilities. The closest freeway is State Route 78 located approximately 0.44 miles north of the project site.
Dudek conducted a Project site evaluation on November 9, 2021, in order to confirm/acquire site information, document existing site conditions, and determine potential actions for addressing the protection of the proposed project’s structures. While on site, Dudek’s fire planners assessed the area’s topography, natural vegetation, and fuel loading, surrounding land use, and general susceptibility to wildfire. The project site ’s existing setting as it relates to wildfire is summarized below.
Site Characteristics and Fire Environment
Fire environments are dynamic systems and include many types of environmental factors and site characteristics.
Fires can occur in any environment where conditions are conducive to ignition and fire movement. Areas of naturally vegetated open space are typ ically comprised of conditions that may be favorable to wildfire spread. The three major components of the fire environment are topography, climate, and vegetation (fuels). The state of each of these components and their interactions with each other determ ines the potential characteristics and behavior of a fire at any given moment. It is important to note that wildland fire may transition to urban fire if structures are receptive to ignition. Structure ignition depends on a variety of factors and can be pr evented through a layered system of protective features including fire-resistive landscapes directly adjacent to the structure(s), application of known ignition resistive materials and methods, and suitable infrastructure for firefighting purposes. Understanding the existing wildland vegetation and urban fuel conditions on and adjacent to the project site is necessary to understand the potential for fire within and around the proposed project (Appendix N).
Topography
The project site is relatively flat, ranging in elevation from approximately 527 feet above mean sea level in the southeast portion of the project area to 551 feet in the northwest corner of the project site.
Climate
North San Diego County and the project area are influenced by the Pacific Ocean and are frequently under the influence of a seasonal, migratory subtropical high -pressure cell known as the “Pacific High.” Wet winters and dry summers with mild seasonal changes characterize the Southern Cal ifornia climate. This climate pattern is occasionally interrupted by extreme periods of hot weather, winter storms, or dry, easterly Santa Ana winds. The average high temperature for the project area is approximately 76°F, with daily highs in the summer and early fall months (June–September) exceeding 88°F. Precipitation typically occurs between December and March with an average rainfall of 16.22 inches (Appendix N).
The prevailing wind pattern is from the west (onshore), but the presence of the Pacific Ocean causes a diurnal wind pattern known as the land/sea breeze system. During the day, winds are from the west –southwest (sea), and at night winds are from the northe ast (land), averaging 2 mph. During the summer season, the diurnal winds may
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average slightly higher (approximately 16 mph) than the winds during the winter season due to greater pressure gradient forces. Surface winds can also be influenced locally by topography and slope variations. The highest wind velocities are associated with downslope, canyon, and Santa Ana winds.
Typically, the highest fire danger is produced by the high -pressure systems that occur in the Great Basin, which result in the Santa Ana winds of Southern California. Sustained wind speeds recorded during recent major fires in San Diego County exceeded 30 mph and ma y exceed 50 mph during extreme conditions. The Santa Ana wind conditions are a reversal of the prevailing southwesterly winds that usually occur on a region-wide basis during late summer and early fall. Santa Ana winds are warm winds that flow fr om the higher desert elevations in the north through the mountain passes and canyons. As they converge through the canyons, their velocities increase.
Consequently, peak velocities are highest at the mouths of canyons and dissipate as they spread across va lley floors. Santa Ana winds generally coincide with the regional drought period and the period of highest fire danger.
The project site is affected by strong winds, such as Santa Ana winds (Appendix N).
Vegetation Fuels
Seven vegetation communities or habitat types occur within the project site and within the biological study area:
vernal pools, Diegan coastal sage scrub (including disturbed and baccharis -dominated), native grassland, non - native grassland, disturbed habitat, and developed. The acreage of each on-site vegetation community or land cover type is provided in Table 1 in the FPP (Appendix N to this EIR) and in Section 3.3, Biological Resources.
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 (flowering, retention of dead plant material), physical structure (bark thickness, leaf size, branching patterns), and overall fuel loading. For example, the native shrub species that compose the coastal sage scrub and chaparral plant communities on site are considered to higher potential hazards (higher intensity heat and flame length) than grass -dominated plant communities (fast-moving, but lower intensity) if ignition occurred. The corresponding fuel models for each of these vegetation types are designed to capture these differences.
Vegetation plays a significant role in fire behavior and is an important component of the fire behavior models discussed in this EIR section and throughout the FPP prepared for the project (Appendix N) . Fire presence and absence at varying cycles or regimes disrupts plant succession, setting plant communities to an earlier state where less fuel is present for a time as the plant community begins its succession again. High-frequency fires tend to convert shrublands to grasslands or maintain grasslands, and f ire exclusion tends to convert grasslands to shrublands over time as shrubs sprout back or establish and are not disturbed by repeated fires. In general, biomass and associated fuel loading will increase over time, assuming that disturbance (e.g., fire, gr azing, or farming) or fuel reduction efforts are not diligently implemented. It is possible to alter successional pathways for varying plant communities through manual alteration.
Fire History
Fire History data provides valuable information regarding fire spread, fire frequency, ignition sources, and vegetation/fuel mosaics across a given landscape. One important use for this information is as a tool for pre - planning. It is advantageous to know which areas may have burned recently and therefore may provide a tactical defense position, what type of fire burned on the site, and how a fire may spread. Fire history represented in th e FPP (Appendix N) uses the Fire and Resource Assessment Program data base. The Fire and Resource Assessment Program summarizes fire perimeter data dating to the late 1800s but is incomplete due to the fact that it only includes fires over 10 acres in size and has incomplete perimeter data, especially for the first half of the twentieth
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century (Appendix N). However, the data does provide a summary of recorded fires and can be used to show whether large fires have occurred in the project area, which indicates whether they may be possible in the future. According to available data from the CAL FIRE in the Fire and Resource Assessment Program database, 26 fires have burned within a 5-mile radius of the project site, with no fires occurring on the project site since the beginning of the historical fire data record. Recorded wildfires within 5 miles range from approximately 12 acres to 40,248 acres (1943 Fire). The second-largest fire (Harmony Fire-1996) was larger than 9,359 acres, and the average fire size is 848 acres (not including the 1943 Fire and Harmony Fire or fires smaller than 10 acres). The Cocos Fire (2014) is the most recent fire, which occurred approximately 2.5 miles southeast of the project site. Smaller fires (less than 10 acres) are not included in the FPP analysis but may be recorded with the San Marcos Fire Department (SMFD).
Based on an analysis of this fire history data set, specifically, the years in which the fires burned, the average interval between wildfires in the area was calculated to be 3 years with intervals ranging between 0 and 17 years. Based on this analysis, it is expected that wildland areas within 5 miles of the project site w ould be subject to wildfire approximately every 3 years with the realistic possibility of shorter interval occurrences, as observed in the fire history record. However, this fire return interval does not equate to the project being threatened every 4 years or less, but to wildfires burning in fuels within 5 miles of the project site. Based on fire history, wildfire risk for the project site is associated primarily with a Santa Ana wind-driven wildfire burning or spotting onto the project site from the northeast, although a fire approaching from the south during more typical on -shore weather patterns is possible. However, because the fuel bed is minimal and occurs within an entirely develope d and urban area, the wildfire threat is considered very low. Even if a vegetation fire did ignite on the post -project open space area, fuels, terrain, and extremely short duration for the wildfire based on lack of fuels to sustain it would result in a minimal threat.
Emergency Response and Service
The project site is located within the jurisdiction of the SMFD, and consequently, SMFD provides the initial response.
The SMFD jurisdictional response area encompasses approximately 33 square miles with a population of approximately 96,000 residents. The SMFD currently operates four Fire Stations, two of which are analyzed herein due to their proximity to the project site and could respond to an incident at the project site. Primary response would be from SMFD Station 2, with SMFD Station 1 and Vista Fire Department Station 4 responding as necessary (Appendix N).
Within the area ’s emergency services system, fire and emergency medical services are provided by Fire Departments (San Marcos Fire Department and Vista Fire Department) County Service Areas, and CAL FIRE.
Generally, each agency is responsible for structural fire protectio n and wildland fire protection within their area of responsibility. However, mutual aid agreements enable non -lead fire agencies to respond to fire emergencies outside their district boundaries. In the project area, fire agencies cooperate on a statewide master mutual aid agreement for wildland fires, and there are mutual aid agreements in place with neighboring fire agencies (North County Boundary Drop Program) that typically include interdependencies that exist among the region ’s fire protection agencies for structural and medical responses but are primarily associated with the peripheral “edges” of each agency’s boundary. These agreements are voluntary, as no local governmental agency can exert authority over another (Appendix N).
Table 3.18-2 presents a summary of the location, fire apparatus equipment, staffing levels, maximum travel distance, and estimated travel time for the two nearby SMFD stations that would respond to a fire or medical emergency at the project site. Travel distances are derived from Google road data while travel times are calculated applying the nationally recognized RAND Corporation formula used by the Insurance Services Office Public Protection Classification Program’s Response Time Standard: (T=0.65 + 1.7D), where T=time and D=distance). The response travel time formula discounts speed for intersections, vehicle deceleration, and acceleration, and does not include turnout donning time.
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Table 3.18-2. SMFD Responding Stations
Station Location Equipment Staffing
Maximum
Travel
Distance a
Travel
Time b
Total
Response
Time c
SMFD
Station 1
180 W. Mission
Road San Marcos,
California
▪ Paramedic
Engine Co.
▪ Pierce 100-foot
MDL Tiller and
Body Assembly
quintuple
combination
pumper.
▪ Type 3 Engine
▪ Paramedic
Ambulance
▪ Battalion Chief
On duty: 10 2.33 mi. 4 minutes
37 secs.
6 minutes
37 secs
SMFD
Station 2
1250 S. Rancho
Santa Fe Road
San Marcos,
California
▪ Paramedic
Engine Co.
▪ Paramedic
Ambulance
On-duty: 5 2.23 mi. 4 minutes
26 secs.
6 minutes
26 secs
VFD
Station 4
2121 Thibodo
Road
Vista, California
▪ Paramedic
Engine Co.
▪ Paramedic
Ambulance
On-duty: 5 2.73 mi. 5 minutes
17 secs.
7 minutes
17 secs
Notes:
a Distance measured to the central portion of the project site, refer to Figures 9 to 11 in Appendix N to this EIR. b Application of the Insurance Services Office formula, T=0.65+1.7(Distance), a 35-mph travel speed, and does not include turnout time. c Application of the Insurance Services Office formula, T=0.65+1.7(Distance), a 35-mph travel speed, plus an additional 2 minutes for dispatch and turnout time.
Based on the project site location in relation to existing SMFD stations, travel time to the project site for the first responding engine from SMFD Station 2 is 4 minutes and 26 seconds to the central portion of the project site, entering from the furthest ingress/egress point on La Mirada Drive. Travel time for secondary response is approximately 4 minutes and 37 seconds. However, travel time does not account for dispatch and turnaround time.
In order to estimate a total response time, an additional 2 minutes were added to the total travel time. This results in an estimated response of 6 minutes and 26 seconds for project from SMFD Station 2. The total secondary response for SMFD Station 1 would be approximately 6 minutes and 37 seconds, and approximately 7 minutes and 17 seconds from VFD Station 3. SMFD’s internal response time standard is to have the first arriving fire apparatus on site within 8 minutes (average maximum initial response of no more than 8 minutes for fire apparatus and 9 minutes for ambulance, 90% of calls).
3.18.2 Regulatory Setting
Existing federal, state, and local regulations related to wildfire that are applicable to the proposed project are summarized below.
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Federal
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.
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 representing 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. The CFC 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 are required to protect f ire and life safety. These measures may include construction standards, separations from property lines, and specialized equipment. To ensure these safety measures are met, the CFC employs a permit system based on hazard classification. The CFC is updated every 3 years. SMFD has adopted the CFC by reference in its own Fire Code.
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, construction, and development in State Responsibility Areas. Title 14 regulates that the future design and construction of structures, subdivisions, and developments in State Responsibility Areas shall provide for basic emergency access and perimeter wildfire protection measures.
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
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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 (PRC).
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 us e 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 comprehensive 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 Plans; improve regulatory effectiveness, compliance monitoring, and reporting pursuant to PRC 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 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.
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San Marcos Fire Department Hazard Risk Analysis and Wildland Urban Interface Community Wildfire Protection Plan
The Community Wildfire Protection Plan, adopted in December 2007 (SMFD 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. SMFD also published the Hazard Risk Analysis for internal City use, incorporating new and existing information relating to wildfire risk within the City to better quantify true risk and management needs. The Hazard Risk Analysis quantifies, clarifies, and manages the wildland urban interface responsibility and meets the requirements of the federal Healthy Forests Restoration Act of 2003 for community fire planning.
City of San Marcos, Ordinance 2003 -1216
The City Ordinance 2003-1216 amends Chapter 17.64 of the 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.
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 wildfire:
Goal LU-8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
Policy LU -8.1: New development shall pay its fair share of required improvements to public facilities and services.
Policy LU-8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities.
Goal LU -10: Fire protection, emergency services, and law enforcement: Provide effective, high -quality and responsive services.
Policy LU-10.1: Provide demand -based fire -fighting and emergency medical services infrastructure, equipment, and personnel to provide a high level of fire, emergency medical, and law enforcement service in San Marcos to meet existing and future demands.
Policy LU-10.2: Work closely with the County of San Diego 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.
Policy LU-10.3: Continue to conduct Public Outreach and education regarding fire safety and crime prevention within San Marcos.
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.18-9
Safety Element
The Safety Element of the San Marcos General Plan contains the following goals and policies pertaining to wildfire that apply to the proposed project:
Goals S-3: Minimize injury, loss of life, and damage to property resulting from structure or wildland fire hazards.
Policy S -3.1: Require development to be located, designed and constructed to provide adequate defensibility and reduce the risk of structural loss and life resulting from wildland fires.
Development will consider hazards relative to terrain, topography, accessibility an d proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead fire sprinklers.
Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire.
Advocate and support regional coordination among fire protection and emergency service providers.
Policy S-3.3: Require development to provide additional access roads when necessary to provide for safe access of emergency equipment and civilian evacuation concurrently.
Policy S-3.4: Coordinate with fire protection and emergency service providers to assess fire hazards before and after wildfire events to adjust fire prevention and suppression needs, as necessary, commensurate with both short- and long-term fire prevention needs.
Goal S-5: Establish and maintain an effective emergency response program to respond to disasters and maintain continuity-of-life support functions during an emergency.
Policy S-5.3: Develop, implement, and maintain an effective evacuation program for areas of risk in the event of a disaster.
The proposed 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 proposed project is consistent with the overall goals and policies of the General Plan pertaining 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:
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
Threshold No. 1: Substantially impair an adopted emergency response plan or emergency evacuation plan.
Threshold No. 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.
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.18-10
Threshold No. 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 No. 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 No. 1: Substantially impair an adopted emergency response plan or emergency evacuation plan.
As described in FPP prepared for the project (Appendix N to this EIR), the project site lies within an area considered a Non-High Hazard Severity Zone, as designated by the City of San Marcos and CAL FIRE. The existing project site is a vacant lot. Implementation of the proposed project would likely reduce the potential for wildfire hazards on site as a result of development and management of designated open space areas.
The project site is located within the jurisdiction of SMFD, and consequently, SMFD provides the initial response.
The SMFD jurisdictional response area encompasses approximately 33 square miles with a population of approximately 96,000 residents. The SMFD currently operates four Fire Stations, two of which are analyzed herein due to their proximity to the project site and could respond to an incident at the project site. Primary response would be from SMFD Station 2, with SMFD Station 1 and VFD Station 4 responding as necessary (Appendix N). Within the area’s emergency services system, fire and emergency medical services are provided by Fire Departments (San Marcos Fire Department and Vista Fire Department) County Service Areas, and CAL FIRE. Generally, each agency is responsible for structural fire protection and wildland fire protection within their area of responsibility.
However, mutual aid agreements enable non-lead fire agencies to respond to fire emergencies outside their district boundaries. Table 3.18-2 presents a summary of the location, fire apparatus equipment, staffing levels, maximum travel distance, and estimated travel time for the two nearby SMFD stations that would respond to a fire or medical emergency at the project site.
Based on the project site location in relation to existing SMFD stations, travel time to the project site for the first responding engine from SMFD Station 2 is 4 minutes and 26 seconds to the central portion of the project site, entering from the furthest ingress/egress point on La Mirada Drive. Travel time for secondary response is approximately 4 minutes and 37 seconds. However, travel time does not account for dispatch and turnaround time.
In order to estimate a total response time, an additional 2 minutes were added to the total travel time. This results in an estimated response of 6 minutes and 26 seconds for project from SMFD Station 2. The total secondary response for SMFD Station 1 would be approximately 6 minutes and 37 seconds and approximately 7 minutes and 17 seconds from VFD Station 3. SMFD’s internal response time standard is to have the first arriving fire apparatus on site within 8 minutes (average maximum initial response of no more than 8 minutes for fire apparatus and 9 minutes for ambulance, 90% of calls). The project would conform with SMFD’s internal response time standard and would not have an overall impact on SMFD’s ability to meet its average response goals.
The SMFD estimates approximately 11,486 total annual calls (Nailon, pers. comm., 2021) and a City population of approximately 95,000 (SMFD 2021). The per capita call volume is roughly 0.12 for the City of San Marcos. As of 2020, the City of San Marcos has a person per household ratio of 3.09 (DOF 2020). Using this household ratio of
3.09, the development of 4 49 residential dwelling units at the Project site would generate approximately 1, 388 people. The emergency service level analysis was based on the maxi mum occupancy level and the project is expected to generate roughly 167 calls per year, most of which are expected to be medical-related calls, consistent
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.18-11
with typical emergency call statistics. Service level requirements are not expected to be significantly impacted with the increase of approximately 1 67 calls per year or 0.5 calls per day for a station (SMFD Station 2) that currently responds to roughly 18 calls per day (6,502 calls per year) in its primary service area. Therefore, the project is not expected to cause a decline in SFMD’s emergency response times. Additional response, rounding out the effective firefighting force (the manpower needed to effe ctively fight a structure fire and/or respond to serious medical emergency) would be provided by SMFD Stations 1 and VFD Station 4.
According to the City’s 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). The proposed project would be required to abide by the standards set forth in the San Marcos Emergency Operations Plan. Implementation of the proposed project is not expected to impact any roadway or stagi ng 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 proposed project would be required to present development plans that afford fire and emergency responders suitable fire access roads dimensions and surfaces ( 5 CFC Section 503.1 through Section 503.4), an adequate number of emergency rated entrances to the community (CFC Appendix D, Section D106), and entryway gate access for first responders (5 CFC, Section 503.6). The proposed points of entry and private driveways would be reviewed by SMFD and would be required to meet the qualifications for emergency access to and from the project site.
As outlined in the FPP prepared for the project (Appendix N), the project, once developed, would not facilitate wildfire spread and would reduce projected flame lengths to levels that would be manageable by firefighting resources for protecting the project’s structures, especially given the ignition resistance of the structures and the planned ongoing maintenance of the entire site landscape.
As determined in the FPP, the project would conform with SMFD ’s internal response time standard and would not have an overall impact on SMFD ’s ability to meet its average response goals. The project would not conflict with any applicable emergency or evacuation plan, and it is determined that impacts related to impairment of an emergency response plan or emergency evacuation plan as a result of the proposed project would be less than significant .
Threshold No. 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.
As described in the FPP prepared for the project (Appendix N to this EIR) The project site lies within an area considered a Non-High Hazard Severity Zone, as designated by the City of San Marcos and CAL FIRE. Fire hazard designations are based on topography, vegetation, and weather, amongst other factors. The project site is within a developed City landscape, surrounded by urban land uses on all sides, and the project site is relatively flat.
With the conversion of the landscape to ignition -resistant development and the annual weed abatement on the preserved areas of the site, wildfires would not have fuels needed to spread on site. Given the climatic, vegetative, topographic characteristics, and local fire history of the area, the Project Site, once developed, is determined to not be subject to wildfires. The potential for off-site wildfire encroaching on or showering embers on site is considered very low (Appendix N).
Because the entire site will be provided annual weed abatement, there is no requirement for fuel modification zones. The Project owners will provide sitewide maintenance in the landscaped areas and will abate the preserved portions of the site by providing appropriate vegetation management to the satisfaction of the SMFD. Due to the
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.18-12
urban location of the site, and the existing and proposed topography of the site, implementation of the proposed project would not exacerbate wildfire risks resulting in exposing occupants to potential hazards. Therefore, impacts are determined to be less than significant.
Threshold No. 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.
As previously described, t he project site is an undeveloped lot that is relatively flat and shows signs of previous disturbance. The proposed redesignation of the project site from Industrial to Residential use would likely reduce the potential for wildfire hazards on site as a result of typical activities associated with each land use. The proposed project would not include associated infrastructure that may exacerbate fire risk. Additionally, the proposed project would be required to comply with all applicable state and local fire codes, including compliance with the California Fire Code as adopted by the City of San Marcos and SMFD, which require a design that affords fire and emergency responders suitable fire access roads dimensions and surfaces (5 CFC, Section 503.1 through 503.4); an adequate number of emergency rated entrances to the community (CFC Appendix D, Section D106); and entryway gate access for first responders (5 CFC Section 503.6). As determined in the FPP prepared for the proposed project (Appendix N to this EIR), SMFD’s existing Stations 1 and 2 would adequately serve the project site while maintaining SMFD’s response goals.
While the proposed project would require the installation of water sources and other underground utilities, these would not exacerbate fire risks, as these improvements would be constructed within an existing right -of-way or within the project site boundar y. No overhead utilities are proposed as part of the project. The proposed project would not require the installation or maintenance of such infrastructure that would exacerbate fire risk, and therefore, impacts are determined to be less than significant.
Threshold No. 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.
As described in Section 3.6, Geology and Soils, of this EIR, the potential for flooding and landslides on site is considered low due to the relatively flat terrain of the project site and surrounding area, and the site location in an urban part of the City.
As described in the FPP (Appendix N) with the conversion of the landscape to ignition-resistant development and the annual weed abatement on the preserved areas of the site, wildfires would not have fuels needed to spread on site.
Given the climatic, vegetative, topographic characteristics, and local fire history of the area, the project site, once developed, is determined to not be subject to wildfires. The potential for off-site wildfire encroaching on or showering embers on site is considered very low.
Due to the nature and location of the project site and the proposed project, implementation of 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 instability, or drainage changes. For the reasons outlined above, impact s are determined to be less than significant.
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.18-13
3.18.5 Mitigation Measures
Impacts related to wildfire would be less than significant, and no mitigation is required.
3.18.6 Conclusion
As analyzed above, no significant impacts related to wildfire were identified; thus, no mitigation measures are required. Impacts related to wildfire as a result of project implementation would be less than significant.
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INTENTIONALLY LEFT BLANK
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-1
3.19 Cumulative Effects
The California Environmental Quality Act (CEQA) requires an environmental impact report (EIR) to analyze cumulative impacts. The purpose of this section of the EIR is to explain the methodology for the cumulative analyses and present the potential cumulative effects of the proposed Pacific Specific Plan Project (proposed project).
Section 15355 of the CEQA Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” Section 15130 of the CEQA Guidelines provides guidance for analyzing significant cumulative impacts in an EIR.
The discussion of cumulative impacts “need not provide as great detail as is provided for the effects attributable to the project alone ,” but instead is to be “ be guided by standards of practi cality and reasonableness.” (CEQA Guidelines Section 15130[b]) The discussion should also focus only on significant effects resulting from the project’s incremental effects and the effects of other projects. According to Section 15130(a)(1), “ an EIR should not discuss impacts which do not result in part from the project evaluated in the EIR.” Cumulative impacts can result from the combined effect of past, present, and future projects located in proximity to the project under review. Therefore, it is important for a cumulative impacts analysis to be viewed over time and in conjunction with other related past, present , and reasonably foreseeable future developments whose impacts might compound or interrelate with those of the project under review.
3.19.1 Methodology
According to Section 15130(b) (1) of the CEQA Guidelines, a cumulative impact analysis may be conducted and presented by either of two methods:
a list of past, present, and probable activities producing related or cumulative impacts; or a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document that has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact.
With the exception of the impact analyses of air quality and greenhouse gas emissions, the cumulative list approach has been used in this cumulative analysis, as discussed below. The cumulative impacts of air quality and greenhouse gas emissions have been evaluated using the summary of projections method because the geographic scope of such impacts are on an air basin and global scale.
3.19.2 Cumulative Projects
Based on information provided by the City of San Marcos (City) an inventory of past, present, and reasonably foreseeable future projects within the vicinity of the project site is presented in Table 3.19-1 and Figure 2 -7, Cumulative Project Map.
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-2
Table 3.19-1. Cumulative Projects
No. Status
Project Name/
Developer Location Description
City of San Marcos
1 Under Construction Block 3 Student
Housing
NW corner of Campus
Way and Barham Drive
342 bed student housing
development, with a
buildout year of 2022
2 Approved Carmel Street
Apartments
Southwest corner of
Industrial St. and Carmel
Street
170-unit multifamily
affordable housing
development, with a
buildout year of 2023
3 Under Construction Kaiser
Permanente Plan
Craven Rd. 206 bed hospital, with a
buildout year of 2023
4 Approved Discovery Village
North
Craven Rd. Office/Commercial/
Residential on 41 acres
5 Proposed Main Square SE corner of San Marcos
Blvd. and McMahr Rd.
Mixed-use development with
a 468-units apartment
complex, and 44,007 sf of
commercial space
6 Approved San Elijo Hills San Elijo Rd. 11,711 sf Commercial development with a buildout
year of 2022
7 Approved Pacific
Commercial
NE corner of Grand Ave.
and Pacific St.
122 room hotel, with a
buildout year of 2022
8 Under Construction San Marcos
Highlands
North end of N. Las
Posas Rd.
187-unit Single-Family
Residential development,
with a buildout year of 2023
9 Complete El Dorado II
Specific Plan
Southwest corner of
Richmar Ave. and
Pleasant Way
Mixed-use development
consisting of a 72-unit
apartment complex and
2,000 sf of specialty retail,
with a buildout year of 2022
10 Under Construction Villa Serena Richmar Ave. and
Marcos St.
12-unit apartment complex,
with a buildout year of 2023
11 Approved Montiel Rd
Partners
Montiel Rd. 8-unit Single-Family
Residential development,
with a buildout year of 2022
12 Approved Meadowlark
Canyon LLC
San Marcos Blvd. 33-unit Single-Family
Residential development
13 Approved Mariposa- Phase
1 Richmar Ave. and Los
Olivos Dr.
66-unit apartment
development, with a
buildout year of 2022
14 Proposed Mariposa- Phase
2 Richmar Ave. and Los
Olivos Dr.
66-unit apartment
development
15 Under Construction Murai-Sab N. Las Posas Rd. 89-unit single-family residential with a buildout
year of 2022
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-3
Table 3.19-1. Cumulative Projects
No. Status
Project Name/
Developer Location Description
16 Approved Pacifica San
Marcos
S. Rancho Santa Fe Rd
and Creek St.
Mixed-use development of
31-unit apartment complex
and 4,375 sf commercial
space with a buildout year of
2022
17 Under Construction Discovery Village
South
Future Discovery St. 220-unit single-family
residential, with a buildout
year of 2022
18 Approved Breaker Real
Estate
SE corner of Twin Oaks
Valley Rd and Richmar
Ave.
174-bed assisted living
facility
19 Approved Hall Land
Company
Barham Drive, east of
Woodland Pkwy.
151-unit multifamily
condominium development
20 Under Construction Carkel SM-
Starbucks
SE corner of San Marcos
Blvd. and Bent Ave.
Drive-thru restaurant with a
buildout year of 2023
21 Approved Southlake Park
Phase 1
Twin Oaks Valley Rd,
South of Village Dr.
Parking lot, fishing dock
22 Approved MacDonald Group San Marcos Blvd.
(Former Sears site)
Mixed-use development with
82-unit apartment complex
and 5,000 sf of commercial
space
23 Under Construction Mission 316 West Mission Rd. at
Woodward St. (east side)
67-dwelling unit multifamily
condominium development
with a buildout year of 2023
24 Proposed Lanikai Mission Rd. at
Woodward St. (west
side)
115-unit senior living
complex
25 Approved Artis Senior
Housing
San Elijo Rd. at Paseo
Plomo
64-bed assisted living
facility
26 Under Construction Sunrise Barham Dr. (near east
City limit)
192-dwelling unit
multifamily condominiums
27 Under Construction Jump Ball LLC W. San Marcos Blvd. at Bent Ave.
Drive-thru restaurant
28 Proposed Montiel
Commercial
2355/2357 Montiel Rd. 32,971-sf office building
29 Under Construction California Allstars East side of Twin Oaks Valley Rd.
28,137-sf industrial building
to be completed in 2022
30 Proposed Bodhi Hill
Buddhist Center
Poinsettia Ave. s/o Linda
Vista Dr.
Development of a 36,501-
sf fellowship hall and 7,612-
sf monk dormitory
31 Proposed Mercy Hill and
Marian Center
Borden Rd. 31,105-sf Christian center
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-4
Table 3.19-1. Cumulative Projects
No. Status
Project Name/
Developer Location Description
32 Under Construction Karl Strauss
Brewery
Las Posas Rd. and Los
Vallecitos Blvd.
10,528-sf tasting room,
commercial kitchen,
entertainment room within
existing commercial building
with a buildout year of 2023
33 Approved Kiddie Academy Twin Oaks Valley Rd.,
northeast of Windy Way
11,430-sf preschool
34 Proposed Edenpark 1601 San Elijo Rd. Adaptive reuse of existing structures for recreation,
sports, and related personal
services, and related
commercial uses with a
buildout year of 2022
35 Under Construction San Marcos Creek
Phase 1
CIP - various
numbers
Via Vera Crux Bridge,
Bent Ave. Bridge,
Discovery
St. widening, Levee
construction,
Promenade, and Creek
Channel Wetland
Restoration
San Marcos Creek Phase 1
Infrastructure, Discovery
St.(east/west segment),
Bent Ave. to Discovery
St. (north/south segment)
36 Funded CIP 88179 Smilax Rd./South Santa
Fe Ave. Intersection,
intersection re-alignment
Smilax Rd./South Santa Fe
Ave. intersection,
intersection re-alignment
37 Under Construction CIP 86002 San Marcos Blvd. at
Discovery St.
intersection
Intersection improvement
300 ft. west, and 920 ft.
east of intersection
38 Funded PARK CIP Rancho Tesoro Park
Improvements – 2 acres
of 41-acre park
City Park – Phase 2 Multi-
Use Field and Parking Lot
Improvements
39 Programmed ST006 South side of San
Marcos Blvd., 500 ft.
east of Acacia Dr.
San Marcos Blvd. Slope
Stabilization Project
40 Proposed Pacific Grand
Ventures
1.49-acre lot east of S.
Pacific at Seminole St.
26,156-sf industrial building
41 Proposed Twin Oaks Valley
Winery
1451 Mulberry Dr. 3,121-sf 2-story winery and
tasting room on a 4.23-acre
lot
42 Proposed Gran Vista Generally located at NW
corner of W. Mission Rd.
and N. Las Posas Rd.
120-unit residential
condominium development
on 7.6 acres
43 Proposed Paul Mayer-Santa
Fe Las Floras LP
Northwest corner of S.
Santa Fe Ave. and Las
Flores Dr.
54-unit residential
apartment building and 117
parking spaces on
2.23 acres
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-5
Table 3.19-1. Cumulative Projects
No. Status
Project Name/
Developer Location Description
44 Proposed Water Mill Homes,
Inc. (Manning
Homes)
SW corner of Mulberry
Dr. and Cox Rd.
9 single-family residential
lots on a 10-acre property
45 Proposed San Marcos
Hospitality
SW corner of Montiel Rd.
and Leora Ln.
Hotel with 107 rooms
46 Proposed Lonnie Tabbaa –
Arco
200 Las Posas Rd. Gas station, convenience
store, car wash.
47 Proposed Bennet Manning South of Woodward St.
at Killarney Terrace
3 single-family residential
lots.
48 Proposed SH North City, LLC Discovery St. west of S.
Twin Oaks Valley Rd.
532 attached and 94
detached condo units (626
total units), master
association community rec
center, public and private
trail systems that connect to
future Knoll Park
49 Approved University District
Specific Plan
Amendment –
UVSM, LLC
Generally located
between North City Dr.,
Carmel St, Campus Way,
and S. Twin Oaks Valley
Rd.
Mixed-use development with
557 residential units and
associated commercial and
office space
50 Approved Hollandia Dairy 620 E. Mission Rd. Partial demolition and reconstruction of dairy
facilities; 48,755 sf
51 Approved American Rentals 1030 Linda Vista Dr. Equipment rental facility 52 Proposed Hunter Industries West terminus of Opal
Dr.
67,657-sf office building
53 Proposed Hughes SMCC,
LLC
NE corner of Pacific St.,
approximately 750 ft.
south of Linda Vista Dr.
67,410-sf industrial building
54 Proposed Marcos Specific
Plan
SW corner of Grand Ave.
and Linda Vista Dr.
Horizontal mixed-use project
with 102 residential units
and 63,641 sf of
commercial space and 8
live/work units
55 Proposed Polley Apartments North side of Polley Dr.
at the eastern terminus
17-unit apartment building
on a 0.60-acre undeveloped
lot
56 Proposed Salim Mixed-Use
Development
South side of San
Marcos Blvd.,
approximately 300 ft
west of Via Vera Cruz
Mixed-use development on
a 4.8-acre lot consisting of
10,067-sf commercial, 250
dwelling units, and 8
live/work units
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-6
Table 3.19-1. Cumulative Projects
No. Status
Project Name/
Developer Location Description
57 Proposed Lennar Homes of
California, LLC
1020-1080 W. San
Marcos Blvd.
Redevelopment project
removing existing building
and constructing a mixed-
use project of 10,500-sf
commercial, 202
condominium units, and a
public park
58 Approved San Elijo Town
Center East
NE corner of San Elijo
Rd. and Elfin Forrest Rd.
at 1093 San Elijo Rd.
Construction of a two-story
multi-tenant commercial
building
Notes:
CUP = Conditional Use Permit
du = dwelling unit
GPA = General Plan Amendment
MFR = multifamily residence
MUP = Major Use Permit
REZ = Rezone
S = Site Plan
SCH = State Clearinghouse
sf = square feet
SP = Specific Plan
SPA = Specific Plan Amendment
SFR = single-family residence
TM = Tentative Map
TPM = Tentative Parcel Map
VTM = Vesting Tentative Map
3.19.3 Cumulative Impact Analysis
Aesthetics
Projects contributing to a cumulative aesthetic impact include those within the project viewshed. The viewshed encompasses the geographic area within which the viewer is most likely to observe the proposed project and surrounding uses. Typically, this is delineated based on topography, as elevated vantage points, such as from scenic vistas, offer unobstructed views of expansive visible landscapes.
Cumulative aesthetic impacts would occur if projects combine to result in substantial adverse impacts to the visual quality of the environment and /or increase sources of substantial lighting and glare. The proposed project would have no substantial impact on a scenic vista or City -protected scenic resource, would not adversely impact the visual character of the area, and would not introduce a substantial new source of lighting or glare.
Although not technically designated scenic vistas, Mt. Whitney, Franks Peak, and the adjacent prominent ridgelines are scenic resources, which the City’s General Plan aims to protect and preserve for their natural visual quality. As previously discussed, the summit of Mt. Whitney is off limits to the public, but Franks Peak and its surrounding recreational trails are publicly accessible. From Franks Peak, viewers would be able to see cumulative development projects in the same viewshed, and potentially port ions of the project site. The proposed residential development would not substantially contrast with the visual patterns of the area as height and density would be consistent with the existing surrounding development and appear as an extension of the already urbanized landscape. Therefore,
3.19 - CUMULATIVE EFFECTS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.19-7
the proposed project would not substantially contribute to a cumulative change in visual character of the surrounding area.
As discussed, the closest Designated State Scenic Highway is State Route 78; however, the segment designated as a State Scenic Highway is located in Anza Borrego State Park, approximately 41 miles east of the project site. Therefore, the proposed project would not result in a cumulative impact to the Designated State Scenic Hig hway segment of State Route 78. Nor would the proposed project result in a cumulative impact to the eligible portion of Interstate-5, as the highway is located beyond intervening topography approximately 7.3 miles west of the project site.
As previously described, the project site is surrounded by existing developments that contain sources of lighting typical of residential, commercial, and industrial uses. The proposed project would introduce new sources of lighting to the project site as the proposed project would allow for the development of residential uses. The project site is currently undeveloped and contains no sources of light. The project and cumulative projects would have to comply with the City’s Municipal Code, which would restri ct light trespass into adjacent properties and ensure that new sources of lighting would not result in significant impacts. Concerning glare, implementation of the proposed project would not result in new sources of glare. The project developer, and the de velopers of any proposed cumulative projects would be required to minimize use of reflective building materials and finishes, as well as reflective lighting structures and metallic surfaces to the extent feasible to impede any potential glare effects to comply with the City’s Municipal Code. Impacts pertaining to light and glare from the project and cumulative projects would be minimized through compliance with applicable regulations related to light and glare and design requirements. For the reasons outlined above, cumulative impacts related to aesthetics are determined to be less than significant.
Air Quality
In analyzing cumulative impacts from a project, the analysis must specifically evaluate a project’s contribution to the cumulative increase in pollutants for which the air basin is designated as nonattainment for the California Ambient Air Quality Standards and National Ambient Air Quality Standards. If a project does not exceed thresholds and is determined to have less -than-significant project -specific impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project, in combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of established thresholds. However, a project would only be considered to have a significant cumulative impact if the project’s cont ribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).
See Threshold No. 2 in Section 3.2.4 of this EIR for a detailed discussion of the proposed project’s cumulative air quality impacts. In analyzing cumulative impacts from the project, the analysis must specifically evaluate a project’s contribution to the cumulative increase in pollutants for which the b asin is designated as nonattainment for the California Ambient Air Quality Standards and National Ambient Air Quality Standards.
Implementation of the project would exceed the significance threshold for volatile organic compounds, which is a precursor to the formation of ozone. Because the San Diego Air Basin is an ozone nonattainment area under the National Ambient Air Quality Standards and California Ambient Air Quality Standards, the potential for the proposed project to result in a cumulatively considerable net increase of a criteria pollutant (volatile organic compounds) for which the project region is nonattainment under an applicable national or California ambient air quality standard is potentially significant. Mitigation Measure MM-AQ-1, outlined in Section 3.2 of this EIR, would be implemented to reduce volatile organic compound emissions generated during construction of the proposed project.
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Cumulative localized impacts would potentially occur if a construction project were to occur concurrently with another off-site project. Table 3.19-1 provides a list of reasonably foreseeable, approved, and pending projects within the City limits. As it is unknown whether the cumulative projects under review will be approved or not, and if approved when actual construction would begin, it would be speculative to estimate any potential overlap of the proposed project. Construction schedules for potential future projects near the project site are currently unknown; therefore, potential construction impacts associated with two or more simultaneous projects would be speculative.
However, future projects would be subject to CEQA and would require an air quality analysis and, where necessary, mitigation if the project would exceed the San Diego Air Pollution Control District (SDAPCD) significance thresholds.
Criteria air pollutant emissions associated with construction activity of future projects would be reduced t hrough implementation of control measures required by SDAPCD. Cumulative PM10 and PM2.5 emissions would be reduced because all future projects would be subject to SDAPCD Rule 55 (Fugitive Dust), which sets forth general and specific requirements for all construction sites in the SDAPCD.
As construction and operation of the project would be typical of multifamily development uses, implementation of the project is not expected to contribute to any cumulative health risks.
Biological Resources
Special -Status Plant and Animal Species
Cumulative impacts consider the potential regional effects of a project and how a project may affect an ecosystem or one of its members beyond the project limits and on a regional scale. As discussed, the project would have potentially significant impacts associated with San Diego button celery, thread-leaved brodiaea, Orcutt’s brodiaea, San Diego fairy shrimp, and nesting birds; however, implementation of MM-BIO-1 through MM-BIO-8b would reduce these impacts to a level below significance.
Similar to the proposed project, cumulative projects would be required to mitigate impacts by avoiding the grading or clearing of suitable habitat for sensitive wildlife during breeding season, or by conducting pre -construction surveys to avoid sensitive s pecies if construction would occur during breeding season. However, through the implementation of required mitigation, impacts to present and potentially present sensitive wildlife species would be reduced to a level below significance for the proposed project and for cumulative projects. Therefore, cumulative impacts with regard to special-status wildlife species would not be cumulatively considerable.
Sensitive Natural Communities
The project would directly contribute to the cumulative loss of 32.2 acres of upland vegetation communities in the region (see Table 3.3-5, Impacts to Sensitive Natural Communities). These vegetation communities are also suitable habitat for several special-status wildlife species. These impacts would be considered significant prior to mitigation.
The project would be required to provide off-site compensatory mitigation lands through the purchase of credits in an approved mitigation or conservation bank, in -lieu fee program, or permittee responsible mitigation, as determined to be appropriate following consultation with the resource agencies. Mitigation ratios are presented in Table 4 of Appendix C to this EIR. Further, with the implementation of mitigation measures MM-BIO-6, MM-BIO-8a, and MM-BIO-8b, as identified below, the project would reduce cumulative impacts to a level below significance.
Cumulative projects would be required to mitigate their individual impacts to sensitive vegetation communities through either on -site preservation/restoration or off -site habitat acquisition, typically at a 2:1 ratio. Therefore,
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because the proposed project and cumulative projects would be required to mitigate for habitat loss, impacts related to the loss of sensitive vegetation communities would not be cumulatively considerable.
Jurisdictional Waters and Wetlands
Implementing the proposed project would result in significant impacts to protected jurisdictional resources under potential regulation by the U.S. Army Corps of Engineers, Regional Water Quality Control Board, and/or the California Department of Fish and Wildlife. The proposed project would be required to secure the necessary regulatory permits prior to impacts per mitigation measure MM-BIO-8a. It is anticipated that a 404 permit from the U.S. Army Corps of Engineers, 401 Certification from the Regional Water Quality Control Board , and a 1602 agreement from the California Department of Fish and Wildlife would be needed. If the wetlands or waters on -site are ruled non - jurisdictional by the U.S. Army Corps of Engineers, it is anticipated that a WDR Permit from Regional Water Quality Control Board and a 1602 agreement from the California Department of Fish and Wildlife would be required.
Proposed m itigation measure MM-BIO-8b proposes ratios consistent with those typically required by these regulatory agencies and, therefore, would compensate for impacts to jurisdictional resources, such that impacts would be reduced to below a level of significance.
Like the proposed project, it is presumed that all reasonably foreseeable cumulative projects would be required to conform to existing regulations with respect to avoidance, minimization, and mitigation of impacts to sensitive habitat, achieving no-net-loss of wetlands and like/kind replacement for impacts to sensitive habitat that cannot be avoided. The regulatory permitting process ensures that every project with unavoidable impacts on jurisdictional resources implements required avoidance, minimization, and compensatory mitigation measures and obtains the appropriate permits. Projects in the region are required to meet a no-net-loss standard for both function and spatial area of wetland and non-wetland resources. Therefore, the project would not contribute to a cumulative impact to jurisdictional waters and wetlands.
Conflict with Local Ordinances/Tree Preservation Policies Like the proposed project, it is presumed that all reasonably foreseeable cumulative projects would be required to conform to the City’s Municipal Code requirements and General Plan Policies for tree replacement. Therefore, the project would not contribute to a cumulative impact related to a conflict with tree preservation policies.
Conflict with Adopted Habitat Management Plan
The project site is recognized as being located within a “Major Amendment Area” within the boundaries of the Multiple Habitat Conservation Program (MHCP) and Draft San Marcos Subarea Plan, which plans for regional biological resource protection and conservation. The project would be required to comply to minimum standards and mitigation ratios required by the MHCP, as set forth in MM-BIO-1 through MM-BIO-8b. Compliance with MM- BIO-1 through MM-BIO-8b in this report would ensure that the project would not co nflict with requirements or policies of the MHCP and draft San Marcos Subarea Plan. Cumulative projects would also be required to comply with relevant MHCP and Natural Community Conservation Plan policies; therefore, cumulative impacts would be less than significant.
In sum, all reasonably foreseeable cumulative projects would be required to conform to existing regulations with respect to avoidance, minimization, and mitigation of impacts to sensitive habitat, achieving no-net-loss of wetlands and like/kind replacement for impacts to sensitive habitat that cannot be avoided. Impacts would be assessed on a regional basis and mitigated pursuant to CEQA, and those projects within the City’s jurisdiction would be reviewed
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by the City during the project review and approval process. For these reasons, project impacts to biological resources are not cumulatively considerable.
Cultural Resources
According to CEQA, the importance of cultural resources comes from the research value and the information they contain, as well as the loss of recognized cultural landmarks and vestiges of our community cultural history. The cumulative study area includes the project area of potential effect and cumulative project sites.
As identified in Section 3.4.4, no historic resources exist at the project site. Thus, no impact to historic resources would occur with implementation of the proposed project. It is expected that cultural resources studies would be prepared for all cumulat ive projects to assess potential impacts, and that these projects would avoid or mitigate impacts to historic resources, as required by local jurisdictions and state law.
As identified in Section 3.4.4, no cultural resources were found at the project site during the field survey. However, the potential to unearth a cultural resource during project construction would be potentially significant (Impact-CR-1). Mitigation measures MM-TCR-1 through MM-TCR-4 would be implemented to reduce impacts to less than significant levels. It is expected that cultural resources studies would be prepared for all other cumulative projects to assess potential impacts, and that these projects wo uld similarly avoid or mitigate impacts to cultural resources, as required by local jurisdictions and state law.
Similar to the project, the presence of human remains on cumulative project sites would typically remain unknown for cumulative projects until earthwork activities commence for project construction. As identified in Section 3.4.4, the cultural resources fi eld survey conducted for the project did not identify any human remains or find any indications that they would be expected to be found on the project site. If human remains are encountered during project construction, there is a potential for a significant impact (Impact CR-2). However, mitigation measures MM- TCR-1 through MM-TCR-4 would ensure any impacts to human remains would be less than significant. It is expected that all cumulative projects would similarly assess potential impacts to human remains, and that these cumulative projects would avoid or mitigate these impacts, as required by local jurisdictions and state law.
Because the project and those projects identified within the cumulative study area would be required to mitigate cultural impacts through the collection and curation of information, construction monitoring, and the preservation of the most important resources, cumulative cultural impacts would be less than significant.
Energy
Potential cumulative impacts on energy would result if the proposed project, in combination with past, present, and future projects, would result in the wasteful or inefficient use of energy within the San Diego region. This could result from development t hat would not incorporate sufficient building energy efficiency features, would not achieve building energy efficiency standards, or would result in the unnecessary use of energy during construction and/or operation. The cumulative projects within the areas serviced by the energy service providers would be applicable to this analysis; this includes existing aging structures that are energy inefficient. Projects that include development of large buildings or other structures that would have the potential to consume energy in an inefficient manner would have the potential to contribute to a cumulative impact. Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use.
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As described previously, the proposed 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, installi ng electric or solar water heaters, implementing a Transportation Demand Management plan, reducing landscaping water use, and planting trees that would be required of the proposed project. Like the project, cumulative projects would be subject to California Green Building Standards Code (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 waste ful and inefficient use of energy. In addition, cumulative projects would be required —at a minimum—to meet Title 24 building standards, further avoiding the inefficient use of energy; and would be required to demonstrate consistency with the City’s Climate Action Plan Checklist and implement measures to reduce potential energy demands and greenhouse gas ( GHG) emissions. Furthermore, various federal and state regulations, including the Low Carbon Fuel Standard, Pavley Clean Car Standards, and Low Emission Vehicle Program, would serve to reduce the transportation fuel demand of cumulative projects.
In summary, the proposed project contains energy -efficiency design features, would comply with applicable regulatory standards for the enhancement of energy efficiency, and would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. Thus, the proposed project would not contribute to a cumulative impact to the wasteful or inefficient use of energy and would not result in a cumulatively considerable contribution to a potential cumulative impact. Cumulative impacts related to energy would be less than significant.
Geology and Soils
Due to the localized nature of geology and soils, cumulative projects would address potential impacts to geology and soils on a project -by-project basis, as potential geologic hazards and soil composition vary by site. Each cumulative project would be required to assess individual and site-specific geologic conditions, which would inform construction and development of each site. All cumulative development would be subject to similar requirements to those imposed and implemented for the proposed project and would be required to adhere to applicable regulations, standards, and procedures.
Further, as discussed in Section 3.6.4, although ground-disturbing activities associated with the proposed project have the potential to unearth previously unidentified paleontological resources, the preliminary geotechnical evaluation prepared for the proposed project did not identify any unique geologic features on the project site. Due to the existing conditions of the site, and the project location surrounded by urban uses, paleontological resources are not anticipated to be unearthed within the project’s area of potential effect. However, the project site is underlain by the Santiago Formation, which has high paleontological sensitivity, and a paleontological records search is recommended prior to project construction to ensure impacts remain less than significant. While some of the projects on the cumulative list are located in areas that may contain paleontological resources, the presence of these resources is typically unknown prior to construction, and it is expected that mitigation measures would be included with approval of cumulative projects to ensure that impacts to paleontological resources are minimized.
As implementation of the proposed project would not result in any significant impacts to geology and soils on the project site, and all cumulative projects would be required to analyze site -specific conditions and implement recommendations or mitigation, cumulative impacts related to geology and soils would be less than significant.
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Greenhouse Gas Emissions
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 in Section 3.7.4 of this EIR, to determine project-level impacts applies here, and the project’s contribution to global climate change would not be cumulatively considerable.
This approach is consistent with the supporting documentation published by the California Natural Resources Agency (CNRA) when promulgating the Senate Bill 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 emi ssions are cumulatively considerable (CNRA 2009b). 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.” The project would not contribute to a significant cumulative impact by generating GHG emissions, either directly or indirectly, that may have a significant impact on the environment or by conflicting with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Cumulative impacts related to greenhouse gas emissions would be less than significant.
Hazards and Hazardous Materials
Hazardous materials impacts are generally site specific and thus handled on a site-by-site basis. Identified cumulative projects are located more than a quarter mile from the project site and thus would be unlikely to result in cumulative impacts to hazardous and hazardous materials together with the proposed project. In addition, any cumulative project would be required to identify existing hazardous materials on site and comply with existing regulations related to use, transport, and disposal of hazardous materials. Similarly, all cumulative projects would be required to analyze and properly mitigate any impacts to the existing evacuation plan if impacts are identified.
With regard to wildfire hazards, any of the cumulative projects proposed within the wildland urban interface would be required to meet minimum fire fuel modification and/or clearing requirements in addition to meeting 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 proposed project’s and cumulative projects’ compliance with applicable regulations related to hazards and wildfire would ensure impacts related to hazards and hazardous materials would be less than significant.
Hydrology and Water Quality
The proposed 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 poten tially result in increased surface runoff, alteration of the regional drainage pattern, and flooding. However, like the proposed project, each individual project applicant would be required to
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hydrologically engineer the respective cumulative project sites to ensure that post-development surface runoff flows can be accommodated by the regional drainage system.
The proposed 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 proposed 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 proposed 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 proposed project would not substantially contribute to a significant cumulative impa ct to water quality. Impacts would be less than significant.
Land Use and Planning
As described in Section 3.10 of this EIR, while the project seeks approval of a GPA and Rezone of the project site, the proposed project would be consistent with the overarching goals of the City’s General Plan. In addition to the City’s General Plan, the proposed project would also be consisten t with the City’s Municipal Code, San Diego Association of Governments 2050 Regional Transportation Plan/Sustainable Communities Strategy, and applicable plans and polices described in the regulatory setting sections throughout Chapter 3. Furthermore, as analyzed throughout Chapter 3, implementation of the proposed project would not result in any significant unavoidable impacts that could further impact land use.
All cumulative projects would be subject to similar criteria as the proposed project, which would ensure compliance with existing applicable land use plans with jurisdiction over the project area. Any cumulative projects that propose amendments to the General Plan or Zoning Ordinance would be 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 proposed 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.
Noise
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 of this EIR, project implementation would result in less than significant noise impacts. No mitigation is required with proper implementation of the recommended design features.
Cumulative traffic noise impact could occur in combination with the project and cumulative projects during construction if traffic noise exceeded City standards. However, it is likely that any construction traffic, 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 proposed project, cumulative projects would include construction and operation noise reduction measures to reduce any potentially significant noise impacts to a level below significance, where feasible. Development plans for cumulative projects would be required to outline mitigation measures, design features, and required regulatory compliance. Implementat ion of project-specific mitigation and design features would ensure cumulative noise impacts would remain at a less than significant level.
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Population and Housing
Cumulative projects in addition to the proposed 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 both residential and mixed-use development projects.
The introduction of a new population is not, in and of itself, a significant impact. As with a project-level analysis, the significance of a cumulative population impact is determined by whether the 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 Regional Housing Need Allocation 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 would be subject to applicable development fees. Compliance with City regulations and fees would ensure that cumulative impacts related to population and housing are adequately addressed.
Further, the proposed project and cumulative projects would not result in the removal of a barrier of growth that would reasonably result in the intensification or development of land, or any cumulative utility or infrastructure expansion. Additionally, because the proposed project is surrounded by existing d evelopment, approval of the proposed project and other projects would not lead to an intensification of the land uses in the area. Therefore, cumulative impacts are determined to be less than significant.
Public Services
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 of this EIR, the project would increase the demand on San Marcos Fire Department (SMFD) resources in comparison to development of an industrial use under the current allowed land use because of the substantial increase of residents in the area. The proposed 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 would serve the project site. SMFD Station 1 and Vista Fire Department (VFD) Station 4 would respond as necessary.
The project and its estimated population of approximately 1,388 people is an increase in potential service demand of approximately 184 calls per year (0.5 calls per day), which is within the capacity of the existing fire stations that will service the proposed project . When considered cumulatively, the potential impact of multiple projects is considered less than significant, mitigated by increased funding available from each project to the SMFD through property taxes and other fees associated with each project, including the proposed project. This funding would be utilized to maintain or enhance fire response capabilities.
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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.
Furthermore, the Fire Protection Plan prepared for the project (Appendix N to this EIR) determined that SMFD could provide emergency response to the project site within its internal 7-minute response time, and development at the project site would not trigger the need for a new fire station closer to the project site. Therefore, the proposed 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 proposed 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 proposed project site would be served by the San Marcos Station, located approximately 4 miles from the proposed project site. As discussed in Section 3.13.4, Project Impact Analysis, the proposed 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 proposed 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 San Marcos Unified School District or another school district in the area. As discussed in Section 3.13.4, Project Impact Analysis, 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. Furthermore, will-serve letters from the San Marcos Unified School District or servicing schools would be required to confirm such schools have adequate capacity to serve grade- school students generated by residential development. This would apply to similar cumulative projects as well. Senate Bill 50 states that the fees imposed by school districts shall constitute the exclusive method of considering and mitigating impacts on school facilities caused by a development project. As such, with contribution of required development fees by the project and cumulative projects, cumulative impacts to schools would be less than significant.
Parks
The proposed project and the cumulative projects in the City of San Marcos would add to the cumulative demand for park and recreation facilities in the City. All residential projects that increase the demand for park and recreation needs in the City are required to provide park space and/or pay park in lieu-fees. The environmental documentation prepared for each project would analyze impacts associated with the construction of any parks within each overall development footprint. As discussed in Section 3.13.4, Project Impact Analysis, the project developer/applicant would be required to
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pay the City’s Public Facility Fee, required for all projects that increase the demand for park and recreation needs in the City, and which is used for developing neighborhood and regional parks. It is expected that all cumulative projects that increase demand for parks and recreation needs would also be required to pay these fees. It is also anticipated that similar to the proposed project, all cumulative residential projects would provide on-site open space and/or recreational amenities consistent with the requirements of the City’s Municipal Code (Section 20.215.050). With payment into the City’s Public Facility Fee and incorporation of on-site recreation, cumulative impacts on recreational facilities in the City would be less than significant.
Libraries
Cumulative projects within the services area of the San Marcos Branch Library would 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 Serr a Library System. In addition, community members can get borrowing privileges at the California State University, San Marcos, campus and the Palomar Community College. These additional library resources provide over 200,000 square feet of additional librar y space. Therefore, due to the City’s availability of library resources, it is determined that cumulative impacts to library facilities in the City as a result of the project would be less than significant.
Recreation
The proposed project, in addition to cumulative projects, would increase the demand for park and recreation facilities in the City. Similar to the project, 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 Facility Fee . Furthermore, any substantial expansion or development of new recreational facilities would be subject to the appropriate CEQA environmental review, which would identify and address any site -specific impacts. Therefore, with payment of the City’s Public Facility Fee and project-specific environmental review, cumulative impacts to recreational facilities would be less than significant.
Transportation
The project in addition to cumulative projects in the study area could result in cumulative impacts related to transportation and circulation. However, the preceding analysis of the proposed project in Section 3.15.4, as well as the Vehicle Miles Traveled Analysis prepared for the proposed project (Appendix J) are based on methodologies that incorporate the cumulative impacts of traffic from forecasted grow within the project area. Additionally, it is expected that a Traffic Impact Analysis 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 potential ly significant impacts. Furthermore, all cumulative projects would be required to comply with applicable City regulations related to transportation and circulation, as the project does. As analyzed in Section 3.15.4, implementation of the proposed project would not result in any significant impacts to transportation and circulation in the study area. Therefore, it is determined that cumulative impacts to transportation as a result of project implementation would be less than significant.
Tribal Cultural Resources
Each cumulative project subject to Assembly Bill 52 would require tribal consultation on a case -by-case basis to identify any potential tribal cultural resources (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
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impacts to TCRs to a level below significance. With implementation of mitigation measures MM-TCR-1 through MM- TCR-4 and compliance with applicable regulations related to TCRs, the project’s contribution to a cumulative impact would be reduced to less than significant.
Utilities and Service Systems
Water
Some of the cumulative projects are within Vallecitos Water District (VWD) service area for potable water service and would contribute to the cumulative demand for water supply. However, Metropolitan Water District of Southern California (MWD) anticipates the demand of future development through their master planning process. According to MWD’s Urban Water Management Plan, no water shortages are anticipated within MWD’s service area in single of multiple dry years through 2040. Not all cumulative projects fall into the VWD’s service area; those that do not would be served by neighboring districts and would be evaluated as such.
As described in Section 3.17 of this EIR, the proposed 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 San Diego County Water Authority, and compliance with the Water Conservation Bill of 2009, no water shortages would occur in a normal year through 2040 (MWD 2016). Other cumulative projects that are consistent with the land use assumptions made in MWD’s Urban Water Management Plan would have already been accounted for in demand projections. Projects that are inconsistent with the land use assumptions made in MWD’s Urban Water Management Plan would also be subject to CEQA and required to include water supply assessments as applicable 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 proj ects would be required to pay applicable Capital Facility Fees to the San Diego County Water Authority and VWD, required to go towards infrastructure improvements. Thus, the project’s contribution to cumulative impacts relative 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 of this EIR, VWD has sufficient capacity to account for the proposed 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 wastewater services caused by the project. As such, the project’s contribution to cumulative impacts relative to wastewater facilities 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
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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 2019). 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; Otay Landfill, with a remaining capacity of 21.1 million cubic yards since June 2017; and Ramona Landfill, which is curren tly at capacity (CalRecycle 2019).
Therefore, it is determined there is adequate capacity throughout the County to serve future development projects, including those identified on the cumulative project list. The project’s contribution to cumulative impacts related to solid waste would be less than significant.
Electrical Power
Potential cumulative impacts on energy would result if the proposed 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 ineffic ient manner would have the potential to contribute to a cumulative impact. Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use.
As described previously, the proposed 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 electric or solar water heaters, implementing a Transportation Demand Management plan, reducing landscaping water use, and planting trees that would be required of the proposed 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 addition, cumulative projects would be required to meet or exceed the Title 24 building standards, further reducing the inefficient use of energy. The project would also be required to meet even more stringent requirements, including the objectives set in the Assembly Bill 32 Scoping Plan (CARB 2017), which would seek to make all newly constructed single -family residential homes zero net energy consumers by 2020, and all new commercial buildings zero net energy consumers by 2030.
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, the project’s contribution to cumulative impacts related to electrical power would be less than significant.
Telecommunications
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 proposed project. Telecommunication demand and service is site and land use specific. All cumulative projects would be
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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 proposed project would not result in cumulative impacts associated with the construction or expansion of telecommunications, As such, the project’s contribution to cumulative impacts related to telecommunications would be less than significant.
Wildfire
Cumulative impacts from multiple projects can cause fire response service decline and must be analyzed for each project. The proposed project and its estimated population of 1, 388 people is an increase in potential service demand of approximately 1 67 calls per year (0.5 calls per day), which is within the capacity of the existing fire stations that will service the project. There are seven1 other future projects in the vicinity of SMFD Station 2 and when considered cumulatively would be mitigated by increased funding available from each project to the SMFD through property taxes and other fees associated with each project, including the proposed project. Therefore, the potential impact of multiple projects is considered less than significant, as this funding would be utilized to maintain or enhance fire response capabilities. The project’s contribution to cumulative impacts related to wildfire risk would be less than significant.
1 Per Pacific Specific Plan EIR Figure 2-7, Cumulative Projects Map, there are seven cumulative projects within the vicinity of SMFD Station 2. These projects are listed in Table 2-3, Cumulative Projects, of the EIR, which include projects 5, 7, 19, 26, 36, 43, and 45.
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 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 comparative merits of the alternatives evaluated, including the No Project Alternative, shall also be discussed.
The range of alternatives evaluated in an EIR is governed by the “rule of reason ,” which requires the EIR set forth alternatives adequate to permit a reasoned choice by decision makers and limited to alternatives that “would avoid or substantially lessen any of the significant effects of the project.”. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6[a] of the CEQA Guidelines).
Other than the No Project Alternative, the EIR needs to examine only those alternatives that could feasibly obtain most of the basic objectives of the proposed project even if the alternative would impede to some degree the attainment of project objectives.
Factors that may influence feasibility of an alternative also include “site suitability, economic viability, 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)” (CEQA Guidelines, Section 15126.6[f][1]). The ultimate determination as to whether an alternative is feasible or infeasibl e is made by the lead agency ’s decision ‐making body, the San Marcos City Council (PRC Section 21081[a][3]) .
This section presents several alternatives to the proposed Pacific Specific Plan Project (proposed project) that were considered pursuant to CEQA and evaluated for their ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the project identified in Chapter 3, Environmental Analysis, of the EIR. Those alternatives include (1) No Project Alternative (Section 4. 4.3), (2) Existing Land Use Designation Alternative (Section 4. 4.4), and (3) Reduced Developmen t Footprint Alternative (Section 4.4.5) , (4) Reduced Development Footprint Alternative - Vernal Pool Impact Minimization (Section 4.4.6), and (5) Reduced Pacific Specific Plan Project Alternative (Section 4.4.7) . Other alternatives were considered but rejected, as summarized in Section 4.3.
4.2 Project Objectives
The objectives of the proposed project are described as follows:
Promote infill development and develop housing on a site that is served by existing utilities, services, and street access, within close proximity to public transportation and shopping centers.
Assist the City in implementing its housing goals by changing a non-residentially zoned site to a site where medium to high-density housing is allowed.
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Provide a variety of housing types, including affordable housing, to align with the City ’s Regional Housing Needs Allocation requirements.
Restore, manage, and conserve sensitive on -site biological resources , to the extent feasible, while accommodating residential uses.
Design buildings, spaces, site layout, and uses that enhance and respect the character of the surrounding area in a manner typical to residential developments and planning principles and to enhance connectivity.
To the extent possible given site constraints, maximize the opportunity to provide medium-density housing for the City of San Marcos up to 15.0 dwelling units per acre, which is comparable to other medium-density housing developments in the City of San Marcos.
4.3 Alternatives Considered But Rejected
The State CEQA Guidelines state that an EIR should identify any alternatives that were considered by the lead agency but were rejected during the planning or scoping process, and the EIR should 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) infeasibility, or (iii) inability to avoid significant environmental impa cts. Factors that may be taken into account when evaluating an alternative’s feasibility include, among other things, site suitability, economic viability, availability of infrastructure, general plan consistency, consistency with other plans, 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 following describes alternative concepts that were considered as alternative to the proposed project by the City but were rejected from further evaluation in this EIR, and a brief description of the reasons for their rejection.
4.3.1 Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations to develop the proposed project. There are sites within the City that are already zoned for residential use under the General Plan that could be developed or redeveloped with a residential project. However, the project applicant does not control another site within the City of comparable land area that is surrounded by existing infrastructure and near existing transit. One of the factors for feasibility of an alternative is “whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” Because the City is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is not considered feasible. It should also be noted that the project site is surrounded on all sides by development and considered an infill site in an urban area.
As such, an alternative location was ultimately rejected from further analysis in the EIR.
4.3.2 Mitigation Bank Alternative
Under the Mitigation Bank Alternative suggested for consideration by the Wildlife Agencies, the entire project site would be conserved as-is. Conservation of the site would occur through purchase with grants or mitigation funds from other projects or through the establishment of a mitigation bank. A conservation or mitigation bank is privately, or publicly owned land managed for its natural resource values. In exchange for permanently protecting, managing, and monitoring the land, the bank sponsor is allowed to sell or transfer habitat credits to permi ttees who need to satisfy legal requirements and compensate for the environmental impacts of dev elopment projects. Under this alternative, no development would occur on site.
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The Mitigation Bank Alternative would not provide any development, and therefore overall impacts would be reduced compared to the proposed project. To the extent this alternative proposes no development, refer to Section
4.4.3, No Project Alternative, for an analysis of a no development alternative at the project site. T his alternative would not meet any of the basic project objectives, and it would not provide housing units in an infill area or enhance uses and connectivity in the surrounding area.
4.4 Project Alternatives Considered in this
Environmental Impact Report
4.4.1 Description of Alternatives
The following alternatives are under consideration for this project:
▪ No Project Alternative (Section 4.4.3)
▪ Existing Land Use Designation Alternative (Section 4.4.4) ▪ Reduced Development Footprint Alternative (Section 4.4.5) ▪ Reduced Development Footprint Alternative – Vernal Pool Impact Minimization (Section 4.4.6) ▪ Reduced Pacific Specific Plan Project Alternative (Section 4.4.7) Alternatives considered and removed from further consideration are summarized in Section 4.3.
4.4.2 Summary of Significant Project Impacts
Project- and cumulative-level impacts associated with implementation of the proposed project are evaluated in Sections 3.1, Aesthetics, through 3.19, Cumulative Effects, of this Draft EIR. As identified in Table 1 ‐1, in Chapter 1 (Executive Summary), construction and/or operation of the proposed project would have the potential to cause the following significant environmental impacts , each of which would be mitigated to less than significant levels with the proposed project:
▪ Impact AQ-1: Construction of the project would exceed the significance threshold for VOC emissions ▪ Impact BIO-1: Construction of the project would result in potential impacts to special-status species ▪ Impact BIO-2: Construction of the project would result in potential impacts to riparian habitat and sensitive natural communities
▪ Impact BIO -3: Construction of the project would result in potential impacts to jurisdictional wetlands and waterways
▪ Impact CR-1: Unknown archaeological resources may occur on the project site, and the proposed project has the potential to disturb such unidentified resources during project grading ▪ Impact CR-2: There is a potential for project construction activities to disturb previously unidentified human remains on the project site
▪ Impact TCR-1: There is potential for project construction to adversely affect previously unidentified tribal cultural resources (TCRs)
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4.4.3 No Project Alternative
Under the No Project Alternative, the proposed project would not be implemented, and the project site would remain undeveloped in its existing condition. This alternative would eliminate all the significant impacts identified for the proposed project. Habitat on the project site would not be impacted under this alternative but would not be preserved or managed.
Comparison of the Effects of the No Project Alternative to the Proposed Project Aesthetics
Under the No Project Alternative, the site would remain in its current condition and the visual character of the site would not change. Existing vegetation would remain on site, and no grading or landform modification would occur under this alternative. This alternative would result in no impacts related to scenic vistas, scenic highways, visual character or quality, or lighting and glare compared to the proposed project, which would have less than significant impacts. No new sources of light, glare, or shading would be introduced. However, as discussed in Sections 3.1 and
3.19 of this EIR, the proposed project would similarly not result in significant impacts to aesthetics and no mitigation would be required. Further, leaving the site condition unchange d in an infill area would be inconsistent with, and not enhance , the character of the surrounding area. However, when c ompared to the proposed project, this alternative would reduce impacts, as no new development or construction would occur.
Air Quality
Under the No Project Alternative, air pollutant emissions assoc iated with construction , including emissions associated with grading, site preparation, site finish ing and building finishing , would not occur. This alternative would therefore avoid significant but mitigable emissions related to construction volatile organic compound (VOC) emissions (Impact AQ -1), because no construction air pollutant emissions would occur. Implementation of this alternative would not introduce any uses that would generate operational air pollutant emissions. Thus, compared to the proposed project, the No Project Alternative would reduce air quality impacts related to VOC emissions generated during construction, because no development would occur, and no mitigation would be required.
Biological Resources
The No Project Alternative would not require any ground-disturbing activities. As such, this alternative would not result in the direct loss of 33.2 acres of upland vegetation communities and would not result in potential impacts to special- status species, riparian habitat, sensitive natural communities, jurisdictional wetlands , or waterways. However, impacts to biological resources on site could occur associated with unauthorized use of the site, causing degradation to natural habitat and sensitive specifies. In addition, sensitive species would not benefit from the conservation, maintenance, active management, monitoring, and compensatory mitigation set forth in mitigation measures MM- BIO-1 through MM-BIO-8b proposed for the project. However, as no development would occur under this alternative, compared to the proposed project, this alternative would result in reduced impacts to biological resources.
Cultural Resources
The No Project Alternative would not require any ground-disturbing activities. Therefore, there would be no potential to impact unknown archaeological resources potentially located within the project site. Further, there would be no potential to disturb previously unidentified human remains that may be present on the project site. As such, 4 - ALTERNATIVES
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mitigation measures MM-TCR-1 through MM-TCR-4 proposed for the project would not be implemented or required for this alternative . Although there may be a reduced level of direct impact to cultural resources, any previously undiscovered on -site resources could be subject to continued degradation due to lack of preservation of the undeveloped site. Nonetheless, compared to the proposed project, this alternative would result in a reduced level of impact to cultural resources as no ground disturbance would occur.
Energy
Under the No Project Alternative, energy use associated with construction or operation of future residences at the site, including from electricity use and natural gas use, would not occur. No construction would occur; therefore, no construction-related energy impacts associated with the operation of construction equipment and worker and vendor vehicles would occur like the proposed project. This alternative would not introduce any people or uses that would generate energy use. In comparison to the proposed project, this alternative would reduce energy use .
However, as described in Section 3.5, Energy, of this EIR, the proposed project ’s impacts related to energy emissions would be less than significant. Therefore, compared to the proposed project’s less than significant impact to Energy, the No Project Alternative would have no impacts.
Geology and Soils
Under the No Project Alternative, the project site would remain in its current state. Existing topography and on-site soils would not be disturbed by any development. Although the project site would still be subject to potential seismic hazards such as seismic ground shaking, under this alternative, no structures would be present on site. Additionally, paleontological resources would be avoided as no grading or construction would occur . Implementation of MM - GEO-1 as proposed for the project ’s potential impacts to paleontological resources would not be required under this alternative. Thus, the risk of loss, injury, or death involving seismic hazards or other geologic conditions would be reduced compared to development of the proposed project.
Greenhouse Gas Emissions
Under the No Project Alternative, greenhouse gas ( GHG) emissions associated with construction or operation of future residences at the site, including from electricity use, natural gas use, water use, and solid waste hand ling would not occur. No construction would occur; therefore, no construction-related GHG impacts associated with the operation of construction equipment and worker and vendor vehicles would occur like the proposed project. This alternative would not introduce any people or uses that would generate greenhouse gas emissions. GHG emissions associated with vehicular trips would not occur. In comparison to the proposed project, this alternative would reduce greenhouse gas emissions. However, as described in Sections 3.7, Greenhouse Gas Emission, and 3.19 of this EIR, the proposed project’s impacts related to GHG emissions would be less than significant. Th erefore, compared to the proposed project’s less than significant impact to GHGs, the No Project Alternative would have no impacts.
Hazards and Hazardous Materials
Under the No Project Alternative, no land uses would be introduced that could result in the use or generation of hazardous materials. In comparison to the proposed project, this alternative would not have th e potential for transport, accidental release, or spill of hazardous materials during construction of the proposed project and would not expose people or structures to the potential of wildland fires, as the site would remain undeveloped. However, as described in Sections 3.8, Hazards and Hazardous Materials, and 3.19 of this EIR, the proposed project’s impacts 4 - ALTERNATIVES
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related to hazards and hazardous materials would be less than significant. Therefore, compared to the proposed project’s less than significant impact to hazards/hazardous materials, this alternative would have no impacts.
Hydrology and Water Quality
Under the No Project Alternative, no development would occur, and no impervious surfaces would be created. The existing on-site hydrologic conditions, drainage patterns, and drainage volumes would remain unaltered. Water quality would also remain unchanged. However, no best management practices would be implemented , and stormwater runoff would continue to leave the project site untreated. Additionally, as described in Section s 3.9, Hydrology and Water Quality, and 3.19 of this EIR, the proposed project’s impacts to hydrology and water quality would be less than significant. Th erefore, compared to the proposed project ’s less than significant impact to Hydrology/Water Quality, this alternative would have no impacts.
Land Use and Planning
Under this alternative, the project site would remain undeveloped and none of the discretionary approvals identified for the project would be required. The proposed General Plan Amendment (GPA) and rezone of the site from Industrial (I) to Specific Plan Area would not be required. However, this alternative would not meet many of the overall goals of the City’s General Plan, including accommodating growth in areas that can sustain a concentration of a variety of uses in areas suitable for multimodal transportation and achieving balanced distribution of land uses to meet the needs of residents and businesses. Nonetheless, because discretionary approvals would not be required to change the existing land use and zoning designations under this alternative to allow for intended development (i.e., potential conflict regarding consistency with applicable regulations) , impacts to land use and planning would be slightly reduced compared to the proposed project.
Noise
The project site is currently vacant and does not generate any noise. Under the No Project Alternative, the project site would remain undeveloped and would not create any new sources of construction or operational noise.
Additionally, this alternative would not generate any groundborne vibration. However, as described in Sections 3.11, Noise, and 3.19 of this EIR , the proposed project ’s impacts to noise would be less than significant. Therefore, compared to the proposed project’s less-than-significant impact to Noise, this alternative would have no impacts.
Population and Housing
The project site is currently undeveloped. The No Project Alternative would not displace existing housing or people or induce population growth in the area, as no development would occur. However, this alternative would also not contribute to meeting regional housing demands. Similar to the proposed project, this alternative would not displace any housing or people. This alternative would have no impact on inducing unplanned population growth compared to the proposed project’s less-than-significant impacts.
Public Services
The No Project Alternative would not result in an increase in demand for public services since no development would occur. Specifically, the No Project Alternative would not increase the demand for police and fire protection services, nor would this alternative increase the demand on parks, school s, and library services. As stated in Sections 3.13, Public Services, and 3.19 of this EIR , the proposed project would result in less -than-significant 4 - ALTERNATIVES
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impacts to public services. Therefore, compared to the proposed project ’s less-than-significant impact to public services, this alternative would have no impacts.
Recreation
Under the No Project Alternative, there would not be an increased demand for park and recreatio nal facilities. As such, payment of the City ’s Public Facility Fees by the applicant would not be required. However, under this alternative, recreation and open space amenities proposed as part of the project would also not be developed. As stated in Section 3.14, Recreation, of this EIR, the proposed project would result in less-than-significant impacts to recreation. Because this alternative would not result in increased demands to parks and recreation, impacts would be reduced compared to the proposed project.
Transportation
Under the No Project Alternative , no development would occur. Therefore, this alternative would have no direct impact on vehicle miles traveled (VMT), would not result in hazards due to design features , and would not alter emergency access, such that no impact would occur. However, compared to the proposed project, this alternative would not promote sustainability by focusing housing development in an infill area identified as having low VMT due to proximity to existing employment, entertainment, schools, markets, parks, transit, and shopping centers. Additionally, other improvements, such as circulation and pedestrian improv ements, as well as undergrounding of existing overhead utilities, would not occur under this alternative. Compared to the proposed project, the No Project Alternative would result in no impacts related to transportation.
Tribal Cultural Resources
The No Project Alternative would not require any ground -disturbing or other construction/development activities.
Therefore, there would be no potential to impact unknown tribal cultural resources potentially located within the project site. However, although there may be a reduced level of direct impact to tribal cultural resources, any previously undiscovered on-site resources could be subject to continued degradation due to lack of preservation with the undeveloped site.
Nevertheless, because the site would not be disturbed under this alternative, mitigation measures MM -TCR-1 through MM-TCR-4 proposed for the project would not be implemented or required under this alternative. Compared to the proposed project, this alternative would result in a reduced level of impact to tribal cultural resources.
Utilities and Service Systems
No development would occur under the No Project Alternative. As such, the increase in demand for water service, wastewater service, and solid waste handling services would be eliminated. As discussed in Sections 3.17, Utilities and Service Systems, and 3.19 of this EIR, impacts to utilities and service systems were determined to be less than significant under the proposed project. Nonetheless, because no development would occur under this alternative, the demand for utilities would be eliminated. Therefore, impacts to utilities and service systems would be reduced under this alternative compared to the proposed project and no impacts on utilities and service systems would occur.
Wildfire
The No Project A lternative would not introduce any development and would therefore not impair any emergency response plan or evacuation plan , exacerbate wildfire risk, nor expose occupants to hazards. As discussed in 4 - ALTERNATIVES
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Sections 3.18, Wildfire, and 3.19 of this EIR, impacts to wildfire were determined to be less than significant under the proposed project. Nonetheless, because no development would occur under this alternative, no impacts related to wildfire exacerbation would occur under this alternative.
Summary and Relation to Project Objectives
Since the No Project Alternative would not provide any development, overall impacts would be reduced compared to the proposed project. However, certain benefits would not be realized under this alternative, including the provision of housing units as identified in the General Plan in an infill area ; restoring, managing, and conserving biological resources; and enhanced uses and connectivity in the surrounding area.
As the No Project Alternative would not develop the site or allow for housing, this alternative would not fulfill any of the project objectives.
4.4.4 Existing Land Use Designation Alternative
Under the Existing Land Use Designation Alternative, the project site would be developed per the City ’s General Plan land use designation as an Industrial (I) land use. The purpose of the Industrial land use designation is to “provide a setting for the full range of indoor manufacturing, distribution, warehousing, processing, and general service uses that are adequately served by vehicular arterials and utilities. Industries that use hazardous materials, require heavy equipment, and/or that generate sustained noise levels are deemed appropriate for this Zone.” The Industrial Zone is intended to implement and be consistent with the Industrial land use designation of the General Plan (City of San Marcos 2018). For the purpose of this analysis, and to provide a direct comparison against the proposed project, the existing land use alternative assumes development of 480,000 square feet of research and development area with a 220,000-square-foot (1,440 spaces), four-story parking structure. Similar to the project, over 17 acres would be set aside for biological preservation (please refer to Figure 4 -1, Existing Land Use Designation Alternative).
Comparison of the Effects of the Existing Land Use Designation Alternative to the Proposed Project Aesthetics
The Existing Land Use Designation Alternative would develop industrial uses on the currently undeveloped site. As described above, to provide a direct comparison against the proposed project, it has been assumed that under this alternative the industrial layout of the site would reflect a similar footprint to that of the proposed project. Similar to the proposed project, this alternative would develop 15.28 acres and preserve 17.94 acres of the 33.2-acre project site. This alternative would consist of development of 480,000 square feet of research and development area with a 220,000-square-foot (1,440 spaces), four-story parking structure. This alternative would similarly result in similar less than significant impacts or no impacts related to scenic vistas, scenic highways, and visual character or quality, or lighting and glare compared to the proposed project. The visual character of the site would change from vacant to industrial, which is consistent with the existing land use designation and immediately adjacent uses to the north.
New sources of lighting would be introduced, but similar to the project, would be required to comply with the City’s Light and Glare Standards. Therefore, aesthetic impacts of the Existing Land Use Designation Alternative would be comparable to the proposed project.
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Air Quality
Under the Existing Land Use Designation Alternative, air pollutant emissions associated with project construction including emissions associated with grading, site preparation, site finishing and building finishing would occur, which would be similar to th e proposed project. Mitigation would be required to reduce potential construction air quality impacts.
Under the Existing Land Use Designation Alternative, mobile source operational emissions from light vehicle trips may be similar to or lower than the proposed project, depending upon the number of employee vehicles driving to and from the proposed project site. However, industrial development would likely result in greater stationary source operational air pollutant emissions compared to the proposed project’s residential use of the site. Industrial uses including manufacturing generally use more energy and water than residential land uses, which translate to increased air pollutant emissions related to energy generation, energy transmission, etc. Diesel particulate matter emissions from heavy-duty equipment operations and heavy-duty truck trips associated with industrial warehouses may also generate significant operational emissions, which could potentially result in associated health impacts to nearby sensitive receptors. Unlike operation of a residential development, development of the Existing Land Use Designation Alternative could result in significant long -term Toxic Air Contaminant emissions, including diesel particulate matter. Industrial development of the site may also result in adverse impacts from odors associated with manufacturing or processing. As such, this alternative would likely result in greater impacts to air quality compared to the proposed project.
Biological Resources
The development footprint of the Existing Land Use Designation Alternative would result in a similar ground disturbance area on the project site. Development of this alternative would result in a similar potential to impact existing biological resources on site, including loss of upland vegetation communities and impacts to special-status species, riparian habitat and sensitive natural communities and jurisdictional wetlands and waterways . Like the project, this Alternative would likely require mitigation measures similar to MM-BIO-1 through MM-BIO-8b in order to reduce impacts to biological resources. With implementation of mitigation measures similar to those proposed for the project, this alternative would result in similar impacts to biological resources compared to the project.
Cultural Resources
The development footprint of the Existing Land Use Designation Alternative would be similar to the proposed project and would result in similar ground -disturbance. Therefore, the potential to impact to unknown archaeological resources located within the project site, as well as unidentified human remains, would occur within a similar area in comparison to the proposed project. As with the proposed project, implementation of mitigation measures similar to MM-TCR-1 through MM-TCR-4 would be required to reduce potential impacts to unknown/unidentified cultural resources. With implementation of mitigation measures similar to those proposed within the project, this alternative would result in a similar level of impacts to cultural resources compared to the project.
Energy
Development of the Existing Land Use Designation Alternative would result in construction and operational energy use. Energy use during construction would be similar to the proposed project and primarily be associated with construction equipment, as -necessary lighting, and electronic equipment such as computers inside temporary construction trailers and heating, ventilation, and air conditioning. The operation of this alternative would require 4 - ALTERNATIVES
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electricity for multiple purposes, proposed daily uses associated with the industrial land use, cooling, lighting, and various equipment. Additionally, the supply, conveyance, treatment, and distribution of water would indirectly result in electricity usage.
The Existing Land Use Designation Alternative demand for energy use is expected to be similar to that required to serve a 449 -unit residential project (approximately 1,388 residents), or greater. As such, demand for energy is determined to be comparable to the proposed project under the Existing Land Use Designation Alternative.
Similar to the proposed project, this alternative would be required to comply with building requirements (including Title 24 standards) designed to ensure efficient energy use, reduce energy demand, and comply with state and local renewable energy and ener gy efficiency requirements. Petroleum use during operation of the Existing Land Use Designation Alternative is expected to be increased compared to the proposed project as a result of industrial land use activities and vehicles. As such, demand for energy is determined to be comparable to the proposed project under this alternative, and less-than-significant impacts to energy would occur.
Geology and Soils
Under the Existing Land Use Designation Alternative, although the project site would be developed with different land uses, ground-disturbance areas would be similar. Development under this alternative would be subject to the same potential seismic hazards such as seismic ground shaking. This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation for the proposed project.
Similar to the proposed project, due to the high paleontological resources potential on-site, mitigation such as MM- GEO-1 as proposed for the project would be required under this alternative. Compared to the proposed project, this alternative would result in similar level of impacts to geology and soils.
Greenhouse Gas Emissions
Construction and operation of the Existing Land Use Designation Alternative would result in construction GHG emissions that are primarily associated with use of off-road construction equipment, on-road vehicles, vendor trucks, daily operations, and worker vehicles. Although this Alternative proposed assumes the same building footprint to that of the proposed project, the Greenhouse Gas Emissions associated with this alternative are expected to be greater due to typical daily operations associated with such industrial land uses. Additionally, the City’s zoning does not have an open space requirement for industrial uses like the projects residential land use requires.
Although this alternative is not expected to conflict with an applicable GHG-related plan, policy, or regulation due to consistency with the existing General Plan land use and zoning designation , the Existing Land Use Designation Alternative is expected to result in greater emissions compared to the project due to operational uses typical of industrial projects. As such, impacts to GHG emissions under the Existing Land Use Designation Alternative would be greater in comparison to the proposed project.
Hazards and Hazardous Materials
Similar to the proposed project, there is the potential for the Existing Land Use Designation Alternative to generate hazardous materials during construction; however, existing federal and state standards are in place for the handling, storage, and transport of these materials. Because the Existing Land Use Designation Alternative would result in development of industrial uses on site, operation of this alternative would likely result in increased use of hazardous materials on site compared to t he household products that would be utilized under the project ’s 4 - ALTERNATIVES
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proposed residential uses. Therefore, compared to the proposed project, this alternative would result in greater impacts related to hazards and hazardous materials.
Hydrology and Water Quality
As described above, the Existing Land Use Designation Alternative would result in a similar disturbance area on the project site. Due to uses associated with industrial development, it is assumed that this alternative would introduce more impervious surfaces to the site compared to the proposed project, as the proposed project would be required to incorporate open space and landscaped areas for residents under the City ’s Municipal Code. Development of both the proposed project and this alternative would alter the existing on -site hydrologic conditions, drainage patterns, and drainage volumes in comparison to existing vacant conditions. It is expected that this alternative, like the proposed project, would also incorporate all required and applicable best management practices to avoid any violations of water quality standards, or otherwise modify or adversely affect surface and groundwater quality or increase runoff rate or volume from the site. Therefore, as compared to the proposed project, this alternative would result in similar, less-than-significant impacts.
Land Use and Planning
Because development of this alternative would be consistent with land uses identified in the City’s General Plan, a GPA and rezone would not be required. Development of an industrial use on the project site would also be consistent with adjacent land uses. By contrast, the proposed project would introduce population growth in an area of the City that h as not been accounted for in the City ’s General Plan. Therefore, because this alternative would avoid a GPA/Rezone, which would be required for the proposed project, no impacts would occur under this alternative, and impacts would be reduced compared to the proposed project.
Noise
The Existing Land Use Designation Alternative would result in similar ground -disturbance on site in comparison to the proposed project. As analyzed in Sections 3.11 and 3.1 9 of this EIR, proposed project noise impacts were determined to be less than significant. Construction noise of this alternative is expected to be similar to that of the proposed project. Operationally, this alternative may result in greater noise generati on during working hours, particularly with components such as outdoor work yards. While it is likely that such industrial uses would generate more noise than a residential development, it would be expected that the uses would comply with the City’s noise ordinance regarding generation of noise at the property line, and that appropriate mitigation would be implemented as needed to reduce potential impacts to less than significant. Therefore, compared to the proposed project, this alternative would result in similar impacts.
Population and Housing
The Existing Land Use Designation Alternative would not induce substantial unplanned population growth in the area, either directly or indirectly. This alternative would propose a new business consistent with the General Plan and provide for infrastructure only as needed to serve the alternative. The proposed project seeks to change the land use designation of the project site to allow for development of residential land uses that have not been accounted for in the City ’s General Plan; however, the proposed new homes and associated estimate of 1,388 residents is not expected to substantially induce unplanned population growth in this infill area. Like the proposed project the Existing Land Use Designation Alternative would have no impact related to displacin g substantial 4 - ALTERNATIVES
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numbers of people or housing. Therefore, impacts related to population and housing for this alternative would be reduced compared to the proposed project’s less-than-significant impact.
Public Services
Similar to the proposed project, the Existing Land Use Designation Alternative would result in an increase in demand for public services due to the development of a currently vacant site. However, industrial development under this alternative would likely result in less of a demand on public services (especially parks, schools , and libraries) compared to residential development proposed by the project. Therefore, impacts to public services under this alternative would be reduced compared to the proposed project but remain less than significant.
Recreation
Unlike the proposed project, the Existing Land Use Designation Alternative would not result in an increase in demand for parks and recreation services over existing conditions, as no residents or substantial population generation would be associated with development of Industrial uses on site. Additionally, this alternative would likely not require usable open space on site. This alternative would result in reduced impacts to recreational facilities compared to the proposed project but remain less than significant.
Transportation
The Existing Land Use Designation Alternative is assumed to be served by a larger volume of large trucks and machinery during both construction and operation of this alternative. However, such uses would be compatible with surrounding industrial uses, and are unlikely to result in hazards due to design features or incompatible uses, similar to the proposed project. It is anticipated that this alternative would be required to provide adequate emergency access, similar to the project.
VMT for the Existing Land Use Designation Alternative is expected to be similar or greater in comparison to the proposed project as a result of operational uses typical of an industrial project, including daily transport and volume of large trucks. Further, this alternative would not promote sustainability by focusing housing development in an infill area identified as having low VMT due to proximity to existing employment, entertainment, schools, markets, parks, transit, and shopping centers.
This Alternative would like result in a larger volume of large trucks and machinery during both construction and operation of this alternative. However, such uses would be compatible with surrounding industrial uses, and are unlikely to result in hazards d ue to design features or incompatible uses. Compared to the proposed project, the Existing Land Use Designation Alternative is expected to result in similar or greater impacts related to transportation.
Tribal Cultural Resources
This alternative would result in new industrial development within a similar footprint as the proposed project on a currently vacant site. As such, this alternative would have similar potential to affect unknown tribal cultural resources compared to the pr oposed project. It is expected that this alternative would require implementation of mitigation measures similar to MM -TCR-1 through MM -TCR-4 proposed for the project. Thus, with the implementation of mitigation, impacts to tribal cultural resources would be similar to the proposed project ’s and less than significant.
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Utilities and Service Systems
The Existing Land Use Designation Alternative demand for water service, energy and solid waste is expected to be greater than that required to serve a 449 -unit residential project (approximately 1,388 residents). As described under the Air Quality analysis above, industrial uses including manufacturing generally use more energy and water than residential land uses. As such, the Existing Land Use Designation Alternative’s demand for utilities and service systems is likely to be greater than the proposed project.
Wildfire
As discussed in Sections 3.18 and 3.19 of this EIR, and in the Fire Protection Plan (Appendix N to this EIR), impacts to wildfire were determined to be less than significant under the proposed project. The site is located in an urbanized, infill area and is not located in any fire hazard severity zones or near any local responsibility areas, state responsibility areas, or near lands classified as very high fire hazards severity zones. Like the proposed project, the Existing Land Use Designation Alternative would be required to comply with all applicable state and local fire codes. Because impacts related to hazards and hazardous materials under this alternative would likely increase as a result of industrial uses on site, the potential for fire risk under this alternative is expected to increase in comparison to the proposed project. Similar to the proposed project, the Existing Land Use Designation Alternative is not expected to impair an emergency response plan or e vacuation plan. Impacts related to wildfir e under this alternative are expected to be similar to or slightly greater than the proposed project.
Summary and Relation to Project Objectives
Under the Existing Land Use Designation Alternative, the project site would be developed per the City ’s General Plan land use designation as an Industrial (I) land use. As described above, this alternative would develop 15.28 acres and preserve 17.94 acres of the 33.2 -acre project site. This alternative would consist of development of 480,000 square feet of research and development area with a 220,000 -square-foot (1,440 spaces) , four-story parking structure. Similar to the project, over 17 acres would be set aside for biological preservation.
Because development of the Existing Land Use Designation Alternative would include grading and development of the same site, construction -related impacts would be similar to the proposed project and would require similar mitigation for impacts to air quality, biological resources, cultural resources and tribal cultural resources. However, the industrial use of the site would be expected to result in greater impacts to air quality, GHG emissions, hazards and hazardous materials, transportation, and wildfire, in comparison to the impacts resulting from the proposed project’s residential use, and additional mitigation may be required.
This alternative would promote infill development on site; however, it would not fulfill any of the basic project objectives and would also not aid the City in achieving its Regional Housing Needs Assessment allocation.
Furthermore, the proposed project site has been designated for industrial development und er the existing and previous General Plans but has remained vacant, evidencing that its constraints have rendered it not marketable and socially and environmentally infeasible for industrial uses.
Although this alternative would be consistent with the existing designated land use and zoning for the site and adjacent land uses on La Mirada Drive, this alternative would not reduce or avoid significant environmental impacts and would not meet any project objectives.
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4.4.5 Reduced Development Footprint Alternative
The Reduced Development Footprint Alternative has been developed in response to comments from the Wildlife Agencies and would reduce the development footprint at the site from 15.28 acres to 8.3 acres and reduce the number of residential units developed from 449 to 321 units . This alternative would be constructed to avoid all vernal pools and wetlands mapped across the site, including pools/basins found not to support vernal pool branchiopods (fairy shrimp), and achieve a 25% maximum building footprint at the site. In order to avoid all these areas while implementing basic project objectives, the project development footprint would be constructed in three separate, non-contiguous area s of the site : the northwest corner, the northeast corner, and the south -central portions of the site (refer to Figure 4-2, Reduced Development Footprint Alternative).
Comparison of the Effects of the Reduced Development Footprint Alternative to the Proposed Project
Aesthetics
The Reduced Development Footprint Alternative would reduce the s cope of the proposed project development footprint to 8.3 acres and reducing the housing unit count to 321 units but would introduce non -contiguous development in three areas of the site . Similar to the proposed project, t his alternative would result in less-than- significant impacts related to aesthetics. The visual character of the site would change from vacant to residential in an urbanized and developed area . Compared to the proposed project, the Reduced Development Footprint Alternative would somewhat increase impacts related to visual character and consistency with surrounding, developed uses by developing three separate, non -contiguous areas of the site to maximize biological resource preservation. New sources of lighting would be introduced, but, similar to the project, would be required to comply with the City ’s Light and Glare Standards. Therefore, aesthetic impacts of the Reduced Development Footprint Alternative would be comparable to the proposed project.
Air Quality
Under the Reduced Development Footprint Alternative, air pollutant emissions associated with project construction, including emissions associated with grading, site preparation, site finishing and building finishing, would be similar compared to the proposed project. While this alternative would reduce the development footprint, additional construction work would be needed in discrete areas of the site. Similar to the proposed project, mitigation would be required to reduce potential air quality impacts associated with construction.
Under the Reduced Development Footprint Alternative, mobile source operational emissions from light vehicle trips would be lower than the proposed project as a result of the reduced unit count. As such, this alternative would likely result in overall reduced impacts to operational air quality compared to the proposed project.
Biological Resources
The Reduced Development Footprint Alternative would result in a reduced ground disturbance area on the project site based upon the 25% maximum development footprint layout . Because reduced ground disturbance would occur under this alternative, there would be less impact existing biological resources on site, specifically impacts to vernal pools.
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However, although this alternative layout would reduce impacts to the vernal pools, it would cause a more severe significant impact to the federally listed threatened thread-leaved brodiaea (a Multiple Species Conservation Program Narrow Endemic species) as it would impact approximately 53% of the thread -leaved brodiaea and its critical habitat on site, in comparison to the project’s direct impact to 19% of thread-leaved brodiaea.
In addition, the separated development areas and the irregular development footprints needed to accommodate housing would result in increased interfaces/edges of the development with the vernal pool and biological habitat areas, which would be greater than if the proposed project ’s single consolidated development envelope were developed. Edge effects refer to off-site and on-site indirect impacts that are short-term (i.e., not permanent) as a result of project construction or long-term (i.e., permanent) due to the design of the proposed project and the effects it may have to adjacent resources. Edge effects would potentially be increased under this alternative in comparison to the proposed project.
Therefore, similar to the project, this alternative would be required to incorporate mitigation measures similar to MM- BIO-1a through MM-BIO-8b to reduce significant impacts to biological resources. This alternative would result in increased impacts to thread-leaved brodiaea, but reduced impacts to vernal pools, in comparison to the project.
Implementation of mitigation measures would be required to reduce this alternative to a less than significant impact.
Cultural Resources
The Reduced Development Footprint Alternative would result in less ground-disturbance compared to the proposed project. Therefore, the potential to impact unknown archaeological resources located within the project site, as well as unidentified human remains, would occur within a smaller area compared to the proposed project, resulting in potentially reduced impacts. However, as with the proposed project, implementation of mitigation measures similar to MM-TCR-1 through MM-TCR-4 would be required to reduce potential impacts to unknown/unidentified cultural resources. With implementation of mitigation measures similar to those proposed within the project, this alternative is expected to result in a similar level of less-than-significant impacts to cultural resources compared to the project.
Energy
Under the Reduced Development Footprint Alternative, development would result in construction and operational energy use. Energy use during construction would primarily be associated with construction equipment, as- necessary lighting, and electronic equipment, such as computers inside temporary construction trailers and HVAC, similar to the proposed project . Natural gas is not anticipated to be used during construction, similar to the proposed project, and would be temporary and negligible if used. Petroleum would be used throughout construction of the alternative and would be similar to the proposed project. While the footprint would be reduced compared to the proposed project, construction would be less efficient due to operations in three separate locations on site.
Ultimately, like the proposed project, the petroleum consumed related to construction would be typical of construction projects of similar types and sizes and would not be wasteful or inefficient.
The operation of this alternative would also require electricity for multiple purposes, similar to the proposed project.
The Reduced Development Footprint Alternative demand for energy use is expected to be similar to or slightly less than that required to serve the proposed project. Similar to the proposed project, this alternative would be required to comply with building requirements (including Title 24 standards) designed to ensure efficient energy use, reduce energy demand, and comply with state and lo cal renewable energy and energy efficiency requirements. Like the proposed project, the operation of residential units would require natural gas for space heating and to power appliances, but compliance with Title 24 would ensure its efficient use. Petroleum use during operation would be 4 - ALTERNATIVES
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slightly reduced compared to the proposed project as fewer residents would operate fewer vehicles. However, ultimately this alternative may increase petroleum inefficiencies compared to the project by reducing residential units to be developed at this VMT-efficient urbanized infill location proximate to commercial uses, transit, and other infrastructure. As such, demand for energy is determined to be comparable to the proposed project under this alternative. Therefore similar, less-than-significant impacts to energy would occur under this alternative.
Geology and Soils
Under the Reduced Development Footprint Alternative, ground -disturbance areas would be reduced. However, development under this alternative would be subject to the same potential seismic hazards, such as seismic ground shaking. This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation for the proposed project. Similar to the proposed project, due to the high potential for paleontological resources on-site, mitigation such as MM -GEO-1 as proposed for the project would be required under this alternative. would be avoided because the potential for paleontological resources to be located on the project site is considered low. Compared to the proposed project, this alternative would result in similar level of impacts to geology and soils.
Greenhouse Gas Emissions
Construction of the Reduced Development Footprint Alternative would result in construction GHG emissions that are primarily associated with use of off-road construction equipment, on-road vehicles, vendor trucks, and worker vehicles, similar to the proposed project.
Estimated annual operational GHG emissions from this alternative would be reduced compared to the proposed project as a result of the reduced unit count and associated vehicle trips, utility usage and development footprint area. Thus, this alternative would result in reduced GHG emissions compared to the proposed project.
Hazards and Hazardous Materials
Similar to the proposed project, there is the potential for the Reduced Development Footprint Alternative to generate hazardous materials during construction; however, existing federal and state standards are in place for the handling, storage and transport of these materials. Because the Reduced Development Footprint Alternative would result in similar development of residential units on site, operation of this alternative would result in similar use of hazardous materials on site, such as household produc ts, that would be utilized under the proposed project.
Therefore, compared to the proposed project, this alternative would result in similar impacts related to hazards and hazardous materials.
Hydrology and Water Quality
As described above, the Reduced Development Footprint Alternative would result in a reduced ground disturbance area on the project site as a result of the reduced building footprint compared to the proposed project. Due to the reduced footprint under this alternative, less impervious surfaces would be introduced to the site compared to the proposed project. Development of both the proposed project and this alternative would alter t he existing on-site hydrologic conditions, drainage patterns, and drainage volumes in comparison to existing vacant conditions. There is a seasonal north -south trending drainage ditch in the southern portion of the project site, adjacent South Las Posas Road, that would be impacted as a result of this alternative layout. It is expected that this alternative , like the proposed project, would also incorporate all required and applicable best management practices to avoid any 4 - ALTERNATIVES
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violations of water quality standards , or otherwise modify or adversely affect surface and groundwater quality or increase runoff rate or volume from the site. Therefore, as compared to the proposed project, this alternative would result in similar, less-than-significant impacts to hydrology and water quality.
Land Use and Planning
The Reduced Development Footprint Alternative would have no impact related to physically dividing an established community, like the proposed project. Because development of this alternative would introduce housing on site, a GPA and rezone would be required, similar to the proposed project. Similar to the proposed project, this alternative would introduce population growth in an area of the City that has not been accounted for in the City’s General Plan. Like the proposed project, this alternative would not create a significant impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. However, it would not promote sustainability through locating residential uses on an underutilized infill site proximate to existing schools, markets, parks, transit, and shopping centers to the same extent as the proposed project. Therefore, because this alternative would also require a GPA/Rezone but would not conflict with applicable plans, policies, and regulations, impacts under this alternative would result in similar impacts to land use to that of the proposed project.
Noise
The Reduced Development Footprint Alternative would result in a reduced development footprint on site with 8.3-ares developed in comparison to the proposed project’s development footprint of 15.28 acres. As analyzed in Sections
3.11 and 3.19 of this EIR, noise impacts associated with the propose d project were determined to be less than significant. Construction noise of this alternative is expected to be similar to that of the proposed project, although the construction schedule for this alternative would be slightly shorter. Operationally, this alternative would result in similar noise generation to that of the proposed project. Development of this alternative would be expected to comply with the City’s noise ordinance regarding generation of noise at the property line , and appropriate mitigation would be implemented as needed to reduce potential impacts to less than significant. Therefore, as compared to the proposed project, this alternative would result in similar, less-than-significant impacts related to noise.
Population and Housing
The Reduced Development Footprint Alternative would similarly introduce unplanned population growth in the area with the development of 321 housing units on the currently vacant site. The proposed project seeks to change the land use designation of the project site to allow for development of r esidential land uses that have not been accounted for in the City ’s General Plan . Development of this alternative would also require a GPA/Rezone.
However, similar to the project, the new homes under this alternative would not be considered to substantially induce unplanned population growth as the project site is an infill site surrounding by existing roadways, utilities and development. Like the proposed project, this alternative would have no impact related to displacing substantial numbers of people or housing. Therefore, impacts related to population and housing for this alternative would be similar to the proposed project’s less-than-significant impact.
Public Services
Similar to the proposed project, the Reduced Development Footprint Alternative would result in an increase in demand for public services due to the development of a currently vacant site. However, due to the reduced number in housing units under this alternative in comparison to the proposed project, this alternative would likely result in 4 - ALTERNATIVES
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less of a demand on public services. Therefore, impacts to public services under this alternative would be slightly reduced compared to the proposed project, but remain less than significant.
Recreation
Similar to the proposed project, the Reduced Development Footprint Alternative would result in an increase d demand on existing park and recreational facilities within the City with the introduction of 321 housing units.
However, similar to the proposed project, this alternative would be required to incorporate open space on site and would be required to pay into applicable developer and park impact fees. Therefore, impacts related to recreation for this alternative would be similar to the proposed project’s less-than-significant impact.
Transportation
The Reduced Development Footprint Alternative would be served by similar vehicle traffic during construction compared to the proposed project, though construction traffic access would be altered due to the modified footprint.
Construction traffic impacts would be less than significant, as with the proposed project.
During operation, project access points for this alternative would be provided by one entry/exit off Linda Vista Drive to serve the apartments, and two different access points off La Mirada Drive to serve the rowhomes (one in the northwest corner and one in the northeast corner). It is anticipated that this alternative would provide adequate emergency access, similar to the project. Additionally, the detached site configuration of this alternative creates potential challenges for pedestrian connections, including incorporation of the urban trail as proposed by the project.
VMT for this alternative is likely to be similar in comparison to the proposed project. Compared to the proposed project, this alternative would result in similar, less-than-significant impacts related to transportation.
Tribal Cultural Resources
This alternative would result in new development within a similar but slightly reduced footprint on the project site. As such, this alternative would have similar or slightly less potential to affect unknown tribal cultural resources compared to the proposed project. It is expected that t his alternative would require implementation of mitigation measures similar to MM-TCR-1 through MM-TCR-4 proposed for the project. Thus, with the implementation of mitigation, impacts to tribal cultural resources would be similar to the proposed project and would be less than significant.
Utilities and Service Systems
The Reduced Development Footprint Alternative demand for water service, energy, and solid waste is expected to be slightly less than that required to serve the proposed project as a result of the reduced unit count from 449 to 321 units under this alternative . However, the detached site configuration under this alternative may create challenges for utility connection and service. Nonetheless, demand for utilities and service systems is determined to be slightly less than the proposed project under this alternative, but still result in a less-than-significant impact, similar to the proposed project.
Wildfire
As discussed in Sections 3.18 and 3.19 of this EIR, and in the Fire Protection Plan (Appendix N to this EIR), impacts to wildfire were determined to be less -than-significant under the proposed project. The site is located in an urbanized, infill area and is not located in any fire hazard severity zones or near any local responsibility areas, state 4 - ALTERNATIVES
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responsibility areas, or near lands classified as very high fire hazards severity zones. Like the proposed project, the Reduced Development Footprint Alternative’s development of 321 residential units would be required to comply with all applicable state and local fire codes. This alternative would therefore not exacerbate wildfire risk nor expose occupants to hazards or other significant risks of loss, injury, or death concerning wildland fires. Impacts related to wildfire under this alternative are expected to be similar to the proposed project.
Summary and Relation to Project Objectives
The Reduced Development Footprint Alternative would include development of 321 units on 8.3 acres of the 33.2- acre site, with the remaining 24.9 acres preserved (refer to Figure 4-2). Because development of this alternative would include construction of the same site, construction -related impacts would be similar to the proposed project and , like the proposed project, would require similar mitigation for impacts to air quality, biological resources, cultural resources and tribal cultural resources. While the development footprint under this alternative (8.3 acres) would be less than that analyzed for the proposed project (15.28 acres), edge effects (indirect impacts that are short -term (i.e., not permanent) as a result of project construction or long -term (i.e., permanent) due to the design of the proposed project and the effects it may have to adjacent resources) to biological resources and impacts to federally listed threatened and state -listed endangered thread-leaved brodiaea would be increased.
Although this alternative would avoid or minimize impacts to vernal pools in comparison to the proposed project, it would cause greater impacts thread-leaved brodiaea.
While this alternative would develop infill housing on an urbanized site and rezone the site to residential to assist the City to implement its housing goals (project objectives 1 and 2), it would implement less housing compared to the proposed project and less efficiently promote infill development. This alternative would also provide less varied housing compared to the proposed project, including less affordable housing (objective 3). This alternative would meet objective 4 by avoiding vernal pools but would result in greater impacts to thread-leaved brodiaea that would be inconsistent with objective 4 . This alternative would not meet project objective 5 because the site would be atypically designed in a manner that does not enhance connectivity. This alternative would also not meet objective 6 to the same extent as the project, as it would not maximize housing density for the City.
4.4.6 Reduced Development Footprint Alternative – Vernal Pool Impact Minimization
In response to comments received from USFWS on the Draft EIR, this Reduced Development Footprint Alternative – Vernal Pool Impact Minimization , considers a variation on the Reduced Development Footprint Alternative previously evaluated above under Section 4.4.5 . Under the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization, development would occur only within a reduced development footprint in the southern portion of the Project site, . The reduced development consists of 228 residential units, including a mix of rowhomes and villas on approximately 9.7 acres of the 33.2 -acre project site. The reduced development includes a total of 532 parking spaces and 82,311 square feet of common open space area. The reduced development also includes landscaping, bio-retention areas, and circulation improvements. The remaining approximately 23.5 acres of the
33.2-acre project site would be preserved and restored as open space and habitat area. The reduced development would have a density of approximately 6.86 dwelling units per acre, including the open space and habitat area (please refer to Figure 4-3 of the Final EIR).
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Similar to the proposed project, this alternative would require a General Plan Amendment, Rezone, Specific Plan, Tentative Map, and Multi-Family Site Development Plan. The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Industrial (I) to Specific Plan Area (SPA).
Comparison of the Effects of the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization to the Proposed Project
Aesthetics
The Reduced Development Footprint Alternative – Vernal Pool Impact Minimization would reduce the scope of the proposed project development footprint to 9.7 acres (from 15.09) and reduce the housing unit count to 228 units (from 449). All development would occur on the southern portion of the site under this alternative, as shown in Figure 4-3. Similar to the proposed project, t his alternative would result in less-than-significant impacts related to aesthetics. The visual character of the site would change from vacant to residential in an urbanized and developed area. Compared to the proposed project, this alternative would not increase impacts related to visual character and consistency with surrounding, developed uses because it would develop one contiguous area in the southern portion of the site to maximize biological resource preservation. New sources of lighting would be introduced, but, similar to the proposed project, would be required to comply with the City’s Light and Glare Standards. Therefore, aesthetic impacts of this alternative would be comparable to the proposed project.
Air Quality
The proposed Reduced Development Footprint Alternative – Vernal Pool Impact Minimization would reduce the number of units compared to the proposed project by 221 units. As the project site is zoned industrial, the alternative would still need a GPA/Rezone to a SPA. However, this proposed alternative would still be within the SANDAG growth projections for the City and therefore would not conflict with the RAQS or SIP. As thisthe proposed alternative would have fewer units than the proposed project, emissions during construction would be similar to or less than that of the proposed project. During operation, this proposed alternative would result in fewer emissions compared to the proposed project due to the reduction in units and vehicle trips. This proposed alternative would have similar or reduced impacts to sensitive receptors compared to the proposed project due to the reduction in disturbed area and focus in the southern portion of the site. This proposed alternative would not result in odors during construction or operation that adversely affect a substantial number of people. Overall, impacts of this proposed alternative would have similar to or reduced impacts to air quality compared to the proposed project (please refer to the Air Quality and Greenhouse Gas Emissions Technical Memorandum prepared for this alternative, included as Appendix B-1 to the Final EIR).
Biological Resources
In response to the Draft EIR, the USFWS requested that the Final EIR include an alternative that limits impacts to 25% of the site and restricts development to the southernmost third of the site. A biological resources memorandum was prepared to analyze this additional alternative, and is included as Appendix C-1 to the Final EIR. As outlined in this memorandum, this alternative would result in approximately 16% less (5.22 acres less) development impact area within the 33.2-acre project site in comparison to the proposed project. When comparing impacts to biological resources, the proposed project and this alternative would both impact native vegetation, vernal pools, and listed special-status plant species. However, the proposed project would also impact a listed special -status animal (federally listed endangered San Diego fairy shrimp) whereas this alternative would have no impacts to listed special-status animals. Both the proposed project and this alternative would result in impacts to grassland, Diegan 4 - ALTERNATIVES
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coastal sage scrub, and vernal pool vegetation. Although both projects would impact vernal pools, the proposed project would impact vernal pools and other features known to be occupied by San Diego fairy shrimp. This alternative would avoid all features occupied by San Diego fairy shrimp. Please refer to Table 4-3, Figure 4-3, and Figure 4-5.
Regarding listed special-status plants, the proposed project would impact two listed plant species (thread -leaved brodiaea and San Diego button celery), while this alternative would impact only thread-leaved brodiaea. However, this alternative would impact a larger amount of thread-leaved brodiaea in comparison to the project; approximately 72,158 additional plants impacted , which in total reflects impacts to approximately 60% of the thread -leaved brodiaea population at the site.
This alternative would cluster development along and within the southern boundary of the project site which would reduce the development interfaces adjacent to proposed biological resource preservation areas on -site. This alternative layout is expected to result in a reduction of pote ntial indirect impacts related to edge effects.
Nonetheless, this alternative would still be required to incorporate mitigation measures MM -BIO-1a through MM- BIO-8b as identified for the proposed project, in order to reduce impacts to a less than significant level. Therefore, compared to the proposed project, this alternative would result in a similar determination of less than significant with mitigation incorporated. This alternative would result in reduced biological impacts to San Diego button celery and vernal pools, but increased impacts to thread-leaved brodiaea.
Cultural Resources
The cultural resources inventory for the proposed project did not identify any cultural resources within the project site, thus, no cultural resources were identified under this Reduced Development Footprint Alternative – Vernal Pool Impact Minimization Area of Potential Effect (APE). Neither the proposed project nor this alternative pose the potential to impact known cultural resources (please refer to the Cultural Resources Impact Memorandum prepared for this alternative, included as Appendix D-1 to the Final EIR) . However, following Native American consultation pursuant to Assembly Bill 52 and Senate Bill 18, the City is including mitigation measures to assure identification and appropriate handling of potentially buried Tribal Cultural Resources (TCR) within the original project site. As this alternative APE proposes a reduced development footprint in comparison to the proposed project, this alternative has a reduced potential of impacting undiscovered TCRs that may be buried within the APE . Mitigation measures TCR-1 to TCR-4 developed for the proposed project would apply to this alternative and would be sufficient to reduce impacts to less than significant.
Energy
Under the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization development would result in construction and operational energy use. Energy use during construction would primarily be associated with construction equipment, as -necessary lighting, and electronic equipment, such as computers inside temporary construction trailers and HVAC, similar to the proposed project. Natural gas is not anticipated to be used during construction, similar to the proposed project, and would be temporary and negligible if used. Petroleum would be used throughout construction of the alternative and would be similar to the proposed project. Ultimately, like the proposed project, the petroleum consumption related to construction would be typical of construction projects of similar types and sizes and would not be wasteful or inefficient. The footprint for this alternative would be reduced compared to the proposed project and would be more efficient due to construction of less units all concentrated on the southern portion of the project site.
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The operation of this alternative would also require electricity for multiple purposes, similar to the proposed project.
The Reduced Development Footprint Alternative – Vernal Pool Impact Minimization demand for energy use is expected to be less than that required to serve the proposed project due to the reduction in development proposed.
Similar to the proposed project, this alternative would be required to comply with building requirements (including Title 24 standards) designed to ensure efficient energy use, reduce energy demand, and comply with state and local renewable energy and energy efficiency requirements. Like the proposed project, the operation of residential units would require natural gas for space heating and to power appliances, but complian ce with Title 24 would ensure its efficient use. Petroleum use during operation would be slightly reduced compared to the proposed project as fewer residents would operate fewer vehicles. However, ultimately this alternative may increase petroleum inefficiencies compared to the project by reducing residential units to be developed at this VMT-efficient urbanized infill location proximate to commercial uses, transit, and other infrastructure. As such, demand for energy is determined to be comparable to the proposed project under this alternative. Therefore similar, less-than-significant impacts relative to energy would occur under this alternative.
Geology and Soils
Under the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization , ground -disturbance areas would be reduced. However, development under this alternative would be subject to the same potential seismic hazards, such as seismic ground shaking. This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation for the proposed project (please refer to the Geotechnical Memorandum prepared for this alternative, included as Appendix F-1 to the Final EIR). Similar to the proposed project, due to the high potential for paleontological resources on -site, mitigation measure MM- GEO-1 as proposed for the project would be required under this alternative. Compared to the proposed project, this alternative would result in similar impacts relative to geology and soils.
Greenhouse Gas Emissions
As the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization would have fewer units compared to the proposed project, it would result in fewer emissions of GHGs during construction and operation.
Under this alternative, estimated total GHG emissions generated during operation, including amortized construction emissions, for this alternative would be below that anticipated to be generated under the existing land use designation for the site. The City adopted the Final CAP on December 8, 2020. The CAP relies on a screening threshold based on land use size and a CAP Consistency Checklist to determine whether a project’s emissions would be consistent with GHG emissions estimated within the City’s CAP. The CAP Consistency Checklist is used to determine significance in accordance with CEQA Guidelines Section 15183.5; therefore, the CAP Consistency Checklist was used to evaluate the reduced development’s significance with respect to GHG emissions (please refer to the Air Quality and Greenhouse Gas Emissions Technical Memorandum prepared for this alternative, included as Appendix B-1 to the Final EIR).
This alternative would be consistent with the City’s CAP. This alternative development would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs because there are currently no mandatory GHG regulations or finalized agency guidelines that would apply to implementati on of this project. Accordingly, potential cumulative GHG impacts would be less than significant. Therefore, the proposed alternative would have a less than significant impact on GHGs and impacts would be reduced as compared to the proposed project.
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Hazards and Hazardous Materials
Similar to the proposed project, there is the potential for th is alternative to generate hazardous materials during construction; however, existing federal and state standards are in place for the handling, storage and transport of these materials. Although this alternative would substantially reduce the number of units on -site, this alternative still proposes residential development that would result in similar use of hazardous materials on site, such as household products, that would be utilized under the proposed project. Therefore, compared to the proposed project, this alternati ve would result in similar less than significant impacts related to hazards and hazardous materials.
Hydrology and Water Quality
This alternative would result in a reduced ground disturbance area on the project site as a result of the reduced building footprint compared to the proposed project. Due to the reduced footprint under this alternative, less impervious surfaces would be introduced to the site compared to the proposed project. Development of both the proposed project and this alternative would alter the existing on-site hydrologic conditions, drainage patterns, and drainage volumes in comparison to existing vacant conditions . There is a seasonal north -south trending drainage ditch in the southern portion of the project site, adjacent to South Las Posas Road, that would be impacted as a result of this alternative layout. It is expected that this alternative, like the proposed project, would also incorporate all required and applicable best management practices to avoid any violations of wa ter quality standards, or otherwise modify or adversely affect surface and groundwater quality or increase runoff rate or volume from the site. Therefore, as compared to the proposed project, this alternative would result in similar, less -than-significant impacts to hydrology and water quality (refer to the Preliminary Drainage Study prepared for this alternative, included as Appendix E-1 to the Final EIR; and the SWQMP prepared for this alternative, included as Appendix G-1 to the Final EIR).
Land Use and Planning
This alternative would have no impact related to physically dividing an established community. Because development of this alternative would introduce housing on site, a GPA and rezone would be required, similar to the proposed project. Similar to the proposed project, this alternative would introduce population growth in an area of the City that has not been accounted for in the City’s General Plan. This alternative would not create a significant impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, because this alternative would also require a GPA/Rezone but would not conflict with applicable plans, policies, and regulations, impacts relative to land use and planning under this alternative would be less than significant, similar to that resulting with the proposed project.
Noise
This alternative would concentrate demolition, grading, and building construction activities in the southern portion of the site, over 600 feet from the nearest sensitive receptors to the north. With this greater separation distance, construction noise lev els experienced at sensitive receptors would be substantially reduced compared to the original site plan. Noise attenuation due to geometric spreading would result in over 10 dB of reduction compared to the original estimate of noise levels reaching up to 70 dBA Leq at receptors 150 feet away. Even with the loudest construction activities occurring closer to receptors south of the site that are over 1 ,300 feet away, construction noise would continue to be temporary and occur during allowable daytime hours per the City's noise ordinance. The analysis for the original project did not identify any exceedances of applicable noise standards at nearby receptors. 4 - ALTERNATIVES
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The reduced scale of the alternative project confined to the southern portion of the site would further ensure construction noise impacts remain less than significant without need for additional mitigation, similar to the original project.
The reduction in units from 449 to 228 would proportionally decrease the amount of traffic added to nearby roadways. With 221 fewer units, the project vehicle trip generation would be reduced by approximately 49% (assuming consistent trip generation rates per unit). Traffi c noise levels increase logarithmically in relation to the actual traffic volume. Therefore, a 49% reduction in project traffic volumes would correspond to approximately a 2 dB decrease in traffic noise levels generated by the project. The traffic noise an alysis for the 449-unit project did not identify any significant impacts at sensitive receptors. The incremental 2 dB reduction in traffic noise for the smaller 228-unit project reaffirms that this impact would remain less than significant and marginally improved compared to the prior project site plan. With fewer residential units proposed, stationary noise sources associated with building operations, such as HVAC systems, would likewise be reduced compared to the proposed project.
Stationary noise impacts associated with the 449 -unit project were found to be less than significant. The smaller 228-unit project would further reduce stationary noise levels and this impact would remain less than significant.
The overall reduction in project scale and concentration of construction activities within the remaining project site areas would result in similar vibration levels compared to the proposed project. Construction vibration impacts associated with the 449-unit project were found to be less than significant at nearby sensitive receptors. The 228- unit project would generate similar vibration levels that would remain below thresholds for human annoyance and building damage. Vibration impacts would be similar to the proposed project and less than significant without mitigation needed.
Overall, this alternative would have reduced noise and vibration impacts compared to the proposed project, but would result in similar less than significant impacts (please refer to the Noise Memorandum prepared for this alternative, included as Appendix I-1 to the Final EIR).
Population and Housing
This alternative would similarly introduce unplanned population growth in the area with the development of 228 housing units on the currently vacant site. The proposed project seeks to change the land use designation of the project site to allow for development of residential land uses that have not been accounted for in the City’s General Plan. Development of this alternative would also require a GPA/Rezone. However, similar to the project, the new homes under this alternative would not be considered to substantially induce unplanned population growth as the project site is an infill site surround ed by existing roadways, utilities and development. Like the proposed project, this alternative would have no impact related to displacing substantial numbers of people or housing. Therefore, impacts related to population and housing for this alternative would be similar to the proposed project’s less-than- significant impact.
Public Services
Similar to the proposed project, this alternative would result in an increase in demand for public services due to the development of a currently vacant site. However, due to the reduced number of housing units under this alternative in comparison to the proposed project, this alternative is anticipated to result in less of a demand on public services.
Therefore, impacts to public services under this alternative would be slightly reduced compared to the proposed project, but would remain less than significant..
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Recreation
Similar to the proposed project, this a lternative would result in an increased demand on existing park and recreational facilities within the City with the introduction of 228 housing units. However, similar to the proposed project, this alternative would be required to incorporate open space on site and would be required to pay into applicable developer and park impact fees. Therefore, impacts related to recreation for this alternative would be similar to the proposed project’s less-than-significant impact.
Transportation
This alternative would be served by similar vehicle traffic during construction compared to the proposed project, though construction traffic access would be altered due to the modified footprint. Construction traffic impacts would be less than significant, as with the pro posed project (please refer to the LTA Memorandum prepared for this alternative, included as Appendix K-1 to the Final EIR).
During operation, this alternative is calculated to generate 1,368 daily trips (ADT) with 109 AM peak hour trips and 123 PM peak hour trips. This alternative would resul t in substantial effects at two intersections (Via Vera Cruz/Grand Ave/SR-78 EB Ramps; and Pacific Street/Linda Vista Drive) ; however this alternative would avoid a substantial effect at one intersection and one street segment in comparison occurring with the proposed project.
The proposed driveway location under this alternative on Linda Vista Drive is approximately 650 feet from Las Posas Road and approximately 680 feet from Pacific Street. Queueing at either intersection would not interfere with driveway operations. This alternative would provide roadway improvements to address the identified deficiencies.
VMT for this alternative would be similar in comparison to the proposed project. Compared to the proposed project, this alternative would result in similar, less-than-significant impacts related to transportation.
Tribal Cultural Resources
This alternative would result in residential development of 228 units within a reduced footprint on the project site (see Figure 4-3). As such, this alternative would have a similar or slightly reduced potential to affect unknown tribal cultural resources compared to the proposed project, as described above under Cultural Resources. This alternative would still require implementation of mitigation measures MM-TCR-1 through MM-TCR-4 proposed for the project. Thus, with the implementation of mitigation, impacts to tribal cultural resources would be slightly reduced as compared to the proposed project and would be less than significant with mitigation incorporated.
Utilities and Service Systems
Under this alternative, the fire flow requirements would not change and it is anticipated that the upgrades to any water mains would no longer be required. This is assuming that all of the connections would be on the Linda Vista main which is already a 12 -inch diameter pipe. This alternative would not be expected to create any sewer deficiencies. Compared to the proposed project, this alternative would result in similar, less-than-significant impacts related to utilities and service systems (please refer to the Water and Sewer Study prepared for this alternative , included as Appendix L-1 to the Final EIR).
Wildfire
As discussed in Sections 3.18 and 3.19 of this EIR, and in the Fire Protection Plan (Appendix N to this EIR), impacts related to wildfire were determined to be less-than-significant under the proposed project. The site is located in an 4 - ALTERNATIVES
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urbanized, infill area and is not located in any fire hazard severity zones or near any local responsibility areas, state responsibility areas, or near lands classified as very high fire hazards severity zones. Like the proposed project, this alternative development of 228 residential units would be required to comply with all applicable state and local fire codes. This alternative would therefore not exacerbate wildfire risk nor expose occupants to hazards or other significant risks of loss, injury, or death concerning wildland fires. Impacts related to wildfire under this alternative are expected to be similar to the proposed project.
Summary and Relation to Project Objectives
The Reduced Development Footprint Alternative – Vernal Pool Impact Minimization would include development of 228 units on approximately 9.7 acres of the 33.2-acre site, with the remaining 23.5 acres preserved (refer to Figure 4-3). Because development of this alternative would include construction of the same site, construction -related impacts would be similar to the proposed project and, like the proposed project, would require similar mitigation for impacts to air quality, biologic al resources, cultural resources and tribal cultural resources. While this alternative would provide for a larger biological preserva tion area of the site (approximately 23. 11 acres in comparison to the proposed project’s 17.89 -acres of preserved area) , reduced edge e ffects, and would reduce impacts to San Diego button celery and vernal pool s in comparison to the project; this alternative would result in substantially more impacts to thread -leaved brodiaea (approximately 72,158 plants). As described above, this alternative would avoid vernal pools occupied by listed branchiopods (fairy shrimp) across the site in comparison to the project and achieve a 30% maximum building footprint at the site.
While this alternative would develop infill housing on an urbanized site and rezone the site to residential to assist the City to implement its housing goals (project objectives 1 and 2), it would implement less housing compared to the proposed project and less efficiently promote infill development. This alternative would also provide less varied housing types compared to the proposed project and would not include any affordable/low-income housing units (objective 3). This alternative would meet objective 4 by avoiding vernal pools but would result in greater impacts to thread-leaved brodiaea that would be inconsistent with objective 4. This alternative would meet project objective 5 because the site would be designed in a manner that enhance s connectivity. This alternative would not meet objective 6 to the same extent as the project, as it would not maximize housing density for the City.
4.4.7 Reduced Pacific Specific Plan Project Alternative In response to comments received from USFW S and CDFW on the Draft EIR, this Reduced Pacific Specific Plan Project Alternative (also referred to as “reduced project alternative” herein) considers a variation on the proposed project layout. The Reduced Pacific Specific Plan Project Alternative consists of 299 residential units, including a mix of rowhomes, villas, and affordable units on approximately 13.3 acres of the 33.2-acre project site. This reduced project alternative includes a total of 646 parking spaces and 111,025 square feet of common open space area. 45 of the 299 total units (15% of the total) would be designated as deed -restricted affordable units (the reduced project alternative reserves the option to contribute to the affordable housing fund by paying the in -lieu fee). This reduced project alternative also includes landscaping, bio -retention areas, and circulation improvements. The remaining approximately 19.9 acres of the 33.2-acre project site would be preserved and restored as open space and habitat area. Th is reduced project alternative would have a density of approximately 8.99 dwelling units per acre, including the open space and habitat area (please refer to Figure 4-4 and Figure 4-5 of the Final EIR). 4 - ALTERNATIVES
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Similar to the proposed project, this alternative would require a General Plan Amendment, Rezone, Specific Plan, Tentative Map, and Multi-Family Site Development Plan. The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Industrial (I) to Specific Plan Area (SPA).
Comparison of the Effects of the Reduced Pacific Specific Plan Project Alternative to the Proposed Project
Aesthetics
The Reduced Pacific Specific Plan Project Alternative would reduce the scope of the proposed project development footprint to 13.3 acres (from 15.09) and reduce the housing unit count to 299 units (from 449). This alternative layout would mirror the proposed project with the exception of the northeastern portion of the development (apartment units), which would be removed under this alternative (see Figure 4-4). Similar to the proposed project, this alternative would result in less-than-significant impacts related to aesthetics. The visual character of the site would change from vacant to residential in an urbanized and developed area. Compared to the proposed project, th is alternative would slightly reduce development on-site. New sources of lighting would be introduced, but, similar to the project, would be required to comply with the City’s Light and Glare Standards. Therefore, aesthetic impacts under this alternative would be comparable to the proposed project.
Air Quality
The Reduced Pacific Specific Plan Project Alternative would reduce the number of units compared to the proposed project by 150 units (from 449 to 299). As the project site is zoned industrial, the alternative would still need a GPA/Rezone to a SPA. However, this proposed alternative would still be within the SANDAG growth projections for the City and therefore would not conflict with the RAQS or SIP. As this proposed alternative would have fewer units than the proposed project, emissions during construction would be similar to or less than that of the proposed project. During operation, this proposed alternative would result in fewer emissions compared to the proposed project due to the reduction in units and vehicle trips. This proposed alternative would have similar to or less impacts to sensitive receptors compared to the proposed project due to the reduction in development area. This proposed alternative would not result in odors during construction or operation that adversely affect a substantial number of people. Daily construction emissions of the proposed project or reduced project alternative would not exceed the significance thresholds for VOC, NO x, CO, SO x, PM10, or PM 2.5. The reduced project alternative would result in fewer emissions during construction compared to the proposed project. Therefore, the potential for the reduced project alternative to result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable national or California ambient air quality standard, and health effects of criteria air pollutants would be reduced to a less than significant impact with mitigation measure MM-AQ-1 incorporated. This alternative would require mitigation similar to that proposed for the project. Overall, impacts of this proposed alternative would have similar to or reduced impacts to air quality compared to the proposed project. Please refer to Appendix B-2.
Biological Resources
In response to comments received from USFWS on the Draft EIR, this Reduced Pacific Specific Plan Project Alternative considers a variation on the proposed project. A biological memorandum was prepared to analyze this additional alternative, and is included as Appendix C-2 to the Final EIR. As outlined in this memorandum, both the proposed project and this alternative would result in impacts to vegetation including Diegan coastal sage scrub, grassland, and vernal pool vegetation. Because of the reduced development footprint under this alternative, 4 - ALTERNATIVES
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biological resource impacts to the 33.2 -acre project site would be r educed by approximately 1.81 acres in comparison to the proposed project.
Both the proposed project and this alternative would impact vernal pools and other features known to be occupied by the federally listed endangered San Diego fairy shrimp; however, implementation of this alternative would impact slightly less resources (vernal pools and San Diego fai ry shrimp) in comparison to the proposed project. Both the proposed project and this alternative would result in similar impacts to the federally lis ted threatened and state listed endangered thread-leaved brodiaea and the feder ally listed endangered and state listed endangered San Diego button celery. Please refer to Table 4-3.
Under this alternative, as a result of the reduced development footprint, potential edge effects would be reduced in comparison to the project. Nonetheless, this alternative would still be required to incorporate mitigation measures MM-BIO-1a through MM-BIO-8b as identified for the proposed project, in order to reduce impacts to a less than significant level. Mitigation measures identified for the proposed project would adequately reduce impacts under this alternative. Therefore, compared to the proposed project, this alternative would result in a similar determination of less than significant with mitigation incorporated. Overall, impacts to biological resources would be slightly reduced as compared to the proposed project.
Cultural Resources
The cultural resources inventory for the proposed project did not identify any cultural resources within the project site, thus, no cultural resources were identified under this Reduced Pacific Specific Plan Alternative APE. Neither the proposed project nor this alternative pose the potential to impact known cultural resources. However, following Native American consultation pursuant to Assembly Bill 52 and Senate Bill 18, the City is including mitigation measures with consulting tribes to assure identification and appropriate handling of potentially buried Tribal Cultural Resources (TCR) within the original project site. As th is alternative proposes less land development in comparison to the proposed project, this alternative has a reduced potential of impacting TCRs that may be buried within the APE. Mitigation measures TCR-1 to TCR-4 developed for the proposed project would be sufficient for this alternative to similarly reduce impacts to less than significant. Please refer to Appendix D-2.
Energy
Under this alternative, development would result in construction and operational energy use. Energy use during construction would primarily be associated with construction equipment, as -necessary lighting, and electronic equipment, such as computers inside temporary construction trailers and HVAC, similar to the proposed project.
Natural gas is not anticipated to be used during construction, similar to the proposed project, and would be temporary and negligible if used. Petroleum would be used throughout construction of the alternative and would be similar to the proposed project. Ultimately, like the proposed project, the petroleum consumed related to construction would be typical of construction projects of similar types and sizes and would not be wasteful or inefficient. The footprint for this alternative would be slightly reduced compared to the proposed project by removing the apartment unit component and would be more efficient due to construction of less units.
The operation of this alternative would also require electricity for multiple purposes, similar to the proposed project.
This alternative demand for energy use is expected to be slightly less than that required to serve the proposed project due to the reduction in development proposed . Similar to the proposed project, this alternative would be required to comply with building requirements (including Title 24 standards) designed to ensure efficient energy use, reduce energy demand, and comply with state and local renewable energy and energy efficiency requirements. 4 - ALTERNATIVES
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Like the proposed project, the operation of residential units would require natural gas for space heating and to power appliances, but compliance with Title 24 would ensure its efficient use. Petroleum use during operation would be slightly reduced compare d to the proposed project as fewer residents would operate fewer vehicles.
However, ultimately this alternative may increase petroleum inefficiencies compared to the project by reducing residential units to be developed at this VMT-efficient urbanized infill location proximate to commercial uses, transit, and other infrastructure. As such, demand for energy is determined to be comparable to the proposed project under this alternative. Therefore similar, less-than-significant impacts to energy would occur under this alternative.
Geology and Soils
Under this alternative, ground-disturbance areas would be slightly reduced in comparison to the proposed project by removing the apartment unit component. However, development under this alternative would be subject to the same potential seismic hazards, such as seismic ground shaking. This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation for the proposed project.
Similar to the proposed project, due to the high potential for paleontological resources on-site, mitigation measure MM-GEO-1 as proposed for the project would be required under this alternative. Compared to the proposed project, this alternative would result in similar impacts relative to geology and soils. Please refer to Appendix F-2.
Greenhouse Gas Emissions
Where a project is not consistent with the existing General Plan land use designation (as is the case with this alternative and the proposed project), the CAP Checklist asks whether the project would generate GHG emissions equal to or less than estimated GHG emissions generated under the existing land use designation for the site (the current land use designation for the site is Industrial (I)). Estimated total GHG emissions generated during operation, including amortized construction emissions, for this alternative would be below emissions anticipated to be generated under the existing Industrial land use designation for the site. The Reduced Pacific Specific Plan Alternative would be consistent with the City’s CAP. Furthermore, th is reduced project alternative would result in fewer GHGs compared to the proposed project. This reduced project alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs because there are currently no mandatory GHG regulations or finalized agency guidelines that would apply to implementation of this project.
Therefore, the proposed alternative would have a less than significant impact relative to GHG emissions GHGs and impacts would be reduced as compared to the proposed project. Please refer to Appendix B 2.
Hazards and Hazardous Materials
Similar to the proposed project, there is the potential for this alternative to generate hazardous materials during construction; however, existing federal and state standards are in place for the handling, storage and transport of these materials. Although this alternative would substantially reduce the number of units on-site in comparison to the project from 449 units to 299 units, this alternative still proposes residential development that would result in similar use of hazardous materials on site, such as household products, that would be utilized under the proposed project. Therefore, compared to the proposed project, this alternative would result in similar less than significant impacts related to hazards and hazardous materials.
Hydrology and Water Quality
The Reduced Pacific Specific Plan Project Alternative development would be the same as the proposed project with the exception of the apartment unit component which would be removed from the northeastern portion of the site 4 - ALTERNATIVES
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plan (see Figure 4-4). This alternative would result in slightly reduced ground disturbance as a result of the reduced building footprint compared to the proposed project. Due to the reduced footprint under this alternative, less impervious surfaces would be introduced to the site compared to the proposed project. Development of both the proposed project and this alternative would alter the existing on-site hydrologic conditions, drainage patterns, and drainage volumes in comparison to existing vacant conditions. It is expected that this alternative, like the proposed project, would also incorporate all require d and applicable best management practices to avoid any violations of water quality standards, or otherwise modify or adversely affect surface and groundwater quality or increase runoff rate or volume from the site. Therefore, as compared to the proposed project, this alternative would result in similar, less-than-significant impacts to hydrology and water quality. Please refer to Appendix E-2 and G-2.
Land Use and Planning
Similar to the proposed project, t he Reduced Pacific Specific Plan Alternative would have no impact related to physically dividing an established community. Because development of this alternative would introduce housing on site, a GPA and rezone would be required, similar to the proposed project. Similar to the proposed project, this alternative would introduce population growth in an area of the City that has not been accounted for in the City’s General Plan. This alternative would not create a significant impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, because this alternative would also require a GPA/Rezone but would not conflict with applicable plans, policies, and regulations, impacts relative to land use and planning under this alternative would be less than significant, similar to that of the proposed project.
Noise
The Reduced Pacific Specific Plan Alternative would eliminate the apartment units previously proposed in the northeastern portion of the site, reducing the overall residential unit count from 449 to 299 units. This reduction in the development footprint and scale of construction would likewise proportionally reduce demolition, grading, and building construction noise generated on-site. The technical analysis of the proposed 449-unit project concluded construction noise impacts would be less than significant with construction occurring during allowable daytime hours.
The revised 299-unit project confined to the remaining portions of the site would likewise be anticipated to generate construction noise within acceptable levels. Construction noise impacts would be reduced compared to the proposed project and remain less than significant without need for additional mitigation.
The reduction in project units from 449 to 299 would proportionally decrease the amount of traffic added to nearby roadways. With 150 fewer units, the project vehicle trip generation would be reduced by approximately 33% (assuming consistent trip generation rates per unit). Traffic noise levels increase logarithmically in relation to the actual traffic volume. Therefore, a 33% reduction in project traffic volumes would correspond to approximately a 1 dB decrease in traffic noise levels generated by the project. The traffic noise analysis for the 449 -unit project did not identify any significant impacts at sensitive receptors. The incremental 1 dB reduction in traffic noise for the smaller 299-unit project reaffirms that this impact would remain less than significant and marginally improved compared to the prior project site plan. With fewer residential units proposed, stationary noise sources associated with building operations, such as HVAC systems, would likewise be reduced compared to the proposed project. Stationary noise impacts associated with the 449-unit project were found to be less than significant. This alternative 299-unit project would further reduce stationary noise levels and this impact would remain less than significant.
The overall reduction in project scale and concentration of construction activities within the remaining project site would result in similar vibration levels compared to the proposed project. Construction vibration impacts associated 4 - ALTERNATIVES
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with the 449 -unit project were found to be less than significant at nearby sensitive receptors. Th is 299-unit alternative would generate similar vibration levels that would remain below thresholds for human annoyance and building damage. Vibration impacts would be similar to the proposed project and less than significant without mitigation needed. Overall, this alternative would result in reduced noise and vibration impacts compared to the proposed project; however, impacts would remain less than significant, similar to the proposed project. Please refer to Appendix I-2.
Population and Housing
The Reduced Pacific Specific Plan Alternative would similarly introduce unplanned population growth in the area with the development of 299 housing units on the currently vacant site. The proposed project seeks to change the land use designation of the project site to allow for development of residential land uses that have not been accounted for in the City’s General Plan. Development of thi s alternative would also require a GPA/Rezone.
However, similar to the project, the new homes under this alternative would not be considered to substantially induce unplanned population growth as the project site is an infill site surrounding by existing r oadways, utilities and development. Like the proposed project, this alternative would have no impact related to displacing substantial numbers of people or housing. Therefore, impacts related to population and housing for this alternative would be similar to the proposed project’s less-than-significant impact.
Public Services
Similar to the proposed project, this alternative would result in an increase in demand for public services due to the development of a currently vacant site. However, due to the reduced number of housing units under this alternative in comparison to the proposed project, this alternative would be anticipated to result in less of a demand on public services. Therefore, impacts to public services under this alternative would be slightly reduced compared to the proposed project, but remain less than significant.
Recreation
Similar to the proposed project, this alternative would result in an increased demand on existing park and recreational facilities within the City with the introduction of 2 99 housing units. However, similar to the proposed project, this alternative would be required to incorporate open space on site and would be required to pay into applicable developer and park impact fees. Therefore, impacts related to recreation for this al ternative would be similar to the proposed project’s less-than-significant impact.
Transportation
The Reduced Pacific Specific Plan Alternative would be served by similar vehicle traffic during construction compared to the proposed project, though construction traffic access may be slightly altered due to the modified (reduced) footprint. Construction traffic impacts would be less than significant, as with the proposed project.
Operation of this alternative would not result in any new substantial project effects beyond those identified for the proposed project. Site access for this alternative would be the same as that proposed under the project. Although traffic may be slightly reduced under this alternative as a result in the unit reduction from 449 to 299, traffic impact determinations would be similar to that of the proposed project. VMT for this alternative is likely to be similar in comparison to the proposed project. Compared to the proposed project, this alternative would result in similar, less- than-significant impacts related to transportation. Please refer to Appendix K-2. 4 - ALTERNATIVES
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Tribal Cultural Resources
The cultural resources inventory for the proposed project did not identify any cultural resources within the project site; thus, no cultural resources were identified under this Reduced Pacific Specific Plan Alternative. Neither the proposed project nor this alternative pose the potential to impact known cultural resources. However, following Native American consultation pursuant to Assembly Bill 52 and Senate Bill 18, the City is including mitigation measures to assure identification and appropriate handling of potentially buried Tribal Cultural Resources (TCR) within the original project site. As this alternative proposes a reduced development footprint in comparison to the proposed project, this alternative has a reduced potential of impacting unknown TCRs that may be buried within the APE. to reduce impacts to less than significant. The City’s cultural mitigation measures proposed for the project (MM-TCR-1 to MM-TCR-4) would still apply under this alternative and would be sufficient to reduce potential impacts to less than significant. .
Thus, with the implementation of mitigation, impacts to tribal cultural resources would be sightly reduced as compared to the proposed project.
Utilities and Service Systems
Under this Reduced Pacific Specific Plan Alternative, the fire flow requirements would not substantially change from the proposed project. This alternative would not be expected to create any sewer deficiencies that that analyzed for the proposed project. Compared to the proposed project, this alternative would result in similar, less-than-significant impacts related to utilities and service systems.
Wildfire
As discussed in Sections 3.18 and 3.19 of this EIR, and in the Fire Protection Plan (Appendix N to this EIR), impacts related to wildfire were determined to be less-than-significant under the proposed project. The site is located in an urbanized, infill area and is not located in any fire hazard severity zones or near any local responsibility areas, state responsibility areas, or near lands classified as very high fire hazards severity zones. Like the proposed project, this alternative development of 299 residential units would be required to comply with all applicable state and local fire codes. This alternative would therefore not exacerbate wildfire risk nor expose occupants to hazards or other significant risks of loss, injury, or death concerning wildland fires. Impacts related to wildfire under this alternative are expected to be less than significant, similar to the proposed project.
Summary and Relation to Project Objectives
The Reduced Pacific Specific Plan Project Alternative would include development of 2 99 units on approximately
13.3 acres of the 33.2 -acre site, with the remaining 19.9 acres preserved (refer to Figure 4 -4). Because development of this alternative would include construction of the same site, construction -related impacts would be similar to the proposed project and, like the proposed project, would require the same mitigation for impacts to air quality, biological resources, cultural resources and tribal cult ural resources. The development footprint under this alternative ( 13.3 acres) would be less than that analyzed for the proposed project (15. 09 acres). This alternative 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. Furthermore, this alternative would provide for a larger biological preservation area of the site (approximately 1.81 acres more than the proposed project).
While this alternative would develop infill housing on an urbanized site and rezone the site to residential to assist the City to implement its housing goals (project objectives 1 and 2), it would implement less housing compared to 4 - ALTERNATIVES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 4-33
the proposed project and less efficiently promote infill development. This alternative would also provide less varied housing compared to the proposed project (objective 3). This alternative would meet objective 4 similar to the project. This alternative would meet project objective 5 because the site would be designed in a manner that enhances connectivity. However, this alternative would not meet objective 6 to the same extent as the project, as it would not maximize housing density for the City.
The Reduced Pacific Specific Plan Project would meet project objectives to a lesser extent compared to the proposed project, as it would implement less housing, less dense housing, and less varied housing compared to the proposed project. Off-site improvements under this alternative would be similar to the proposed project.
4.5 Environmentally Superior Alternative
Table 4-1 provides a qualitative comparison of the impacts for each Alternative compared to the proposed project.
As shown in Table 4 -1, the No Project Alternative would eliminate all of the significant impacts identified for the project. However, the No Project Alternative would not meet any of the project objectives.
CEQA Guidelines Section 15126.6(e)(2) states that if the No Project alternative is identified as the environmentally superior alternative, then an environmentally superior alternative should be identified among the other alternatives.
Please refer to Table 4 -2 below, which shows a comparison of proposed alternative components , and Table 4 -3 which provides a comparison of biological resource impacts. Additionally, please refer to Figure 4-5 of the Final EIR which depicts a comparison of the proposed project development area versus the development areas of the proposed alternatives.
Of the alternatives identified to reduce potential environmental impacts compared to the proposed project, the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization would be considered the environmentally superior alternative to the p roposed project. This alternative would meet most of the project objectives and reduce the severity of impacts related to air quality, biological resources, cultural resources, greenhouse gas emissions, and tribal cultural resources in comparison to the proposed project due to the reduced unit count and reduced development footprint. However, such impacts under this alternative would still remain as less than significant with mitigation incorporated, similar to the proposed project. Additionally, while this alternative would develop infill housing on an urbanized site and rezone the site to residential to assist the City to implement its housing goals (project objectives 1 and 2), it would implement less housing compared to the proposed project and less efficiently promote infill development. This alternative would also provide less varied housing compared to the proposed project and would not include any affordable/low -income housing units. In comparison to the proposed project, this Reduced Development Footprint Alternative – Vernal Pool Impact Minimization alternative would cluster development along and within the southern boundary of the site, which would consolidate development potentially reducing the development interfaces/edges to adjacent preservation areas on-site.
The Reduced Development Footprint Alternative – Vernal Pool Impact Minimization would result in approximately 16% less (5.22 acres less) development impact area to the total 33.2 -acre project site in comparison to the proposed project. As outlined in Section 4.4.6 above, when comparing impacts to biological resources, the proposed project and tThe Reduced Development Footprint Alternative – Vernal Pool Impact Minimization alternative would both impact native vegetation, vernal pools, and listed special-status plant species. However, the proposed project would also impact a listed special-status animal (federally listed endangered San Diego fairy shrimp) whereas this alternative would have no impacts to listed special -status animals. Additionally, this alternative would avoid all features occupied by San Diego fairy shrimp.
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 4-34
Although this alternative would impact a substantially larger amount of thread -leaved brodiaea in comparison to the project; the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization has been determined the environmentally superior alternative due to the reduction in impacts to vernal pools, and increase in preserve area in comparison to the proposed project. Furthermore, this alternative supports the City’s goal of being responsive to the Trustee Agencies’ comments provided on the Draft EIR.
The Reduced Development Footprint would meet most of the project objectives while reducing the severity of impacts related to air quality, biological resources, cultural resources, and tribal cultural resources in comparison to the proposed project due to the reduced unit count and reduced development footprint . While the Reduced Development Footprint Alternative may result in greater impacts to thread -leaved brodiaea, requiring potentially greater off-site mitigation, on the whole it would reduce impacts associated with the proposed project and therefore, among the feasible alternatives identified herein, it is considered to be environmentally superior.
Table 4-1. Comparison of Impacts of Proposed Project and Alternatives Environmental
Topic
Proposed
Project
No Project
Alternative
Existing
Land Use
Designation
Alternative
Reduced
Development
Footprint
Alternative
Reduced
Development
Footprint
Alternative –
Vernal Pool
Impact
Minimization
Reduced
Pacific
Specific
Plan Project
Alternative
Aesthetics LTS No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Same) LTS (Same)
Air Quality LTSM No Impact
(Reduced)
LTSM (Same
or Greater)
LTSM
(Reduced)
LTSM
(Reduced)
LTSM
(Reduced)
Biological
Resources
LTSM No Impact
(Reduced)
LTSM (Same) LTSM
(Reduced)
LTSM
(Reduced)
LTSM
(Reduced)
Cultural
Resources
LTSM No Impact
(Reduced)
LTSM (Same) LTSM
(Reduced)
LTSM
(Reduced)
LTSM
(Reduced)
Geology and Soils LTS No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Same) LTS (Same)
Greenhouse Gas
Emissions
LTS No Impact
(Reduced)
LTS (Same or
Greater)
LTS (Same) LTS (Reduced) LTS
(Reduced)
Hazards and
Hazardous
Materials
LTS No Impact
(Reduced)
LTS (Same or
Greater)
LTS (Same) LTS (Same) LTS (Same)
Hydrology and
Water Quality
LTS No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Same) LTS (Same)
Land Use LTS No Impact
(Reduced)
LTS
(Reduced)
LTS (Same) LTS (Same) LTS (Same)
Noise LTS No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Reduced) LTS
(Reduced)
Population and
Housing
LTS No Impact
(Reduced)
No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Same)
Public Services LTS No Impact
(Reduced)
LTS (Same or
Reduced)
LTS (Same) LTS (Same) LTS (Same)
Recreation LTS No Impact
(Reduced)
No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Same)
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 4-35
Table 4-1. Comparison of Impacts of Proposed Project and Alternatives Environmental
Topic
Proposed
Project
No Project
Alternative
Existing
Land Use
Designation
Alternative
Reduced
Development
Footprint
Alternative
Reduced
Development
Footprint
Alternative –
Vernal Pool
Impact
Minimization
Reduced
Pacific
Specific
Plan Project
Alternative
Transportation LTS No Impact
(Reduced)
LTS (Same or
Greater)
LTS (Same) LTS (Same) LTS (Same)
Tribal Cultural
Resources
LTSM No Impact
(Reduced)
LTSM (Same) LTSM
(Reduced)
LTSM
(Reduced)
LTSM
(Reduced)
Utilities and
Service Systems
LTS No Impact
(Reduced)
LTS (Same) LTS (Same) LTS (Same) LTS (Same)
Wildfire LTS No Impact
(Reduced)
LTS (Same or
Greater)
LTS (Same) LTS (Same) LTS (Same)
Notes: Impact Status: LTS = Less than Significant Impact; LTSM = Less than Significant with Mitigation.
Table 4-2. Comparison of Components of Proposed Project and Alternatives Components
Proposed
Project
No Project
Alternative
Existing
Land Use
Designation
Alternative
Reduced
Development
Footprint
Alternative
Reduced
Development
Footprint
Alternative –
Vernal Pool
Impact
Minimization
Reduced
Pacific
Specific
Plan Project
Alternative
Units 449 — — 321 228 299
Density 13.5
dwelling
units per
acre
— — 9.4 dwelling
units per acre
6.86 dwelling
units per acre
8.99 dwelling
units per
acre
Development
Footprint Area
15.09 acres — 15.28
(480,000 sf
of research
and
development
area with a
220,000-sf
four-story
parking
structure)
8.3 acres 9.7 acres 13.3 acres
Housing Types Apartments,
rowhomes,
villas, and
affordable
flats
— — Rowhomes
and
apartments
Rowhomes
and villas
Rowhomes,
villas,
affordable
flats
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 4-36
Table 4-2. Comparison of Components of Proposed Project and Alternatives Components
Proposed
Project
No Project
Alternative
Existing
Land Use
Designation
Alternative
Reduced
Development
Footprint
Alternative
Reduced
Development
Footprint
Alternative –
Vernal Pool
Impact
Minimization
Reduced
Pacific
Specific
Plan Project
Alternative
Usable Open
Space (private
and common)
134,985 sf — — 58,000 sf 111,341 sf 115,165 sf
Preserved
Open Space
17.94 acres — 17.94 acres 24.7 acres 23.5 acres 19.9 acres Note: The development footprint area acreages reflected in this table may slightly vary from the acreage call outs throughout Section
4.4 above, as the acreages identified in Appendix C-1 and Appendix C-2 of this EIR include on-site and off-site impacts by development as well as roadway dedications and improvements ; whereas the development footprint area acreages shown in this Table 4.2 are based on the conceptual site plans shown in Figures 4-1 through 4-4 of this EIR. These slight acreage discrepancies do not impact the alternative analysis conclusions.
Table 4-3. Comparison of Biological Resource Impacts by Project Alternative Identified
Biological
Resource
Impacts Sensitive Natural Community Special -Status Plants Special -
Status
Animals
Project
Alternative
Vernal
Pools Grassland
Diegan
Coastal
Sage
Scrub
Thread -
leaved
Brodiaea
Orcutt’s
Brodiaea
San Diego
Button
Celery
San Diego
Fairy
Shrimp
Proposed
Project (449
units)
0.15-
acre
14.35 acres
1.09 acres 33,879
plants
80,655plants 103 plants 8 features
No Project
Alternative
— — — — — — —
Existing Land
Use
Designation
Alternative
0.15-
acre
14.35 acres
1.09 acres 33,879
plants
80,655
plants
103 plants 8 features
Reduced
Development
Footprint
Alternative
(321 units)
0.03-
acre
10.39 acres
0.14-acre 95,509
plants
46,032
plants
0 plants 0 features
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 4-37
Table 4-3. Comparison of Biological Resource Impacts by Project Alternative Identified
Biological
Resource
Impacts Sensitive Natural Community Special -Status Plants Special -
Status
Animals
Project
Alternative
Vernal
Pools Grassland
Diegan
Coastal
Sage
Scrub
Thread -
leaved
Brodiaea
Orcutt’s
Brodiaea
San Diego
Button
Celery
San Diego
Fairy
Shrimp
Reduced
Development
Footprint
Alternative –
Vernal Pool
Impact
Minimization
(228 units)
0.03-
acre
10.30 acres
0.04-acre 106,037
plants
44,283
plants
0 plants 0 features
Reduced
Pacific
Specific Plan
Project
Alternative
(299 units)
0.14-
acre
12.87 acres
0.78-acre 33,879
plants
78,984
plants
103 plants 6 features
Notes
1 Quantities reflect additional biological surveys performed in response to draft EIR comments and since preparation of the draft EIR. 2 Quantities represent on-site and off-site impacts by proposed development as well as roadway dedications and improvements.
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60,000 SF
3-STORY
170,000 SF
3-STORY
250,000 SF
3-STORY
PARKING STRUCTURE 4-STORY
220,000 SF
INDUSTRIAL SUMMARY
GROSS SITE AREA 33.229 ACRES
BIO PRESERVATION 17.943 ACRES
STREET DEDICATION 0.195 ACRES
DEVELOPMENT AREA 15.091 ACRES
BUILDING AREA
R&D BUILDINGS 480,000 SF
PARKING GARAGE 220,000 SF
TOTAL BUILDING AREA 700,000 SF
FAR .48
PARKING 1,440 SPACES
(3/1,000 AVG.)
DEVELOPMENT STANDARDS
ZONING INDUSTRIAL (I)
BUILDING HEIGHT 45 FT
SETBACKS
BUILDINGS 10 FT
GENERAL PARKING 10 FT
TRUCK/BUS PARKING 30 FT
LOADING DRS/DOCKS 20 FT
Existing Land Use Designation Alternative
Pacific Project EIR
FIGURE 4-1
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR
SOURCE: Summa Architecture, 2022
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24.0 LEASING
REC
N
0 60 120 180
APARTMENTS
150 1B/1BA 740 SF
125 2BD/2.5BA 1,256 SF
25 3BD/2.5BA 1,579 SF
300 8.2 AC = 36 DU/AC
PARKING SUMMARY
1BD 150 X 1.5 = 225 SPACES
2&3BD 150 X 2 = 300 SPACES
GUEST 300 X .33 = 99 SPACES
TOTAL 624 SPACES
PROVIDED COVERED (1:1) 300 GARAGES
PROVIDED OPEN 360 OPEN
TOTAL PROVIDED 660 SPACES
PRIVATE OPEN SPACE REQUIRED PROVIDED
300 X 50 SF 15,000 SF 15,000 SF
COMMON OPEN SPACE REQUIRED PROVIDED
GROUND FLOOR SF X 30% 48,600 SF
TOT LOT (1:25 DU) 12X400 SF 4,800 SF
PLAYGROUND 800 SF
TOTAL 54,200 SF 55,000 SF
SCALE:
ROWHOMES
2 2BD/2BA 1,200 SF
2 3BD/3BA 1,310 SF
7 3BD/3.5BA 1,736 SF
10 4BD/3.5BA 1,890 SF
21 1.2 AC = 17.5 DU/AC
PARKING SUMMARY
21 X 2.33 = 49 SPACES
REQUIRED COVERED (1:1) 21 (PROVIDED 42 GARAGES)
TOTAL PROVIDED 50 SPACES (INCL 8 OPEN)
PRIVATE OPEN SPACE REQUIRED PROVIDED
21 X 50 SF 1,050 SF 1,200 SF
COMMON OPEN SPACE REQUIRED PROVIDED
GROUND FLOOR SF X 30% 2,338 SF
TOT LOT (1:25 DU) 1X400 SF 400 SF
TOTAL 2,738 SF 3,000 SF
PROJECT SUMMARY
RESIDENCES 321 HOMES
GROSS SITE AREA 33 ACRES (8.3 ACRES NET)
GROSS DENSITY 9.4 DU/AC (32.3 DU/AC NET)
Reduced Development Footprint Alternative
Pacific Project EIR
FIGURE 4-2
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SOURCE: Summa Architecture, 2022
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Reduced Development Footprint Alternative - Vernal Pool Impact Minimization Pacific Project EIR
FIGURE 4-3
SOURC
E: Summ
a Architecture,
2024
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Reduced Pacific Specific Plan Project Alternative
Pacific Project EIR
FIGURE 4-4
SOURC
E: Summ
a Architecture,
2024
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LINDA VISTA DR
RYAN DR
S PACIFIC ST
PRIVATE RD
S LAS POSAS RD
LINDA VISTA DR
LA MIRADA DR
Project Site Plan and Alternative Comparison
Pacific Project EIR
SOURCE: Summa Architecture 2023; SANGIS 2023
Date: 1/10/2024 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\FigureX-ProjectSitePlanAlternative sComparison.mxd 0 300 150
Feet
Project Boundary
Proposed Project - 449 units
Reduced Development Footprint Alternative - 321 units
Reduced Development Footprint - Vernal Pool Impact Minimization - 228 units Reduced Pacific Specific Plan Project Alternative - 299 units FIGURE 4-5
Grand Plaza
Shopping Mall
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 5-1
5 Environmental Effects Found Not to
Be Significant
As required by Section 15128 of the California Environmental Quality Act Guidelines, the following is a discussion of the environmental effects that were considered as part of this environmental impact report ( EIR) but were determined to have “No Impact” and, therefore, are not discussed in detail in Chapter 3, Environmental Analysis, of this EIR. Agriculture/Forestry Resource s and Mineral Resources were the only environmental issue areas eliminated from Chapter 3 and are briefly discussed below.
As discussed in Chapter 2 , Project Description , of this EIR, the project proposes development of 449 residential units, including a mix of apartments, rowhomes, villas, and affordable flats on approximately 15.28 acres within the approximately 33-acre project site. The project proposes a General Plan Amendment and Rezone from Industrial (I) to Specific Plan Area (SPA).
5.1 Agriculture and Forestry Resources
The project site is designated as Urban and Built -Up Land by the California Department of Conservation Farmland Mapping and Monitoring Program (CDC 2021). As a result, the proposed project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses.
Furthermore, the project site is not zoned for agricultural use or designated as land under the Williamson Act, nor is the project site zoned for forest land or timberland production (CDC 2014). Therefore, implementation of the proposed project would not result in the loss or conversion of forest land. No impact would occur regarding conflicts with existing zoning for agricultural use or forest land.
Designated farmland does not exist within the vicinity of the project site. The proposed project would not result in substantial changes that could result in the conversion of farmland to non -agricultural use. The proposed project site is surrounded entirely by developed land, except for one vacant lot adjacent to the southern portion of the site.
This vacant lot is designated Light Industrial by the City of San Marcos. Other existing development adjacent to the project site include Light Industrial, Parks, Mixed Use, and Commercial uses (City of San Marcos 2021). Given the extent of development surrounding the proposed project site, the proposed project would not result in the conversion of any existing farmland, and no impact would occur.
5.2 Mineral Resources
According to the City’s General Plan – Conservation and Open Space Element, the City has land classified in all four Mineral Resource Zones (MRZ) (City of San Marcos 2012). The different MRZs are defined as follows:
▪ MRZ-1: Areas where adequate information indicates that no significant mineral deposits are present or where it is judged that little likelihood exists for their presence. ▪ MRZ-2: Areas where adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists. ▪ MRZ-3: Areas containing mineral deposits the significance of which cannot be evaluated from available data. ▪ MRZ-4: Areas where available information is inadequate for assignment to any other MRZ zone. 5 - ENVIRONMENTAL EFFECTS FOUND NOT TO BE SIGNIFICANT
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 5-2
California does not require that local governments protect land designated as MRZ-1, MRZ-3, or MRZ-4. However, the City is responsible for recognizing lands designated as MRZ -2 and protecting these areas from premature development incompatible with mining. City lands designated as MRZ -2 include small portions between Double Peak, Mt. Whitney, and Franks Peak, and small portions in the northern Sphere of Influence within Twin Oaks Valley Neighborhood (City of San Marcos 2012). These locations do not overlap with the proposed project site; therefore, no loss of known mineral resources would occur.
Furthermore, the project site is not designated as a locally important mineral resource recovery site on any local General Plan, Specific Plan, or other land use plan (City of San Marcos 2012). Thus, due to the location and nature of the proposed project, there would be no impact to mineral resources.
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 6-1
6 Other CEQA Considerations
6.1 Significant Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines, Section 15126.2(b), requires that an environmental impact report (EIR) describe any significant impacts that cannot be avoided, including those impacts that can be mitigated but not reduced to a less -than-significant level. Chapter 3, Environmental Analysis, of this EIR describes the potential environmental impacts of the Pacific Specific Plan Project (proposed project) and recommends mitigation measures to reduce impacts, where feasible.
As discussed in this EIR, implementation of the proposed project would not result in any significant and unavoidable impacts . All potentially significant impacts would be reduced to a less -than-significant level with mitigation incorporated.
6.2 Growth Inducement
Section 15126.2(d) of the CEQA Guidelines mandates that the growth -inducing nature of a proposed project be discussed. This CEQA Guideline states the growth -inducing analysis is intended to address the potential for the proposed project to “foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) also mandates that a CEQA document speak to the proposed proje ct’s likelihood to induce substantial population growth in an area, either directly (e.g., by proposing new homes or businesses) or indirectly (e.g., through extension of roads or other infrastructure).
A project may be distinguished as either facilitating planned growth or inducing unplanned growth. Facilitating growth is related to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing growth is related to lowering or removing barriers to growth or by creating an amenity or facility that attracts new population/econo mic activity. For purposes of this EIR analysis, a significant growth inducement impact would occur if the proposed project, an d associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burden existing community services, the environment, or cause a demand for General Plan Amendments. This section contains a discussion of the growth - inducing factors related to the proposed project and as defined under CEQA Guidelines, Section 15126.2(d). A project is defined as growth inducing when it directly or indirectly:
1. Fosters population growth
2. Includes the construction of additional housing in the surrounding environment
3. Removes obstacles to population growth
4. Taxes existing community service facilities, requiring construction of new facilities that could cause significant environmental effects
5. Encourages or facilitates other activities that could significantly affect the environments, either individually or cumulatively
It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
6 - OTHER CEQA CONSIDERATIONS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 6-2
The project consists of 449 residential units, including a mix of apartments, rowhomes, villas, and affordable flats on approximately 15.09 acres within the 33-acre project site. The project would also include a total of 927 parking spaces, and 134,985 square f eet of private common open space area. The proposed project also includes landscaping, bio-retention areas, and circulation improvements. The remaining 17.94 acres of the 33.2-acre project site would be preserved and restored open space and habitat area. The proposed project wou ld have a density of approximately 29.8 dwelling units per acre, not including the proposed open space and habitat area. With the open space area included, the density of the proposed project would be approximately 13.5 dwelling units per acre.
The project proposes a General Plan Amendment, Rezone, Specific Plan, Tentative Map, and Multi family Site Development Plan. The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Industrial (I) to Specific Plan Area (SPA). The Specific Plan has been prepared with the intent to provide a comprehensive plan to ensure the efficient development of a new residential community. The Specific Plan serves as both a policy document and a regulatory document for the systematic implementation of the policies and goals of the General Plan (the Specific Plan is included as Appendix M to this EIR). The Tentative Map presents specific lot configurations for the site. The Multifamily Site Development Plan will configure the site for multifamily dwelling units, street configuration, infrastructure, recreational open space, and private open space.
As described in Section 3.12, Population and Housing, it is anticipated that the proposed residential development at the project site could generate a population increase of up to approximately 1,388 people. Although the proposed project would accommodate some planned growth within the City of San Marcos (City), and not all potential future residents of the project are expected to be new to the City, the project could still result in unplanned growth for the City because residential land use(s) for the project site were not accounted for in the City’s General Plan.
As described in Section 3.12 of this EIR , the City of San Marcos is forecast to grow from 98,915 persons in 2020 to 109,095 persons in 2035, which is a population increase of 10,180 (SANDAG 2013). Additionally, San Diego Association of Governments allocated 3,116 housing units to the San Marcos area for the 2021 –2029 Housing Element Cycle (SANDAG 2020). Approval of the proposed project to residential land use could help the City accommodate this substantial population growth and its need for housing. The proposed project would be subject to compliance with the City ’s General Plan Housing Element goals and policies, compliance with housing -related ordinances in the City’s Municipal Code, and applicable development fees as outlined in Section 3.12 of this EIR.
Compliance with these policies, ordinances, and fee provisions would ensure any growth at the site is adequately planned for in terms of ensuring the provision of community service facilities, including utilities, public services , recreation, emergency access, roadways, etc.
There is no hardline number or percentage available to determine whether or not th e estimated introduction of approximately 1,388 people would be considered a substantial increase in population. However, the San Diego Association of Governments 2050 Regional Growth Forecast is intended to be used as a starting point for regional planning as opposed to a prescribed growth pattern. While the City has determined that there are adequate sites available with appropriate designations/zoning to accommodate the rem aining Regional Housing Needs Assessment allocation for the current General Plan Housing Element planning period (2013 to 2021) , and has tentatively determined the same for the 2021–2029 Draft Housing Element Update (City of San Marcos 2021), the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with approved/constructed residential development. It is likely the site will act to accommodate some of the planned population growth in the City.
Potential indirect growth -inducing impacts are unlikely to result from the proposed project. No extension of infrastructure is anticipated to be needed for the proposed project, as the site is located in an urbanized, infill area. 6 - OTHER CEQA CONSIDERATIONS
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In addition, the proposed project would be required to evaluate project-specific requirements, which would ensure the development does not overtax existing infrastructure or community service facilities, consistent with the guidelines, standards, design features and mitigation measures provided in this EIR.
Therefore, while the proposed project would induce growth beyond current estimates and forecasts, it would not remove obstacles to further growth, expand infrastructure, or overtax existing community facilities. The proposed project would therefore not be considered substantially growth inducing.
6.3 Significant Irreversible Environmental Changes
CEQA Guidelines, Section 15126.2(c), requires that an EIR identify any significant irreversible environmental changes associated with the proposed project. Such changes include, for example, the intensification of land use or irreversible damage from environmental accidents associated with the proposed project.
As described above, the project consists of 449 residential units, including a mix of apartments, rowhomes, villas, and affordable flats on approximately 15.28 acres within the 33-acre project site. The remaining 17.94 acres of the 33-acre project site would be preserved and restored open space and habitat area. The proposed General Plan Amendment and Rezone would change the General Plan designation and Zoning from Industrial (I) to Specific Plan Area.
The proposed project change in land use would not be an intensification of land use over the existing industrial designation. As analyzed in Chapter 4 of this EIR, industrial development under the existing land use and zoning designation would result in additional and more severe environmental impacts in comparison to the development under the proposed project designations. Nevertheless, as analyzed throughout Chapter 3 of this EIR, the proposed project may result in significant impacts to air quality, biological resources, cultural resources, and tribal cultural resources (see Tables 1-1 and 1-2 in Chapter 1, Executive Summary, of this EIR). Although all potential impacts as a result of the proposed project would be mitigated to a less -than-significant level, such impacts would be considered irreversible.
Further, construction and/or operation of the proposed project would require the use of resources that include, but are not limited to , soils, gravel, concrete, and asphalt , lumber and other related forest products , petrochemical construction materials, steel, copper, and other metal s, water, fuels, and energy. As such, the proposed project would result in the short-term and long-term use of fossil fuels and other nonrenewable resources.
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7 References
Executive Summary
City of San Marcos. 2018. General Plan Land Use Interactive Map [database]. Accessed November 14, 2018. http://maps2.san-marcos.net/mapgallery/map.html?webmap=5b762031658c493cb7dc604654b5d9ce Chapter 2: Project Description
City of San Marcos. 2012a. City of San Marcos Public FINAL Zoning Ordinance. Adopted November 13, 2012. https://www.san-marcos.net/home/showdocument?id=11357.
City of San Marcos. 2012b. City of San Marcos General Plan, Conservation and Open Space Element. Accessed March 15, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8478.
City of San Marcos. 2018. San Marcos Municipal Code. Chapter 20.230 – Industrial Zones. Accessed March 15, 2021. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId= TIT20ZO_CH20.230INZO.
WRCC (Western Regional Climate Center). 2017. “Monthly Climate Summary San Diego Lindbergh Field, California (047740).” Accessed June 2018. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca7740.
Chapter 3: Environmental Analysis
Section 3.1: Aesthetics
Caltrans (California Department of Transportation). 2021. California State Scenic Highway System Map. Accessed April 8, 2021. https://www.arcgis.com/apps/webappviewer/index.html?id= 2e921695c43643b1aaf7000dfcc19983.
Caltrans. 2022. Scenic Highways – Frequently Asked Questions. https://dot.ca.gov/programs/ design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways/ lap-liv-i-scenic-highways-faq2.
City of San Marcos. 2012. City of San Marcos General Plan – Conservation and Open Space Element. Adopted February 14, 2012. Accessed April 9, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8478.
U.S. Census Bureau. 2019. QuickFacts – Escondido city, California. Updated July 1, 2019. Accessed April 9, 2021. https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia/PST045219. 7 - REFERENCES
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Section 3.2: Air Quality
CAPCOA (California Air Pollution Control Officers Association). 2021. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2020.4.0. Prepared by BREEZE Software, A Division of Trinity Consultants, in collaboration with South Coast Air Quality Management District and the California Air Districts. September. Accessed November 2021. http://caleemod.com/.
CARB (California Air Resources Board). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel- Fueled Engines and Vehicles. October 2000. http://www.arb.ca.gov/diesel/documents/rrpfinal.pdf.
CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. http://www.arb.ca.gov/ch/landuse.htm.
CARB. 2017. California Greenhouse Gas Inventory for 2000-2015 by Category as Defined in the 2008 Scoping Plan. https://www.arb.ca.gov/cc/inventory/data/tables/ghg_inventory_scopingplan_ sum_2000-15.pdf.
CARB. 2019a. “Glossary of Air Pollution Terms.” CARB website. Accessed June 2019. http://www.arb.ca.gov/ html/gloss.htm.
CARB. 2019b. “Ozone & Health.” Accessed May 2019. https://ww2.arb.ca.gov/resources/ozone-and-health.
CARB. 2019c. “Nitrogen Dioxide & Health.” Accessed May 2019. https://ww2.arb.ca.gov/resources/ nitrogen-dioxide-and-health.
CARB. 2019d. “Carbon Monoxide & Health.” Accessed May 2019. https://ww2.arb.ca.gov/resources/ carbon-monoxide-and-health.
CARB. 2019e. “Sulfur Dioxide & Health.” Accessed May 2019. https://ww2.arb.ca.gov/resources/ sulfur-dioxide-and-health.
CARB. 2019f. “Overview: Diesel Exhaust and Health.” Accessed May 2019. https://www.arb.ca.gov/research/ diesel/diesel-health.htm.
CARB. 2021a. State Area Designations. Accessed March 2021. http://www.arb.ca.gov/desig/adm/adm.htm.
CARB. 2021b. iADAM: Air Quality Data Statistics. Accessed March 2021. https://www.arb.ca.gov/adam.
CARB. 2021c. Ambient Air Quality Standards. Accessed March 2021. http://www.arb.ca.gov/research/ aaqs/aaqs2.pdf.
CDPH. 2019. Epidemiologic Summary of Coccidioidomycosis in California, 2018. https://www.cdph.ca.gov/ Programs/CID/DCDC/CDPH%20Document%20Library/CocciEpiSummary2018.pdf.
City of San Marcos. 2012. City of San Marcos General Plan. Adopted February 14, 2012. http://www.san-marcos.net/work/economic-development/general-plan. 7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-3
City of San Marcos. 2020a. City of San Marcos Final Climate Action Plan. Adopted December 2020. Accessed March 2021. https://www.san-marcos.net/home/showpublisheddocument?id=25084.
City of San Marcos. 2020b. San Marcos Code of Ordinances, Title 20, Chapter 20.230 – Industrial Zones. January
14. Accessed October 2020. https://library.municode.com/ca/san_marcos/codes/ code_of_ordinances?nodeId=TIT20ZO_CH20.230INZO.
County of San Diego. 2007. Guidelines for Determining Significance and Report and Format and Content Requirements – Air Quality. Land Use and Environment Group. Department of Planning and Land Use.
Department of Public Works. March 19, 2007.
EPA. 2013. Integrated Science Assessment of Ozone and Related Photochemical Oxidants. U.S. EPA, EPA/ 600R-10/076F, 2013.
EPA. 2016. “Criteria Air Pollutants.” https://www.epa.gov/criteria-air-pollutants.
EPA. 2020. EPA Air Data: Air Quality Data Collected at Outdoor Monitors Across the US. Last Updated:
November 17, 2020. Accessed March 2021. https://www.epa.gov/outdoor-air-quality-data.
EPA. 2021. Current Nonattainment Counties for Criteria Pollutants. February 28, 2021. Accessed March 2021. https://www3.epa.gov/airquality/greenbook/ancl.html.
Nelson, J. 2019. Coccidioidomycosis Data Requests. Email from J. Nelson (County of San Diego Health and Human Services Agency Senior Epidemiologist) to S. Wang (Dudek). December 13, 2019.
NRC (National Research Council). 2005. Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants. Washington, DC: The National Academies Press. https://doi.org/10.17226/11208.
OEHHA (Office of Environmental Health Hazard Assessment). 2018. Indicators of Climate Change in California.
May 9, 2018. https://oehha.ca.gov/media/downloads/climate-change/report/ 2018caindicatorsreportmay2018.pdf.
SANDAG. 2013. Series 13 Regional Growth Forecast City of San Marcos. http://datasurfer.sandag.org/ download/sandag_forecast_13_jurisdiction_san-marcos.pdf.
SCAQMD (South Coast Air Quality Management District). 2003. Final 2003 AQMP Appendix V: Modeling and Attainment Demonstrations. August 2003. Accessed March 2021. https://www.aqmd.gov/docs/ default-source/clean-air-plans/air-quality-management-plans/2003-air-quality-management-plan/ 2003-aqmp-appendix-v.pdf?sfvrsn=2.
SDAPCD (San Diego Air Pollution Control District). 1976. Regulation IV: Prohibitions; Rule 51: Public Nuisance.
Accessed February 2017. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/ Rules_and_Regulations/Prohibitions/APCD_R50-1-51.pdf.
SDAPCD. 1997. Regulation IV: Prohibitions; Rule 50: Visible Emissions. Effective August 13, 1997. Accessed July 27, 2018. https://www.sdapcd.org/content/dam/sdc/apcd/PDF/Rules_and_Regulations/ Prohibitions/APCD_R50.pdf.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-4
SDAPCD. 1998. Regulation II: Permits; Rule 20.2: New Source Review Non-Major Stationary Sources. Effective December 17, 1998. Accessed July 27, 2018. https://www.sdapcd.org/content/dam/sdc/ apcd/PDF/Rules_and_Regulations/Permits/APCD_R20-2.pdf.
SDAPCD. 2005. Measures to Reduce Particulate Matter in San Diego County. December 2005. Accessed March 2021. https://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Air%20Quality% 20Planning/PM-Measures.pdf.
SDAPCD. 2009. Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Adopted June 24, 2009; effective December 24, 2009. Accessed December 12, 2016. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/ Rules_and_Regulations/Prohibitions/APCD_R55.pdf.
SDAPCD. 2015. Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Adopted June 24, 2015. Effective January 1, 2016. Accessed December 12, 2016. http://www.sdapcd.org/content/dam/sdc/ apcd/PDF/Rules_and_Regulations/Prohibitions/APCD_R67-0-1.pdf.
SDAPCD. 2016. 2008 Eight-Hour Ozone Attainment Plan for San Diego County. Final. December 2016. San Diego, California: SDAPCD. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/ Air%20Quality%20Planning/8-Hr-O3%20Attain%20Plan-08%20Std.pdf.
SDAPCD. 2019. Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessments (HRAs). May. Accessed February 2022. https://www.sdapcd.org/content/dam/ sdapcd/documents/permits/air-toxics/Hot-Spots-Guidelines.pdf.
SDAPCD. 2020. 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County. October 2020. https://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Air% 20Quality%20Planning/Att%20A%20(Attainment%20Plan)_ws.pdf.
SDAPCD. 2021. Rule 67.0.1. Architectural Coatings (Rev. Adopted February 10, 2021, Effective January 1, 2022). https://www.sdapcd.org/content/dam/sdapcd/documents/rules/current-rules/Rule-67.0.1- eff010122.pdf.
SDAPCD. 2022. Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessment (HRAs). July 2022. https://www.sdapcd.org/content/dam/sdapcd/documents/permits/ air-toxics/Hot-Spots-Guidelines.pdf.
SJVAPCD (San Joaquin Valley Air Pollution Control District). 2015. Brief of Amicus Curiae in Support of Defendant and Respondent, County of Fresno, and Real Party In Interest and Respondent, Friant Ranch, L.P., Sierra Club v. County of Fresno, Case No. S219783 (filed Apr. 13, 2015). https://www.courts.ca.gov/ documents/7-s219783-ac-san-joaquin-valley-unified-air-pollution-control-dist-041315.pdf.
WRCC (Western Regional Climate Center). 2017. “Monthly Climate Summary San Diego Lindbergh Field, California (047740).” Accessed June 2018. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca7740. 7 - REFERENCES
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Section 3.3: Biological Resources
AMEC Earth & Environmental, Conservation Biology Institute, Onaka Planning & Economics, and The Rick Alexander Company. 2003. Final Multiple Habitat Conservation Program Plan, Volume I. March.
City of San Marcos. 2001. Public Review Draft San Marcos Subarea Plan. Retrieved from:
https://www.sandag.org/index.asp?publicationid=153&fuseaction=publications.detail.
City of San Marcos. 2012. City of San Marcos General Plan. Adopted February 14.
Historical Aerials. 2021. Retrieved from: https://www.historicaerials.com/viewer.
U.S. Army Corps of Engineers (USACE). 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0). Eds. J.S. Wakely, R.W. Lichvar, and C.V. Noble. ERDC/ EL TR-06-16. Vicksburg, MS: U.S. Army Engineer Research and Development Center. September.
U.S. Fish and Wildlife Service (USFWS). 1997. Coastal California Gnatcatcher (Polioptila californica californica) Presence/Absence Survey Protocol. 5pp.
USFWS. 2017. Survey Guidelines for the Listed Large Branchiopods. November 13.
Section 3.4: Cultural Resources
City of San Marcos. 2012. City of San Marcos General Plan - Conservation and Open Space Element. Adopted February 14, 2021. Accessed April 5, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8478.
Section 3.5: Energy
CAPCOA (California Air Pollution Control Officers Association). 2021. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2020.4.0. Prepared by BREEZE Software, A Division of Trinity Consultants, in collaboration with South Coast Air Quality Management District and the California Air Districts. September. Accessed November 2021. http://caleemod.com/.
CARB (California Air Resources Board). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October 2000. http://www.arb.ca.gov/diesel/ documents/rrpfinal.pdf.
CARB. 2017. California’s 2017 Climate Change Scoping Plan. November 2017. https://www.arb.ca.gov/ cc/scopingplan/scoping_plan_2017.pdf.
CARB. 2019. “Overview: Diesel Exhaust and Health.” Accessed May 2019. https://www.arb.ca.gov/ research/diesel/diesel-health.htm.
CARB. 2021. EMFAC2021 v1.0.1. Accessed November 2021. https://arb.ca.gov/emfac/. 7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-6
CEC (California Energy Commission). 2018. 2019 Building Energy Efficiency Standards Fact Sheet. March 2018. https://www.energy.ca.gov/title24/2019standards/documents/2018_Title_24_2019_Building_ Standards_FAQ.pdf
City of San Marcos. 2012. City of San Marcos General Plan. Adopted February 14.
City of San Marcos. 2020. City of San Marcos Final Climate Action Plan. Adopted December 2020. Accessed March 2021. https://www.san-marcos.net/home/showpublisheddocument?id=25084.
CPUC (California Public Utilities Commission). 2016. CPUC Biennial RPS Program Update: In Compliance with Public Utilities Code Section 913.6. January 1, 2016. Accessed October 4, 2019. https://www.cpuc.ca.gov/-/media/cpuc-website/files/uploadedfiles/cpuc_website/content/ utilities_and_industries/energy/reports_and_white_papers/final12302015section913-6report.pdf.
CPUC. 2022. Our Renewable Energy Goals. https://www.sdge.com/more-information/environment/ about-our-initiatives/renewable-goals.
EIA. 2018a. “California State Energy Profile”. Last updated November 15, 2018. Accessed March 2019. https://www.eia.gov/state/print.php?sid=CA
EIA. 2018b. “California State Profile and Energy Estimates – Table F15: Total Petroleum Consumption Estimates, 2016.” Accessed February 2019. http://www.eia.gov/state/seds/data.cfm?incfile=/state/seds/ sep_fuel/html/fuel_use_pa.html&sid=US&sid=CA.
EIA. 2019. “State Electricity Profiles – California Electricity Profile 2018.” December 31, 2019; corrected March 23, 2020. Accessed May 2020. https://www.eia.gov/electricity/state/california/index.php.
EIA (U.S. Energy Information Administration). 2020a. “California Electricity Profile 2019.” EIA, Electricity. Released November 2, 2020. Accessed March 2021. https://www.eia.gov/electricity/state/california/index.cfm.
EIA. 2020b. “California State Energy Profile.” Last updated January 16, 2020. Accessed May 2020. https://www.eia.gov/state/print.php?sid=CA.
EIA. 2021. “Natural Gas Consumption By End Use (California, 2019).” EIA, Natural Gas. Released February 26, 2021.Accessed March 2021. https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm.
EPA (U.S. Environmental Protection Agency). 2013. Integrated Science Assessment of Ozone and Related Photochemical Oxidants. U.S. EPA, EPA/600R-10/076F, 2013.
SANDAG ( San Diego Association of Governments). 2021. 2021 Regional Plan. Accessed April 2022. https://sdforward.com/mobility-planning/2021-regional-plan.
SDG&E (San Diego Gas & Electric). 2019. “Energy Data Access.” Accessed July 2019. https://energydata.sdge.com/.
SDG&E. 2022. “About Us” [webpage]. Accessed October 13, 2022. https://www.sdge.com/more-information/ our-company/about-us.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-7
The Climate Registry. 2021. The Climate Registry’s 2021 Default Emission Factors. May. https://www.theclimateregistry.org/wp-content/uploads/2021/05/2021-Default-Emission- Factor-Document.pdf.
Section 3.6: Geology and Soils
California Building Standards Commission. 2020. California Uniform Building Code. Updated January 1, 2020.
Accessed March 29, 2021. https://www.dgs.ca.gov/BSC/Codes.
California Geological Survey. 2008. Guidelines for Evaluating and Mitigating Seismic Hazards in California.
Special Publication 117A. State Minin and Geology Board. Revised and re-adopted September 11, 2008.
City of San Marcos. 2012. City of San Marcos General Plan – Safety Element. Approved February 14, 2012.
Accessed March 26, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
County of San Diego. 2017. Multi-Jurisdictional Hazard Mitigation Plan. Updated October 2017. Accessed March 29, 2021. https://www.sandiegocounty.gov/content/dam/sdc/oes/emergency_ management/HazMit/2018/2018%20Hazard%20Mitigation%20Plan.pdf.
Section 3.7: Greenhouse Gas Emissions
CAPCOA (California Air Pollution Control Officers Association). 2021. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2020.4.0. Prepared by BREEZE Software, A Division of Trinity Consultants, in collaboration with South Coast Air Quality Management District and the California Air Districts. September. Accessed November 2021. http://caleemod.com/.
CARB. 2008. Climate Change Scoping Plan: A Framework for Change. December 2008. http://www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm.
CARB. 2014. First Update to the AB 32 Scoping Plan. May 2014. http://www.arb.ca.gov/cc/scopingplan/ document/updatedscopingplan2013.htm.
CARB. 2015. “Glossary of Terms Used in GHG Inventories.” https://www.arb.ca.gov/cc/inventory/ faq/ghg_inventory_glossary.htm.
CARB. 2017. California’s 2017 Climate Change Scoping Plan. November 2017. https://www.arb.ca.gov/ cc/scopingplan/scoping_plan_2017.pdf.CARB. 2018. “AB 32 Scoping Plan.” Last updated January 8, 2018. Accessed July 30, 2018. https://www.arb.ca.gov/cc/scopingplan/scopingplan.htm.
CARB. 2021. “California’s 2000-2019 Greenhouse Gas Emissions Inventory 2021 Edition. July 2021. https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/pubs/reports/ 2000_2019/ghg_inventory_00-19_method_update_document.pdf CEC (California Energy Commission). 2018. 2019 Building Energy Efficiency Standards Fact Sheet. March 2018. https://www.energy.ca.gov/title24/2019standards/documents/2018_Title_24_2019_Building_ Standards_FAQ.pdf.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-8
City of San Marcos. 2012. City of San Marcos General Plan. Adopted February 14, 2012. http://www.san-marcos.net/work/economic-development/general-plan.
City of San Marcos. 2020a. San Marcos Code of Ordinances, Title 20, Chapter 20.230 – Industrial Zones. January
14. Accessed October 2020. https://library.municode.com/ca/san_marcos/ codes/code_of_ordinances?nodeId=TIT20ZO_CH20.230INZO.
City of San Marcos. 2020b. City of San Marcos Final Climate Action Plan. Adopted December 2020. Accessed March 2021. https://www.san-marcos.net/home/showpublisheddocument?id=25084.
City of San Marcos. 2020c. City’s Guidance to Demonstrating Consistency with the City of San Marcos Climate Action Plan: For Discretionary Projects Subject to CEQA.
CNRA. 2009. 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008. http://resources.ca.gov/docs/climate/Statewide_ Adaptation_Strategy.pdf.
CNRA. 2014. Safeguarding California: Reducing Climate Risk—An Update to the 2009 California Climate Adaptation Strategy. July 2014. http://resources.ca.gov/docs/climate/Final_Safeguarding_ CA_Plan_July_31_2014.pdf.
CNRA. 2018. Safeguarding California Plan: 2018 Update, California’s Climate Adaptation Strategy. January 2018. http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california-plan- 2018-update.pdf.
EPA. 2016. “Glossary of Climate Change Terms.” July 10, 2017. https://www3.epa.gov/climatechange/glossary.html.
EPA. 2017a. “Climate Change.” Last updated January 19, 2017. https://www.epa.gov/climatechange.
EPA. 2017b. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990–2015. EPA 430-P-17-001. https://www.epa.gov/sites/production/files/2017-02/documents/2017_complete_report.pdf.
EPA. 2021. Current Nonattainment Counties for Criteria Pollutants. February 28, 2021. Accessed March 2021. https://www3.epa.gov/airquality/greenbook/ancl.html.
EPA and NHTSA (U.S. Environmental Protection Agency and Department of Transportation’s National Highway Traffic Safety Administration). 2016. EPA and NHTSA Adopt Standards to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond. August 2016. https://nepis.epa.gov/Exe/ZyPDF.cgi/P100P7NL.PDF?Dockey=P100P7NL.PDF.
IPCC (Intergovernmental Panel on Climate Change). 1995. IPCC Second Assessment: Climate Change 1995. A Report of the Intergovernmental Panel on Climate Change. Geneva, Switzerland: IPCC. https://www.ipcc.ch/pdf/climate-changes-1995/ipcc-2nd-assessment/2nd-assessment-en.pdf.
IPCC. 2007. Climate Change 2007: Synthesis Report. A Report of the Intergovernmental Panel on Climate Change. Geneva, Switzerland: IPCC. https://www.ipcc.ch/publications_and_data/ publications_ipcc_fourth_assessment_report_synthesis_report.htm. 7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-9
IPCC. 2013. Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, edited by R.K. Pachauri and L.A.
Meyer. Geneva, Switzerland: IPCC. https://www.ipcc.ch/report/ar5/syr/.
IPCC. 2014. “Summary for Policymakers.” In Climate Change 2014 Synthesis Report. A Report of the Intergovernmental Panel on Climate Change. Contribution of Working Groups I, II, and III to the Fifth Assessment Report of the IPCC. Geneva, Switzerland: IPCC. http://www.ipcc.ch/report/ar5/syr/.
PBL (PBL Netherlands Environmental Assessment Agency). 2018. Trends in Global CO2 and Total Greenhouse Gas Emissions, 2018 Report.
SANDAG. 2015. San Diego Forward: The Regional Plan. October 2015. http://www.sdforward.com/ pdfs/RP_final/The%20Plan%20-%20combined.pdf.
SANDAG. 2021. 2021 Regional Plan. Accessed April 2022. https://sdforward.com/mobility-planning/ 2021-regional-plan.
The White House. 2021. Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis. January 20. https://www.whitehouse.gov/briefing-room/ presidential-actions/2021/01/20/executive-order-protecting-public-health-and-environment-and- restoring-science-to-tackle-climate-crisis/.
Section 3.8: Hazards and Hazardous Materials
City of San Marcos. 2012. City of San Marcos General Plan – Safety Element. Approved February 14, 2012.
Accessed March 30, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
County of San Diego. 2005. Integrated Waste Management Plan. Revised 2005. Accessed March 30, 2021. https://www.sandiegocounty.gov/content/dam/sdc/common_components/images/dpw/recyclingpdfs/ summaryplan.pdf.
County of San Diego. 2017. Multi-Jurisdictional Hazard Mitigation Plan. Updated October 2017. Accessed March 30, 2021. https://www.sandiegocounty.gov/content/dam/sdc/oes/ emergency_management/HazMit/2018/2018%20Hazard%20Mitigation%20Plan.pdf.
San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan.
Amended December 1, 2011. Accessed March 30, 2021. https://www.lee-associates.com/ elee/sandiego/LeeLandTeam/Ponto/McClellan-Palomar_ALUCP_20111.pdf.
San Marcos Fire Department. 2007. Wildlife Urban Interface/Community Wildfire Protection Plan. Adopted December 2007. Accessed March 30, 2021. https://www.san-marcos.net/home/ showdocument?id=3680.
Section 3.9: Hydrology and Water Quality
Carlsbad Watershed Management Area Responsible Agencies. 2016. Carlsbad Watershed Management Area Water Quality Improvement Plan. Adopted June 30, 2016. Accessed April 2, 2021. http://www.projectcleanwater.org/download/carlsbad-water-quality-improvement-plan-and- appendices-june-2016/.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-10
City of San Marcos. 2012a. City of San Marcos General Plan – Conservation and Open Space Element. Adopted February 14, 2021. Accessed April 2, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8478.
City of San Marcos. 2012b. City of San Marcos General Plan – Safety Element. Adopted February 14, 2021.
Accessed April 2, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
City of San Marcos. 2012c. City of San Marcos General Plan – Land Use and Community Design Element. Adopted February 14, 2021. Accessed April 2, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8480.
County of San Diego. 2020. County of San Diego BMP Design Manual for Permanent Site design, Storm Water Treatment and Hydromodification Management. Effective September 15, 2020. Accessed April 2, 2021. https://www.sandiegocounty.gov/content/sdc/dpw/watersheds/DevelopmentandConstruction/ BMP_Design_Manual.html.
MWD (Metropolitan Water District of Southern California). 2016. Urban Water Management Plan. Adopted June 2016. Accessed April 2, 2021. http://www.mwdh2o.com/PDF_About_Your_Water/2.4.2_ Regional_Urban_Water_Management_Plan.pdf#search=urban%20water%20management%20plan.
Regional Water Quality Control Board (RWQCB). 2021. San Diego Basin Plan Map GIS webpage. Accessed April 2, 2021. https://gispublic.waterboards.ca.gov/portal/apps/webappviewer/index.html?id= 1f58bd97fdcd45329a5e16e373ede24d.
SWRCB (State Water Resources Control Board). 2002. SDRWQCB Watershed Management Approach. Appendix A, Overview of San Diego Region Watershed Management Areas. Approved January 25, 2002. Accessed April 2, 2021. https://www.waterboards.ca.gov/sandiego/water_issues/programs/wmc/docs/ wmchapxa102.pdf.
SWRCB. 2015. San Diego Region – Phase I Municipal Storm Water Permit. Amended November 18, 2015.
Accessed April 2, 2021. https://www.waterboards.ca.gov/sandiego/water_issues/programs/ stormwater/sd_stormwater.html.
Section 3.10: Land Use and Planning
City of San Marcos. 2012a. City of San Marcos General Plan – Land Use and Community Design Element.
Adopted February 14, 2012. Accessed April 2, 2021. https://www.san-marcos.net/ home/showpublisheddocument?id=8480.
City of San Marcos. 2012b. City of San Marcos General Plan – Mobility Element. Adopted February 14, 2012.
Accessed April 5, 2021. https://www.san -marcos.net/home/showpublisheddocument?id=8479 .
City of San Marcos. 2012c. City of San Marcos General Plan – Conservation and Open Space Element. Adopted February 14, 2012. Accessed April 8, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8478.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-11
City of San Marcos. 2012d. City of San Marcos General Plan – Parks, Recreation, and Community Health Element.
Adopted February 14, 2021. Accessed April 8, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8477.
City of San Marcos. 2012e. City of San Marcos General Plan – Safety Element. Adopted February 14, 2012.
Accessed April 8, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
City of San Marcos. 2012f. City of San Marcos General Plan – Noise Element. Adopted February 14, 2012.
Accessed April 8, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8475.
City of San Marcos. 2013. City of San Marcos General Plan – 2013-2021 Housing Element. Adopted June 25, 2013. Accessed April 8, 2021. https://www.san -marcos.net/home/ showpublisheddocument?id=8474.
City of San Marcos. 2022. San Marcos Municipal Code. Chapter 20.230 – Industrial Zones. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.230INZO.
SANDAG (San Diego Association of Governments). 2001. Draft Natural Community Conservation Plan for the City of San Marcos. Adopted May 2001. Accessed April 2, 2021. https://www.sandag.org/uploads/ publicationid/publicationid_153_8102.pdf.
SANDAG. 2003. Multiple Habitat Conservation Program. Approved March 2003. Accessed April 2, 2021. https://www.sandag.org/index.asp?projectid=97&fuseaction=projects.detail.
SANDAG. 2019. San Diego Forward – 2019 Federal Regional Transportation Plan. Approved November 15, 2019.
Accessed April 2, 2021. https://sdforward.com/2019-federal-rtp.
San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan.
Amended December 1, 2011. Accessed April 2, 2021. https://www.lee-associates.com/ elee/sandiego/LeeLandTeam/Ponto/McClellan-Palomar_ALUCP_20111.pdf.
SDCSD (San Diego County Sheriff’s Department). 2021. San Diego County Sheriff’s Department – San Marcos Station webpage. Accessed March 16, 2021. https://www.sdsheriff.gov/Home/Components/ FacilityDirectory/FacilityDirectory/40/61.
Section 3.11: Noise
Caltrans (California Department of Transportation). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. September.
Caltrans. 2020. Transportation and Construction Vibration Guidance Manual. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise, Paleontology Office. Sacramento, California. April.
Carrier. 2012. CA16NA 018-061 Single-Stage Air Conditioner w/ Puron Refrigerant. Catalog No: CA16NA-06PD. https://resource.carrierenterprise.com/is/content/Watscocom/carrier_ca16na03600g_article_ 1404816 230548_en_ss?_ga=2.123164302.489492439.1570570581-792571132.1570570581 City of San Marcos. 2012. City of San Marcos General Plan. Chapter 7.0, Noise Element. February 2012. 7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-12
City of San Marcos. 2017. City of San Marcos Municipal Code.
DOT (U.S. Department of Transportation). 2006. FHWA Roadway Construction Noise Model: User’s Guide. Final Report. FHWA-HEP-06-015. DOT-VNTSC-FHWA-06-02. Cambridge, Massachusetts: DOT, Research and Innovative Technology Administration. Final Report. August.
Federal Highway Administration (FHWA). 2004. Traffic Noise Model (version 2.5).
FHWA. 2008. Roadway Construction Noise Model (RCNM), Software Version 1.1. U.S. Department of Transportation, Research and Innovative Technology Administration, John A. Volpe National Transportation Systems Center, Environmental Measurement and Modeling Division. Washington, D.C.
December 8, 2008.
FTA (Federal Transit Administration). 2018. Transit Noise and Vibration Impact Assessment. FTA Report No. 0123. September.
Halliwell, R.E., Nightingale, T.R.T., Warnock, A.C.C., Birta, J.A. 1998. “Gypsum Board Walls: Transmission Loss Data”. Internal Report IRC-IR-761. NRC-CNRC. March.
Loren Cook Company. 2015. A Handbook for The Mechanical Designer. Retrieved February 18, 2021, from https://www.lorencook.com/PDFs/Catalogs/Cookbook_Catalog.pdf.
OPR (Governor’s Office of Planning and Research). 2003. State of California General Plan Guidelines. October.
Section 3.12: Population and Housing
City of San Marcos. 2013. 2013 – 2021 Housing Element. Adopted June 25, 2013. Accessed March 31, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8474.
City of San Marcos. 2021. Public Review Draft 2021-2029 Housing Element Update. March 12, 2021. Accessed April 1, 2021. https://static1.squarespace.com/static/5e31b267da2435584e40b8eb/ t/604ab7e87b0857655f8b1603/1615509491186/Part+2+Draft+2021-2029+San+Marcos+HE.pdf.
DOF (California Department of Finance). 2020. E-5 Population and Housing Estimates for Cities, Counties and the State – May 2020. Accessed March 31, 2021. https://dof.ca.gov/Forecasting/Demographics/ Estimates/E-5/.
SANDAG (San Diego Association of Governments). 2004. Regional Comprehensive Plan for the San Diego Region.
Adopted July 2004. Accessed March 31, 2021. https://www.sandag.org/ index.asp?projectid=1&fuseaction=projects.detail.
SADNAG. 2011. 2050 Regional Transportation Plan. Adopted October 2011. Accessed March 31, 2021. https://www.sandag.org/uploads/2050RTP/F2050rtp_all.pdf.
SANDAG. 2013a. Series 13 Regional Growth Forecast City of San Marcos. Adopted October 2013. Accessed March 31, 2021. https://datasurfer.sandag.org/download/sandag_forecast_13_jurisdiction_ san-marcos.pdf.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-13
SANDAG. 2013b. Series 13 Regional Growth Forecast – San Diego Region. Adopted October 2013. Accessed March 31, 2021. https://www.sandag.org/uploads/projectid/projectid_503_19239.pdf.
SANDAG. 2020. Regional Housing Needs Assessment 6th Housing Element Cycle 2021-2029. Approved July 10, 2020. Accessed March 31, 2021. https://www.sandag.org/index.asp?projectid=189&fuseaction= projects.detail.
Section 3.13: Public Services
City of San Marcos. 2012a. City of San Marcos General Plan – Land Use and Community Design Element.
Approved February 14, 2012. Accessed March 16, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8480.
City of San Marcos. 2012b. City of San Marcos General Plan – Safety Element. Approved February 14, 2012.
Accessed March 16, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
City of San Marcos. 2012c. City of San Marcos General Plan – Parks, Recreation, and Community Health Element.
Approved February 14, 2012. Accessed March 16, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8477.
City of San Marcos. 2018. Parks Master Plan Update. Updated 2018. Accessed March 18, 2021. https://www.san-marcos.net/home/showpublisheddocument/22713/636730373939070000.
City of San Marcos. 2021a. City of San Marcos Fire Department – Department Overview. Accessed March 16, 2021. https://www.san-marcos.net/departments/public-safety/fire-department/department-overview.
City of San Marcos. 2021b. City of San Marcos Fire Department – Fire Department Facilities webpage. Accessed March 16, 2021. https://www.san-marcos.net/departments/public-safety/fire-department/department- overview/fire-facilities.
City of San Marcos. 2021c. City of San Marcos – Library webpage. Accessed March 18, 2021. https://www.san-marcos.net/live/library.
City of San Marcos. 2021d. City of San Marcos Municipal Plan Chapter 17.36 – Park and Recreational Development Construction Unit Fee. Accessed March 16, 2021. https://library.municode.com/ ca/san_marcos/codes/code_of_ordinances?nodeId=TIT17BUCOREAC_CH17.36PAREDECOUNFE.
City of San Marcos. 2021e. City of San Marcos Municipal Plan Chapter 17.44 – Development Services and Public Facilities Exactions, Fees and/or Costs. Accessed March 16, 2021. https://library.municode.com/ ca/san_marcos/codes/code_of_ordinances?nodeId=TIT17BUCOREAC_CH17.44DESEPUFAEXFECO.
City of San Marcos. 2021f. City of San Marcos Municipal Plan Chapter 17.52 – School Fees and Land Dedication.
Accessed March 16, 2021. https://library.municode.com/ca/san_marcos/codes/ code_of_ordinances?nodeId=TIT17BUCOREAC_CH17.52SCFELADE.
CSUSM (California State University San Marcos). 2021. Borrowing Books and Media. Accessed March 18, 2021. https://biblio.csusm.edu/content/borrowing-policies-books-and-media. 7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-14
Palomar College. 2021. Library FAQ. Last updated 2021. Accessed March 18, 2021. https://www2.palomar.edu/pages/library/library-faq/.
San Diego County Library. 2021. San Diego County Library – San Marcos Branch Library webpage. Accessed March 18, 2021. https://www.sdcl.org/locations_SM.html.
SDCSD (San Diego County Sheriff’s Department). 2021. San Diego County Sheriff’s Department – San Marcos Station webpage. Accessed March 16, 2021. https://www.sdsheriff.gov/Home/Components/ FacilityDirectory/FacilityDirectory/40/61.
Serra Cooperative Library System. 2016. About Serra webpage. Updated 2016. Accessed March 18, 2021. https://www.serralib.org/.
SMUSD (San Marcos Unified School District). 2019. Local Control Funding Formula (LCFF) and Local Control Accountability Plan (LCAP) – San Marcos Unified School District. Approved August 23, 2019. Accessed March 17, 2020. https://www.sdcoe.net/about-sdcoe/Documents/district-LCAP/ 2017-20-San-Marcos.pdf.
SMUSD. 2020. Residential and Commercial Developer Fees webpage. Last updated April 22, 2020. Accessed March 17, 2021. https://www.smusd.org/cms/One.aspx?portalId=157433&pageId=394313.
Section 3.14: Recreation
City of San Marcos. 2012. City of San Marcos General Plan – Parks, Recreation, and Community Health Element.
Approved February 14, 2012. Accessed March 16, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8477.
City of San Marcos. 2018. Parks Master Plan Update. Updated June 2018. Accessed March 18, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=22713.
City of San Marcos. 2021a. City of San Marcos Municipal Code: Chapter 17.36 – Park and Recreational Development Construction Unit Fee. Accessed March 18, 2021. https://library.municode.com/ca/san_marcos /codes/code_of_ordinances?nodeId=TIT17BUCOREAC_CH17.36PAREDECOUNFE.
City of San Marcos. 2021b. City of San Marcos Municipal Plan Chapter 17.44 – Development Services and Public Facilities Exactions, Fees and/or Costs. Accessed March 16, 2021. https://library.municode.com/ ca/san_marcos/codes/code_of_ordinances?nodeId=TIT17BUCOREAC_CH17.44DESEPUFAEXFECO.
City of San Marcos. 2023. Discover San Marcos Parks & Recreation. Accessed February 17, 2023. https://www.san-marcos.net/departments/parks-recreation.
DOF (Department of Finance). 2020. E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2011-2020. Updated May 2020. Accessed March 18, 2021. http://www.dof.ca.gov/ Forecasting/Demographics/Estimates/E-5/.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-15
Section 3.15: Transportation
City of San Marcos. 2012. City of San Marcos General Plan – Safety Element. Approved February 14, 2012.
Accessed March 26, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
City of San Marcos. 2022. San Marcos Code of Ordinances. Chapter 20.340 Off-Street Parking and Loading. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_ CH20.340OREPALO
OPR (Governor’s Office of Planning and Research). 2023. SB 743 Frequently Asked Questions. https://opr.ca.gov/ceqa/sb-743/faq.html
SANDAG. 2021. 2021 Regional Plan. Accessed April 2022. https://sdforward.com/mobility-planning/2021- regional-plan.
Section 3.16: Tribal Cultural Resources
City of San Marcos. 2012. City of San Marcos General Plan - Conservation and Open Space Element. Adopted February 14, 2021. Accessed April 5, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8478.
Section 3.17: Utilities and Service Systems
CalRecycle. 2019a. SWIS Facility Detail: Sycamore Landfill (37-AA-0023). Accessed April 12, 2021. https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2871.
CalRecycle. 2019b. Estimated Solid Waste Generation Rates. Accessed May 13, 2021. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates.
City of San Marcos. 2012a. City of San Marcos General Plan – Land Use and Community Design Element.
Adopted February 14, 2012. Accessed April 12, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8480.
City of San Marcos. 2012b. City of San Marcos General Plan – Conservation and Open Space Element. Adopted February 14, 2012. Accessed April 12, 2021. https://www.san-marcos.net/home/ showpublisheddocument?id=8478.
County of San Diego. 2008. Integrated Waste Management Plan. Non-Disposal Facility Element for the County Unincorporated Area. Adopted July, 2008. Accessed April 12, 2021. https://www.sandiegocounty.gov/ content/dam/sdc/common_components/images/dpw/recyclingpdfs/2008NDFE1.pdf.
MWD (Metropolitan Water District of Southern California). 2016. Urban Water Management Plan. Adopted June 2016. Accessed April 12, 2021. http://www.mwdh2o.com/PDF_About_Your_Water/
2.4.2_Regional_Urban_Water_Management_Plan.pdf#search=urban%20water% 20management%20plan.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-16
SANDAG (San Diego Association of Governments). 2013. Series 13 Regional Growth Forecast City of San Marcos.
Adopted October 2013. Accessed March 31, 2021. https://datasurfer.sandag.org/download/ sandag_forecast_13_jurisdiction_san-marcos.pdf.
SANDAG. 2020. Final 6th Cycle Regional Housing Needs Assessment Plan. July 10, 2020. Accessed April 2022. https://www.sandag.org/uploads/projectid/projectid_189_27782.pdf.
SDCWA (San Diego County Water Authority). 2021. 2020 Water Shortage Contingency Plan Draft. March 2021.
Accessed October 2022. https://www.sdcwa.org/wp-content/uploads/2021/03/Draft-2020-WSCP.pdf VWD (Vallecitos Water District). 2018. 2018 Waster, Wastewater, and Recycled Water Master Plan. Adopted October 4, 2018. Accessed April 12, 2021. http://www.vwd.org/home/showdocument?id=10656.
Section 3.18 Wildfire
City of San Marcos. 2012. City of San Marcos General Plan – Safety Element. Approved February 14, 2012.
Accessed March 26, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8476.
DOF (California Department of Finance). 2020. E-5 Population and Housing Estimates for Cities, Counties and the State – May 2020. Accessed March 31, 2021. https://dof.ca.gov/Forecasting/Demographics/ Estimates/E-5/.
Nailon, J. 2021. “San Marcos Fire Department Service Calls Volume.” Personal Communication (phone call) with J. Nailon, Fire Marshal and Dudek. June 2, 2021.
SMFD (San Marcos Fire Department). 2007. Wildlife Urban Interface/Community Wildfire Protection Plan.
Adopted December 2007. Accessed March 30, 2021. https://www.san-marcos.net/home/ showdocument?id=3680.
SMFD. 2021. San Marcos Fire Department, Department Overview (Webpage). Available at https://www.san- marcos.net/departments/public-safety/fire-department/department-overview.
Section 3.19 Cumulative Effects
CalRecycle. 2019. SWIS Facility Detail. Accessed April 12, 2021. https://www2.calrecycle.ca.gov/SolidWaste/ Site/Summary/2871.
CARB. 2017. California’s 2017 Climate Change Scoping Plan. November 2017. https://www.arb.ca.gov/ cc/scopingplan/scoping_plan_2017.pdf.CARB. 2018. “AB 32 Scoping Plan.” Last updated January 8, 2018. Accessed July 30, 2018. https://www.arb.ca.gov/cc/scopingplan/scopingplan.htm.
CNRA (California Natural Resources Agency). 2009a. Final Statement of Reasons for Regulatory Action:
Amendments to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB 97. December 2009.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-17
CNRA. 2009b. 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008. http://resources.ca.gov/docs/climate/Statewide_ Adaptation_Strategy.pdf.
CNRA. 2018. Safeguarding California Plan: 2018 Update, California’s Climate Adaptation Strategy. January 2018. http://resources.ca.gov/docs/climate/safeguarding/update2018/safeguarding-california- plan-2018-update.pdf.
MWD (Metropolitan Water District of Southern California). 2016. Urban Water Management Plan. Adopted June 2016. Accessed April 2, 2021. http://www.mwdh2o.com/PDF_About_Your_Water/2.4.2_Regiona l_Urban_Water_Management_Plan.pdf#search=urban%20water%20management%20plan.
Chapter 4: Alternatives
City of San Marcos. 2018. General Plan Land Use Interactive Map [database]. Accessed November 14, 2018. http://maps2.san-marcos.net/mapgallery/map.html?webmap= 5b762031658c493cb7dc604654b5d9ce.
Chapter 5: Effects Found Not to Be Significant
CDC (California Department of Conservation). 2014. San Diego County Williamson Act 2013/2014. Accessed March 15, 2021.
CDC. 2021. California Important Farmland Finder. Accessed March 15, 2021. https://maps.conservation.ca.gov/ DLRP/CIFF/.
City of San Marcos. 2012. City of San Marcos General Plan – Conservation Open Space Element. Accessed March 15, 2021. https://www.san-marcos.net/home/showpublisheddocument?id=8478.
City of San Marcos. 2021. General Plan Land Use Interactive Map. Accessed March 15, 2021. http://maps2.san-marcos.net/mapgallery/map.html?webmap= 5b762031658c493cb7dc604654b5d9ce.
Chapter 6: Other CEQA Considerations
City of San Marcos. 2021. Public Review Draft 2021-2029 Housing Element. March 2021. https://static1.squarespace.com/static/5e31b267da2435584e40b8eb/t/ 604ab78dae06a97845cb9183/1615509412961/Consolidated+Draft+2021- 2029+San+Marcos+HE.pdf.
DOF (California Department of Finance). 2020. E-5 Population and Housing Estimates for Cities, Counties and the State – May 2020. Accessed March 31, 2021. https://dof.ca.gov/Forecasting/ Demographics/Estimates/E-5/.
7 - REFERENCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 7-18
SANDAG (San Diego Association of Governments). 2013. Series 13 Regional Growth Forecast City of San Marcos.
Adopted October 2013. Accessed March 31, 2021. https://datasurfer.sandag.org/ download/sandag_forecast_13_jurisdiction_san-marcos.pdf.
SANDAG. 2020. Regional Housing Needs Assessment 6th Housing Element Cycle 2021-2029. Approved July 10, 2020. Accessed March 31, 2021. https://www.sandag.org/
index.asp?projectid=189&fuseaction=projects.detail.
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 8-1
8 List of Preparers
8.1 City of San Marcos
Chris Garcia, Senior Planner
Saima Qureshy, Principal Planner
Joe Farace, Planning Manager
8.2 Dudek
Brian Grover, AICP, Principal
Vanessa Scheidel, Environmental Planner
Carolyn Somvilay, Environmental Analyst
Samantha Wang, Air Quality Specialist
Adam Poll, Air Quality Specialist
Mark Storm, Senior Acoustician Technical Specialist
Connor Burke, Environmental Technical Analyst
Michael Huff, Urban Forestry Specialist
Matthew DeCarlo, Cultural Archaeologist
Kathryn Landoe, Technical Editor
Jennifer Farned, Technical Editor
Amy Seals, Senior Technical Editor
Rachel Dobrolenski, Publications Specialist
8.3 Technical Preparers
Thomas Liddicoat, Helix Environmental Planning – Biological Technical Report William Lundstrom, Lundstrom Engineering & Surveying – Drainage Study Robert R. Russell, GeoTek, Inc. – Preliminary Geotechnical Evaluation Christopher Livesey, GeoTek, Inc. – Phase I Environmental Site Assessment Stephen M. Nielsen, Dexter Wilson Engineering, Inc. – Sewer & Water Memorandum Roman Lopez, Linscott Law & Greenspan – Transportation Impact Analysis Alijandra Alonso, Linscott Law & Greenspan – Transportation Impact Analysis Samantha Wang, Dudek – Air Quality and Greenhouse Gas Technical Report Adam Poll, Dudek – Air Quality and Greenhouse Gas Technical Report Mark Storm, Dudek – Noise Technical Report
Connor Burke, Dudek – Noise Technical Report
Michael Huff, Dudek – Preliminary Fire Emergency Response Analysis Matthew DeCarlo, Dudek – Cultural Resources Inventory Report
8 - LIST OF PREPARERS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 8-2
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