San Marcos City Council
July 23, 2024

ATTACHMENT D

FINAL ENVIRONMENTAL IMPACT REPORT
FINAL

Environmental Impact Report
Pacific Specific Plan Project
State Clearinghouse No. 2022050650
MAY 2024
Prepared for:

CITY OF SAN MARCOS
1 Civic Center Drive
San Marcos, California 92069
Contact: Joseph Farace
Prepared by:

605 Third Street
Encinitas, California 92024
Contact: Vanessa Scheidel

Printed on 30% post-consumer recycled material.

FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 TOC-i
Table of Contents
SECTION PAGE NO.

Acronyms and Abbreviations ...................................................................................................................................... ACR-i 0 Final EIR Introduction ...................................................................................................................................... 0-1 1 Executive Summary.......................................................................................................................................... 1-1

1.1 Project Summary ................................................................................................................................ 1-1

1.2 Summary of Significant Effects And Mitigation Measures That Reduce or Avoid the Significant Effect ................................................................................................................................ 1-2

1.3 Areas of Controversy .......................................................................................................................... 1-3

1.4 Issues to be Resolved by the Decision-Making Body ....................................................................... 1-3

1.5 Project Alternatives ............................................................................................................................ 1-4

1.5.1 No Project Alternative ........................................................................................................... 1-4

1.5.2 Existing Land Use Designation Alternative .......................................................................... 1-4

1.5.3 Reduced Development Footprint Alternative ...................................................................... 1-5

1.5.4 Reduced Development Footprint Alternative – Vernal Pool Impact Minimization ............ 1-5

1.5.5 Reduced Pacific Specific Plan Project Alternative .............................................................. 1-6

1.5.6 Environmentally Superior Alternative .................................................................................. 1-6 2 Project Description, Location, and Environmental Setting ............................................................................ 2-1

2.1 Project Objectives ............................................................................................................................... 2-1

2.2 Project Description ............................................................................................................................. 2-1

2.2.1 Discretionary Actions Required of the City .......................................................................... 2-3

2.2.2 Project Characteristics ......................................................................................................... 2-3

2.3 Environmental Setting ........................................................................................................................ 2-9

2.3.1 Existing Land Uses and Setting ............................................................................................ 2-9

2.3.2 Existing Land Use and Zoning Designations ..................................................................... 2-10

2.3.3 Regional Setting .................................................................................................................. 2-10

2.3.4 Public Services .................................................................................................................... 2-12

2.4 Intended Uses for EIR....................................................................................................................... 2-13

2.4.1 Scope of the EIR ................................................................................................................. 2-13

2.4.2 Notice of Preparation and Scoping .................................................................................... 2-14

2.4.3 Draft EIR and Public Review ............................................................................................... 2-14

2.4.4 Final EIR Publication and Certification .............................................................................. 2-15

2.4.5 Matrix of Project Approvals and Permits ........................................................................... 2-15

2.5 Project Inconsistencies with Applicable Regional and General Plans ........................................... 2-16

2.6 List of Past, Present, and Reasonably Anticipated Future Projects in the Project Area .............. 2-17

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 TOC-ii
3 Environmental Analysis .................................................................................................................................... 3-1

3.1 Aesthetics ........................................................................................................................................... 3-1

3.1.1 Existing Conditions................................................................................................................ 3-1

3.1.2 Regulatory Setting ................................................................................................................ 3-3

3.1.3 Thresholds of Significance ................................................................................................... 3-5

3.1.4 Project Impact Analysis ........................................................................................................ 3-5

3.1.5 Mitigation Measures ............................................................................................................. 3-8

3.1.6 Conclusion ............................................................................................................................. 3-8

3.2 Air Quality ......................................................................................................................................... 3.2-1

3.2.1 Existing Conditions............................................................................................................. 3.2-2

3.2.2 Regulatory Setting ........................................................................................................... 3.2-12

3.2.3 Thresholds of Significance .............................................................................................. 3.2-18

3.2.4 Project Impact Analysis ................................................................................................... 3.2-23

3.2.5 Mitigation Measures ........................................................................................................ 3.2-30

3.2.6 Conclusion ........................................................................................................................ 3.2-31

3.3 Biological Resources ....................................................................................................................... 3.3-1

3.3.1 Existing Conditions............................................................................................................. 3.3-2

3.3.2 Methodology ..................................................................................................................... 3.3-12

3.3.3 Regulatory Setting ........................................................................................................... 3.3-15

3.3.4 Thresholds of Significance .............................................................................................. 3.3-21

3.3.5 Project Impact Analysis ................................................................................................... 3.3-21

3.3.6 Mitigation Measures ........................................................................................................ 3.3-30

3.3.7 Conclusion ........................................................................................................................ 3.3-38

3.4 Cultural Resources .......................................................................................................................... 3.4-1

3.4.1 Existing Conditions............................................................................................................. 3.4-1

3.4.2 Regulatory Setting ............................................................................................................. 3.4-3

3.4.3 Thresholds of Significance ................................................................................................ 3.4-7

3.4.4 Project Impact Analysis ..................................................................................................... 3.4-7

3.4.5 Mitigation Measures .......................................................................................................... 3.4-8

3.4.6 Conclusion ........................................................................................................................ 3.4-12

3.5 Energy .............................................................................................................................................. 3.5-1

3.5.1 Existing Conditions............................................................................................................. 3.5-1

3.5.2 Regulatory Setting ............................................................................................................. 3.5-3

3.5.3 Thresholds of Significance .............................................................................................. 3.5-11

3.5.4 Project Impact Analysis ................................................................................................... 3.5-11

3.5.5 Mitigation Measures ........................................................................................................ 3.5-16

3.5.6 Conclusion ........................................................................................................................ 3.5-16

3.6 Geology and Soils ............................................................................................................................ 3.6-1

3.6.1 Existing Conditions............................................................................................................. 3.6-2

3.6.2 Regulatory Setting ............................................................................................................. 3.6-4

3.6.3 Thresholds of Significance ................................................................................................ 3.6-7

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3.6.4 Project Impact Analysis ..................................................................................................... 3.6-8

3.6.5 Mitigation Measures ........................................................................................................ 3.6-11

3.6.6 Conclusion ........................................................................................................................ 3.6-12

3.7 Greenhouse Gas Emissions ............................................................................................................ 3.7-1

3.7.1 Existing Conditions............................................................................................................. 3.7-1

3.7.2 Regulatory Setting ............................................................................................................. 3.7-6

3.7.3 Thresholds of Significance .............................................................................................. 3.7-19

3.7.4 Project Impact Analysis ................................................................................................... 3.7-24

3.7.5 Mitigation Measures ........................................................................................................ 3.7-43

3.7.6 Conclusion ........................................................................................................................ 3.7-43

3.8 Hazards and Hazardous Materials ................................................................................................. 3.8-1

3.8.1 Existing Conditions............................................................................................................. 3.8-1

3.8.2 Regulatory Setting ........................................................................................................... 3.8-10

3.8.3 Thresholds of Significance .............................................................................................. 3.8-16

3.8.4 Project Impact Analysis ................................................................................................... 3.8-17

3.8.5 Mitigation Measures ........................................................................................................ 3.8-20

3.8.6 Conclusion ........................................................................................................................ 3.8-20

3.9 Hydrology and Water Quality ........................................................................................................... 3.9-1

3.9.1 Existing Conditions............................................................................................................. 3.9-2

3.9.2 Regulatory Setting ............................................................................................................. 3.9-4

3.9.3 Thresholds of Significance ................................................................................................ 3.9-9

3.9.4 Project Impact Analysis ................................................................................................... 3.9-10

3.9.5 Mitigation Measures ........................................................................................................ 3.9-14

3.9.6 Conclusion ........................................................................................................................ 3.9-14

3.10 Land Use and Planning ................................................................................................................. 3.10-1

3.10.1 Existing Conditions........................................................................................................... 3.10-1

3.10.2 Regulatory Setting ........................................................................................................... 3.10-2

3.10.3 Thresholds of Significance .............................................................................................. 3.10-7

3.10.4 Project Impact Analysis ................................................................................................... 3.10-7

3.10.5 Mitigation Measures ..................................................................................................... 3.10-19

3.10.6 Conclusion ..................................................................................................................... 3.10-19

3.11 Noise .............................................................................................................................................. 3.11-1

3.11.1 Existing Conditions........................................................................................................... 3.11-1

3.11.2 Regulatory Setting ........................................................................................................... 3.11-4

3.11.3 Thresholds of Significance .............................................................................................. 3.11-8

3.11.4 Project Impact Analysis ................................................................................................ 3.11-10

3.11.5 Mitigation Measures ..................................................................................................... 3.11-16

3.11.6 Conclusion ..................................................................................................................... 3.11-16

3.12 Population and Housing ................................................................................................................ 3.12-1

3.12.1 Existing Conditions........................................................................................................... 3.12-1

3.12.2 Regulatory Setting ........................................................................................................... 3.12-3

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 TOC-iv

3.12.3 Thresholds of Significance .............................................................................................. 3.12-7

3.12.4 Project Impact Analysis ................................................................................................... 3.12-7

3.12.5 Mitigation Measures ........................................................................................................ 3.12-9

3.12.6 Conclusion ........................................................................................................................ 3.12-9

3.13 Public Services .............................................................................................................................. 3.13-1

3.13.1 Existing Conditions........................................................................................................... 3.13-1

3.13.2 Regulatory Setting ........................................................................................................... 3.13-3

3.13.3 Thresholds of Significance .............................................................................................. 3.13-7

3.13.4 Project Impact Analysis ................................................................................................... 3.13-8

3.13.5 Mitigation Measures ..................................................................................................... 3.13-11

3.13.6 Conclusion ..................................................................................................................... 3.13-11

3.14 Recreation ...................................................................................................................................... 3.14-1

3.14.1 Existing Conditions........................................................................................................... 3.14-1

3.14.2 Regulatory Setting ........................................................................................................... 3.14-3

3.14.3 Thresholds of Significance .............................................................................................. 3.14-5

3.14.4 Project Impact Analysis ................................................................................................... 3.14-6

3.14.5 Mitigation Measures ........................................................................................................ 3.14-6

3.14.6 Conclusion ........................................................................................................................ 3.14-6

3.15 Transportation ............................................................................................................................... 3.15-1

3.15.1 Existing Conditions........................................................................................................... 3.15-1

3.15.2 Regulatory Setting ........................................................................................................ 3.15-12

3.15.3 Thresholds of Significance ........................................................................................... 3.15-15

3.15.4 Project Impact Analysis ................................................................................................ 3.15-16

3.15.5 Mitigation Measures ..................................................................................................... 3.15-27

3.15.6 Conclusion ..................................................................................................................... 3.15-27

3.16 Tribal Cultural Resources .............................................................................................................. 3.16-1

3.16.1 Existing Conditions........................................................................................................... 3.16-2

3.16.2 Regulatory Setting ........................................................................................................... 3.16-3

3.16.3 Thresholds of Significance .............................................................................................. 3.16-5

3.16.4 Project Impact Analysis ................................................................................................... 3.16-6

3.16.5 Mitigation Measures ........................................................................................................ 3.16-7

3.16.6 Conclusion ........................................................................................................................ 3.16-7

3.17 Utilities and Service Systems ........................................................................................................ 3.17-1

3.17.1 Existing Conditions........................................................................................................... 3.17-2

3.17.2 Regulatory Setting ........................................................................................................... 3.17-5

3.17.3 Thresholds of Significance .............................................................................................. 3.17-9

3.17.4 Project Impact Analysis ................................................................................................... 3.17-9

3.17.5 Mitigation Measures ..................................................................................................... 3.17-16

3.17.6 Conclusion ..................................................................................................................... 3.17-16

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 TOC-v

3.18 Wildfire ........................................................................................................................................... 3.18-1

3.18.1 Existing Conditions........................................................................................................... 3.18-1

3.18.2 Regulatory Setting ........................................................................................................... 3.18-5

3.18.3 Thresholds of Significance .............................................................................................. 3.18-9

3.18.4 Project Impact Analysis ................................................................................................ 3.18-10

3.18.5 Mitigation Measures ..................................................................................................... 3.18-13

3.18.6 Conclusion ..................................................................................................................... 3.18-13

3.19 Cumulative Effects ........................................................................................................................ 3.19-1

3.19.1 Methodology ..................................................................................................................... 3.19-1

3.19.2 Cumulative Projects ......................................................................................................... 3.19-1

3.19.3 Cumulative Impact Analysis ............................................................................................ 3.19-6 4 Alternatives ....................................................................................................................................................... 4-1

4.1 Introduction to Alternatives................................................................................................................ 4-1

4.2 Project Objectives ............................................................................................................................... 4-1

4.3 Alternatives Considered But Rejected .............................................................................................. 4-2

4.3.1 Alternative Location .............................................................................................................. 4-2

4.3.2 Mitigation Bank Alternative .................................................................................................. 4-2

4.4 Project Alternatives Considered in this Environmental Impact Report ........................................... 4-3

4.4.1 Description of Alternatives ................................................................................................... 4-3

4.4.2 Summary of Significant Project Impacts ............................................................................. 4-3

4.4.3 No Project Alternative ........................................................................................................... 4-4

4.4.4 Existing Land Use Designation Alternative .......................................................................... 4-8

4.4.5 Reduced Development Footprint Alternative .................................................................... 4-14

4.4.6 Reduced Development Footprint Alternative – Vernal Pool Impact Minimization ........ 4-19

4.4.7 Reduced Pacific Specific Plan Project Alternative ............................................................ 4-26

4.5 Environmentally Superior Alternative ................................................................................................. 33 5 Environmental Effects Found Not to Be Significant ....................................................................................... 5-1

5.1 Agriculture and Forestry Resources .................................................................................................. 5-1

5.2 Mineral Resources ............................................................................................................................. 5-1 6 Other CEQA Considerations ............................................................................................................................. 6-1

6.1 Significant Unavoidable Impacts ....................................................................................................... 6-1

6.2 Growth Inducement ............................................................................................................................ 6-1

6.3 Significant Irreversible Environmental Changes ............................................................................... 6-3 7 References ....................................................................................................................................................... 7-1 8 List of Preparers ............................................................................................................................................... 8-1

8.1 City of San Marcos.............................................................................................................................. 8-1

8.2 Dudek .................................................................................................................................................. 8-1

8.3 Technical Preparers ........................................................................................................................... 8-1

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 TOC-vi

APPENDICES
A NOP, Public Scoping Comments
B Air Quality and Greenhouse Gas Technical Report
B-1 Air Quality and Greenhouse Gas Emissions Technical Memorandum for the Reduced Development Footprint Alternative – Vernal Pool Minimization
B-2 Air Quality and Greenhouse Gas Emissions Technical Memorandum for the Pacific Specific Plan Project Alternative
C Biological Resources Technical Report (Revised May 2024) C-1 Biological Technical Memorandum for the Reduced Development Footprint Alternative – Vernal Pool Minimization
C-2 Biological Technical Memorandum for the Pacific Specific Plan Project Alternative D Cultural Resources Inventory Report
D-1 Cultural Technical Memorandum for the Reduced Development Footprint Alternative – Vernal Pool Minimization
D-2 Cultural Technical Memorandum for the Pacific Specific Plan Project Alternative E Drainage Study
E-1 Drainage Study for the Reduced Development Footprint Alternative – Vernal Pool Minimization E-2 Drainage Study for the Pacific Specific Plan Project Alternative F Preliminary Geotechnical Evaluation
F-1 Geotechnical Memorandum for the Reduced Development Footprint Alternative – Vernal Pool Minimization F-2 Geotechnical Memorandum for the Pacific Specific Plan Project Alternative G Storm Water Quality Management Plan (SWQMP)
G-1 SWQMP for the Reduced Development Footprint Alternative – Vernal Pool Minimization G-2 SWQMP for the Pacific Specific Plan Project Alternative H Phase I Environmental Site Assessment
I Noise Report
I-1 Noise Technical Memorandum for the Reduced Development Footprint Alternative – Vernal Pool Minimization
I-2 Noise Technical Memorandum for the Pacific Specific Plan Project Alternative J Vehicle Miles Traveled Analysis
K Local Transportation Analysis
K-1 Local Transportation Analysis for the Reduced Development Footprint Alternative – Vernal Pool Minimization
K-2 Local Transportation Analysis for the Pacific Specific Plan Project Alternative L Sewer and Water Study
L-1 Water and Sewer Study for the Reduced Development Footprint Alternative – Vernal Pool Minimization M Pacific Specific Plan (Revised May 2024)

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N Fire Protection Plan
O Paleontological Resources Inventory Report
P Public Comments and Responses to Comments

FIGURES
2-1 Project Location ............................................................................................................................................. 2-23 2-2 Project Site and Surroundings ...................................................................................................................... 2-25 2-3a General Plan Land Use .................................................................................................................................. 2-27 2-3b Proposed General Plan Land Use ................................................................................................................. 2-29 2-4a Existing Zoning ............................................................................................................................................... 2-31 2-4b Proposed Zoning ............................................................................................................................................ 2-33 2-5 Conceptual Site Plan ...................................................................................................................................... 2-35 2-6a Villas – Renderings ........................................................................................................................................ 2-37 2-6b Rowhomes - Renderings ................................................................................................................................ 2-39 2-6c Apartments - Renderings ............................................................................................................................... 2-41 2-6d Affordable Units - Renderings ........................................................................................................................ 2-43 2-7 Cumulative Project Map ................................................................................................................................ 2-45

3.1-1 Existing Views from State Route 78 .............................................................................................................. 3-10

3.1-2 Proposed Views from State Route 78 ........................................................................................................... 3-13

3.3-1 Special-Status Plant Species ...................................................................................................................... 3.3-39

3.3-2 Special-Status Wildlife Species .................................................................................................................. 3.3-41

3.3-3 Vegetation Communities ............................................................................................................................ 3.3-43

3.3-4 Potentially Jurisdictional Wetlands and Waters ........................................................................................ 3.3-45

3.14-1 Conceptual Open Space ............................................................................................................................. 3.14-9

3.15-1 Existing Traffic Conditions ....................................................................................................................... 3.15-29

3.15-2 Conceptual Circulation ............................................................................................................................. 3.15-31 4-1 Existing Land Use Designation Alternative ................................................................................................... 4-39 4-2 Reduced Development Footprint Alternative ............................................................................................... 4-41 4-3 Reduced Development Footprint Alternative – Vernal Pool Impact Minimization ..................................... 4-43 4-4 Reduced Pacific Specific Plan Project Alternative ....................................................................................... 4-45 4-5 Project Site Plan and Alternative Comparison ............................................................................................. 4-47 TABLES
0-1 Comment Letters and Commenters................................................................................................................ 0-1 0-2 Summary of Changes to the Draft EIR ............................................................................................................ 0-2 1-1 Summary of Significant Environmental Impacts ............................................................................................ 1-2 1-2 Comparison of Impacts of Proposed Project and Alternatives ...................................................................... 1-8 2-1 Proposed Land Uses ........................................................................................................................................ 2-2

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 TOC-viii
2-2 Proposed Common Open Space ..................................................................................................................... 2-4 2-3 Proposed Private Open Space ......................................................................................................................... 2-4 2-4 Proposed Parking ............................................................................................................................................. 2-6 2-5 Required Actions and Approvals ................................................................................................................... 2-16 2-6 Cumulative Projects ....................................................................................................................................... 2-18

3.1-1 Aesthetics Summary of Impacts...................................................................................................................... 3-1

3.2-1 Air Quality Summary of Impacts ................................................................................................................... 3.2-1

3.2-2 San Diego Air Basin Attainment Classification ............................................................................................ 3.2-4

3.2-3 Local Ambient Air Quality Data ..................................................................................................................... 3.2-5

3.2-4 Ambient Air Quality Standards ................................................................................................................... 3.2-13

3.2-5 San Diego Air Pollution Control District Air Quality Significance Thresholds ................................................. 3.2-18

3.2-6 Construction Scenario Assumptions .......................................................................................................... 3.2-20

3.2-7 AERMOD Principal Parameters .................................................................................................................. 3.2-21

3.2-8 Estimated Maximum Daily Construction Emissions – Unmitigated ......................................................... 3.2-25

3.2-9 Estimated Project Maximum Daily Operational Emissions – Unmitigated .............................................. 3.2-26

3.2-10 Construction Activity Health Risk Assessment Results ............................................................................. 3.2-27

3.2-11 Estimated Maximum Daily Construction Emissions – Mitigated ............................................................. 3.2-31

3.3-1 Biological Resources Summary of Impacts ................................................................................................. 3.3-1

3.3-2 Special-Status Plant Species Observed on the Project Site ....................................................................... 3.3-4

3.3-3 Special-Status Animal Species Observed on the Project Site .................................................................... 3.3-7

3.3-4 Existing Vegetation/Habitat Types1 ............................................................................................................. 3.3-8

3.3-5 Potentially Jurisdictional Resources .......................................................................................................... 3.3-11

3.3-6 Impacts to Sensitive Natural Communities ............................................................................................... 3.3-26

3.3-7 Impacts to Potentially Jurisdictional Resources ........................................................................................ 3.3-27

3.4-1 Cultural Resources Summary of Impacts .................................................................................................... 3.4-1

3.5-1 Energy Summary of Impacts......................................................................................................................... 3.5-1

3.5-2 Project Hours of Operation for Construction Equipment .......................................................................... 3.5-13

3.5-3 Project Construction Equipment Diesel Demand ...................................................................................... 3.5-13

3.5-4 Project Construction Worker Vehicle Gasoline Demand........................................................................... 3.5-14

3.5-5 Project Construction Vendor Truck Diesel Demand .................................................................................. 3.5-14

3.5-6 Mobile Source Fuel Consumption – Operation ......................................................................................... 3.5-15

3.6-1 Geology and Soils Summary of Impacts ...................................................................................................... 3.6-1

3.7-1 Greenhouse Gas Emissions Summary of Impacts ...................................................................................... 3.7-1

3.7-2 Greenhouse Gas Emissions Sources in California ...................................................................................... 3.7-5

3.7-3 Construction Scenario Assumptions – Existing Land Use Designation ................................................... 3.7-21

3.7-4 Estimated Annual Construction GHG Emissions – Existing Land Use Designation ............................... 3.7-25

3.7-5 Estimated Annual Operational GHG Emissions – Existing Industrial Land Use Designation ................. 3.7-26

3.7-6 Estimated Annual Construction GHG Emissions – Proposed Project ...................................................... 3.7-26

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3.7-7 Estimated Annual Operational GHG Emissions – Proposed Project ........................................................ 3.7-27

3.8-1 Hazards and Hazardous Materials Summary of Impacts ........................................................................... 3.8-1

3.8-2 Environmental Database .............................................................................................................................. 3.8-4

3.8-3 EnviroStor Database Site.............................................................................................................................. 3.8-6

3.9-1 Hydrology and Water Quality Summary of Impacts ..................................................................................... 3.9-1

3.10-1 Land Use Summary of Impacts .................................................................................................................. 3.10-1

3.10-2 General Plan Consistency ........................................................................................................................... 3.10-8

3.11-1 Noise Summary of Impacts ........................................................................................................................ 3.11-1

3.11-2 Measured Baseline Outdoor Ambient Noise Levels .................................................................................. 3.11-3

3.11-3 Exterior Noise Standards by Zone .............................................................................................................. 3.11-6

3.11-4 Permitted Increase in Noise Levels ........................................................................................................... 3.11-7

3.11-5 Permitted Increase in Interior Noise Levels .............................................................................................. 3.11-7

3.11-6 Typical Construction Equipment Maximum Noise Levels ...................................................................... 3.11-10

3.11-7 Estimated Distances between Construction Activities and the Nearest Noise-Sensitive Receptors ....................................................................................................................... 3.11-11

3.11-8 Predicted Construction Noise Levels per Activity Phase ....................................................................... 3.11-11

3.11-9 Roadway Traffic Noise Modeling Results ............................................................................................... 3.11-13

3.11-10 Predicted Net Sound Transmission Class of Occupied Room Façade ................................................. 3.11-14

3.12-1 Population and Housing Summary of Impacts .......................................................................................... 3.12-1

3.12-2 Forecasted Growth for the San Diego Region and the City of San Marcos ............................................. 3.12-5

3.13-1 Public Services Summary of Impacts ......................................................................................................... 3.13-1

3.14-1 Recreation Summary of Impacts ................................................................................................................ 3.14-1

3.15-1 Transportation Summary of Impacts ......................................................................................................... 3.15-1

3.15-2 Existing Traffic Volumes .............................................................................................................................. 3.15-5

3.15-3 Existing Intersection Operations ................................................................................................................ 3.15-8

3.15-4 Existing Intersection Queuing .................................................................................................................. 3.15-10

3.15-5 Existing Street Segment Operations ....................................................................................................... 3.15-11

3.15-6 Proposed Project Trip Generation ........................................................................................................... 3.15-16

3.15-7 Project VMT Findings ............................................................................................................................... 3.15-25

3.16-1 Tribal Cultural Resources Summary of Impacts ........................................................................................ 3.16-1

3.17-1 Utilities and Service Systems Summary of Impacts .................................................................................. 3.17-1

3.17-2 MWD Water Demands ................................................................................................................................ 3.17-2

3.18-1 Wildfire Summary of Impacts ..................................................................................................................... 3.18-1

3.18-2 SMFD Responding Stations ........................................................................................................................ 3.18-5

3.19-1 Cumulative Projects .................................................................................................................................... 3.19-2 4-1 Comparison of Impacts of Proposed Project and Alternatives .................................................................... 4-34 4-2 Comparison of Components of Proposed Project and Alternatives ............................................................ 4-35 4-3 Comparison of Biological Resource Impacts by Project Alternative ........................................................... 4-36

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 ACR-i
Acronyms and Abbreviations
Acronym/Abbreviation Definition
g/m3 micrograms per cubic meter
AB Assembly Bill
ACC air-cooled condensing
ADT average daily traffic volumes
AERMOD American Meteorological Society/EPA Regulatory Model AFY acre-feet per year
ANSI American National Standards Institute
APE area of potential effect
BMP best management practice
BTR Biological Resources Technical Report
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAL FIRE California Department of Forestry and Fire Protection CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards
CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CARB California Air Resources Board
CBC California Building Code
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CFC chlorofluorocarbons
CFC California Fire Code
CFGC California Fish and Game Code
CH4 methane
CMP Congestion Management Program
CNEL community noise equivalent level
CNPS California Native Plant Society
CNRA California Natural Resources Agency
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission
CRHR California Register of Historic Resources
CRPR California Rare Plant Rank
CWA Clean Water Act
dB decibel

ACRONYMS AND ABBREVIATIONS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 ACR-ii
Acronym/Abbreviation Definition
dBA A-weighted decibel
DPM diesel particulate matter
DU/acre dwelling unit per acre
DWR Department of Water Resources
EDCO EDCO Waste and Recycling
EIR environmental impact report
EISA Energy Independence and Security Act of 2007
EO Executive Order
EOP Emergency Operations Plan
EPA Environmental Protection Agency
ERNS Emergency Response Notification System
ESA Environmental Site Assessment
ESA Endangered Species Act
FAA Federal Aviation Administration
FAR Floor area ratio
FEMA Federal Emergency Management Agency
FPP Fire Protection Plan
g/L grams per liter
GHG greenhouse gas
GPA General Plan Amendment
GWP global warming potential
HCFC hydrochlorofluorocarbon
HELIX HELIX Environmental Planning, Inc
HFC hydrofluorocarbon
HMMP Habitat Mitigation Monitoring Plan
HRA health risk assessment
HAS Hydrologic Subarea
I Interstate
IBC International Building Code
IFC International Fire Code
IPCC Intergovernmental Panel on Climate Change
ips inches per second
ISTEA Intermodal Surface Transportation Efficiency Act of 1991 ITP Incidental Take Permit
kV kilovolt
kWh kilowatt-hours
LCFS Low Carbon Fuel Standard
Ldn day–night average noise level
Leq equivalent noise level over a given period
LID low impact development
LLG Linscott, Law & Greenspan Engineers
Lmax maximum sound level
LOS Level of Service

ACRONYMS AND ABBREVIATIONS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 ACR-iii
Acronym/Abbreviation Definition
LTA Local Transportation Analysis
LTPP Long-Term Procurement Plan
LUST Leaking Underground Storage Tank
MBTA Migratory Bird Treaty Act
MGD million gallons per day
MHCP Multiple Habitat Conservation Program
MM Mitigation Measure
MMT million metric tons
MRF Meadowlark Water Reclamation Facility
MRZ Mineral Resource Zone
MS4 municipal separate storm sewer system
msl mean sea level
MT metric ton
MWD Metropolitan Water District of Southern California
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Communities Conservation Planning
NCTD North County Transit District
NEPA National Environmental Policy Act
NEV neighborhood electric vehicle
NHTSA National Highway Traffic Safety Administration
NO2 nitrogen dioxide
NOP Notice of Preparation
NOx oxides of nitrogen
NPDES National Pollutant Discharge Elimination System
NPL National Priority List
NRHP National Register of Historic Places
O3 ozone
PAR Property Analysis Record
PFC perfluorocarbon
PFF Public Facility Fee
PM particulate matter
PM10 coarse particulate matter
PM2.5 fine particulate matter
PMP Preserve Management Plan
ppm parts per million
PPV peak particle velocity
PRC California Public Resources Code
PRIMP Paleontological Resources Impact Mitigation Program RAQS Regional Air Quality Strategy
RCRA Resource Conservation and Recovery Act
RFS Renewable Fuel Standard

ACRONYMS AND ABBREVIATIONS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 ACR-iv
Acronym/Abbreviation Definition
RHNA Regional Housing Need Allocation
RPS Renewables Portfolio Standard
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SAFE Safer Affordable Fuel-Efficient
SANDAG San Diego Association of Governments
SB Senate Bill
SCAQMD South Coast Air Quality Management District
SCIC South Coastal Information Center
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCWA San Diego County Water Authority
SDG&E San Diego Gas & Electric
SDNHM Natural History Museum of San Diego
SEMS Superfund Enterprise Management System
SF6 sulfur hexafluoride
SIP California State Implementation Plan
SLF Sacred Lands File
SMFD San Marcos Fire Department
SMMC San Marcos Municipal Code
SMUSD San Marcos Unified School District
SO2 sulfur dioxide
SoCalGas Southern California Gas
SOx sulfur oxides
SPA Specific Plan Area
SPL sound pressure level
SR State Route
ST short-term
STC sound transmission class
SWAT Solid Waste Assessment Test
SWF/LF Solid Waste Fill/Landfill
SWPPP stormwater pollution prevention plan
SWQMP Storm Water Quality Management Plan
SWRCB State Water Resources Control Board
SWRCY Solid Waste Recycling Facilities
TAC toxic air contaminant
TCA Tribe Traditionally and Culturally Affiliated Native American Tribe TCR tribal cultural resource
TDM Transportation Demand Management
TMDL total maximum daily load
TWLT two-way left-turn
USACE U.S. Army Corps of Engineers

ACRONYMS AND ABBREVIATIONS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 ACR-v
Acronym/Abbreviation Definition
USFWS U.S. Fish and Wildlife Service
UST underground storage tank
UWMP Urban Water Management Plan
V/C volume to capacity
VFD Vista Fire Department
VMT Vehicle Miles Traveled
VOC volatile organic compound
VPMP Vernal Pool Mitigation Plan
VWD Vallecitos Water District
WMUDS Waste Management Unit Database System
WQIP Water Quality Improvement Plan
ZEV zero-emission vehicle

ACRONYMS AND ABBREVIATIONS
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 ACR-vi

INTENTIONALLY LEFT BLANK

FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 0-1
0 Final EIR Introduction
The Draft Environmental Impact Report (EIR) was circulated for public review from March 2, 2023, through April 17, 2023, in accordance with Section 15105(a) of the CEQA Guidelines. A total of eight (8) written comment letters were received on the Draft EIR from agencies and organizations, as shown in Table 0-1. Appendix P, which includes both public comment letters and responses to each comment letter received, has been included as part of the Final EIR.

Each of the written comment letters have been assigned an alphanumeric label, and the individual comments within each written comment letter are bracketed and numbered. For example, Comment Letter A1 contains one comment that is numbered A1-1.

The responses to each comment on the Draft EIR represent a good -faith, reasoned effort to address the environmental issues identified by the comment s. Under the CEQA Guidelines, the City, as lead agency, is not required to respond to all comments on the Draft EIR, but only those comments that raise environmental issues. In accordance with CEQA Guidelines Sections 15088 and 15204, the City has independe ntly evaluated the comments and prepared written responses describing the disposition of any significant en vironmental issues raised (see Appendix P to the Final EIR). CEQA does not require the City to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters.

Table 0-1. Comment Letters and Commenters
Comment Letter Commenter
Agencies
A1 City of Carlsbad Public Works Branch/Transportation Department A2 US Department of Fish and Wildlife
A3 California Department of Fish and Wildlife
A4 California Department of Transportation
Organizations
O1 San Diego County Archaeological Society, Inc.

O2 California Native Plant Society
O3 Southwest Mountain States Regional Council of Carpenters Individuals
I1 Leslie Kuhn

Changes have been made to the Final EIR in strikeout/underline format in response to comments and to provide updates and clarifications to information provided in the Draft EIR . Consistent with CEQA Guidelines Section 15088.5(b), these revisions have been made to clarify text for consistency or revise punctuation as appropriate throughout the document, and these revisions do not result in new significant information that would require recirculation of the document.

Revisions made throughout the Final EIR are in response to input from agencies and stakeholders as provided in the comments to the Draft EIR. Additional alternatives, including the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization, and the Reduced Pacific Specific Plan Alternative have been incorporated as part of the Final EIR in response to the Wildlife Agencies comments and requests. These additional alternatives included as part of the Final EIR do not significantly differ from the original project or the alternatives analyzed in the Draft EIR. 0 – FINAL EIR INTRODUCTION
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 0-2
Table 0-2 summarizes changes made to the EIR, by EIR chapter and section, and shows original text included and proposed changes to the text.

Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
Introduction (new chapter)
Executive Summary
Section 1.2,

Implementation of MM-BIO-7a, MM-BIO-
7b and MM-BIO-7c, refer to Section 3.3.5.

Implementation of MM-BIO-7a and MM-BIO-7b
and MM-BIO-7c, refer to Section 3.3.5.

Section 1.5.4,

1-6
N/A 1.5.4 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. Under the Reduced
Development Footprint Alternative – Vernal
Pool Impact Minimization, development would
occur 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).

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).
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
Section 1.5.5,

N/A 1.5.5 Reduced Pacific Specific Plan Project
Alternative
In response to comments received from
USFWS 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 (this
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. This 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).

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).

Section 1.5.6,

1-7

1.5.4 Environmentally Superior Alternative 1.5.64 Environmentally Superior Alternative 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.

Of the alternatives identified to reduce
potential environmental impacts compared to
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 0-4
Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
the proposed project, the Reduced
Development Footprint Alternative – Vernal
Pool Impact Minimization would be considered
the environmentally superior alternative to the
proposed 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. Whenwhen comparing
impacts to biological resources, the proposed
project and The 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
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
listed special-status animals. Additionally, this
alternative would avoid all features occupied
by San Diego fairy shrimp.

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.

Section 1.5.6,

Table 1-2. Comparison of Impacts of
Proposed Project and Alternatives
Table 1-2. Comparison of Impacts of Proposed
Project and Alternatives (new columns for the
Reduced Development Footprint Alternative –
Vernal Pool Impact Minimization, and
Reduced Pacific Specific Plan Project
Alternative have been added to this Table 1-2)
Project Description
Section 2.2.2,

3. At the intersection of 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
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.

3. At the intersection of 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 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.

Section 2.2.2,

4. At the intersection of Las Posas
Road/Linda Vista Drive, in conjunction
with the Urban Trail to be provided on
Linda Vista Drive and to align with the
proposed cross-section of Linda Vista
Drive between Pacific Street and Las
Posas Road the existing shared
through/right-turn lane on the westbound
approach will be converted to right turn
only.

4. At the intersection of Las Posas Road/Linda
Vista Drive, inIn conjunction with the Urban
Trail to be provided on Linda Vista Drive. And
to align the intersection of Las Posas
Road/Linda Vista Drive 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.
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
Section 2.3.4,

(Fire Protection)
The SMFD operates two Fire Stations
(Stations 1 and 3) that would respond to
an incident at the proposed project site.
(Fire Protection)
The SMFD operates two Fire Stations (Stations
1 and 23) that would respond to an incident at
the proposed project site.

Section 2.4.4,

Once the 45-day public review period has
concluded, the City will review all public
comments on the Draft EIR and provide a
written response to all written comments
pertaining to environmental issues as part
of the Final EIR. The Final EIR will include
all written comments received during the
public review period, responses to
comments, and, if applicable, edits and
errata made to the Draft EIR. The City will
then consider certification of the Final EIR
(14 CCR 15090). If the EIR is certified, the
City may consider project approval (14
CCR 15092).

Once the 45-day public review period has
concluded, the City will review all public
comments on the Draft EIR and provide a
written response to all written comments
pertaining to environmental issues as part of
the Final EIR. This Final EIR includes all written
comments received during the public review
period, responses to comments, and, if
applicable, edits and errata made to the Draft
EIR. The City will then consider certification of
the Final EIR (14 CCR 15090). If the EIR is
certified, the City may consider project
approval (14 CCR 15092).

The Draft Environmental Impact Report (EIR)
was circulated for public review from March 2,
2023, through April 17, 2023, in accordance
with Section 15105(a) of the CEQA Guidelines.

A total of eight (8) written comment letters
were received on the Draft EIR from agencies
and organizations, as shown in Table 0-1 in
Chapter 0, Introduction, of the Final EIR.

Appendix P, which includes both public
comment letters and responses to each
comment letter received, has been included
as part of the Final EIR.

Biological Resources
Section 3.3,

This section is based on the Draft
Biological Resources Technical Report
(BTR) prepared by HELIX Environmental
Planning Inc. (HELIX) in January 2023,
which is included as Appendix C to this
environmental impact report (EIR).

This section is based on the Draft Biological
Resources Technical Report (BTR) prepared by
HELIX Environmental Planning Inc. (HELIX) in
January 2023 (revised May 2024), which is
included as Appendix C to this environmental
impact report (EIR).

Section 3.3.5,

Direct impacts to this species could also
occur if appropriate avoidance and
minimization measures are not
implemented, including measures
proposed for potential indirect impacts on
other sensitive species, such as: the
installation of temporary construction
and/or silt fencing at the limits of work
(MM-BIO-5), biological construction
monitoring where work limits occur
adjacent to known sensitive resources
(MM-BIO-6), and long-term protection and
Direct impacts to this species could also occur
if appropriate avoidance and minimization
measures are not implemented, including
measures proposed for potential indirect
impacts on other sensitive species, such as:
the installation of temporary construction
and/or silt fencing at the limits of work (MM-
BIO-5), biological construction monitoring
where work limits occur adjacent to known
sensitive resources (MM-BIO-6), and long-term
protection and management of avoided
resources through the implementation of a
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
management of avoided resources
through the implementation of a PMP
(MM-BIO-3, MM-BIO-7b and MM-BIO-7c).

PMP (MM-BIO-3, MM-BIO-7ab and
MM-BIO-7bc).

Section 3.3.6,

and 3.3-31
(MM-BIO-1)
Rare Plant Transplant Plan. Prior to
issuance of land disturbance, clearing,
grubbing, or grading permits for the
project site, the project Applicant shall
submit a rare plant transplant plan to the
City and resource agencies (USFWS and
CDFW) regarding transplanting and
monitoring of special-status plants: San
Diego button-celery, Orcutt’s brodiaea,
and thread leaved brodiaea. The
transplant plan shall include, at minimum,
methods for plant salvage,
seed/bulb/corm collection,
transplantation, relocation, performance
standards, and maintenance and
monitoring (5 years) to provide for no loss
of these plant species and to achieve
establishment success. Overall, San Diego
button-celery, Orcutt’s brodiaea, and
thread-leaved brodiaea shall be
translocated and/or replanted through
propagation into existing suitable habitat
in the on-site open space preserve near
existing populations of these species and
according to the conceptual mitigation
plan for the project (refer to Figure 15,
Conceptual Mitigation Plan, in the
Biological Resources Technical Report
prepared for the project). The planting of
these species shall also be incorporated,
as applicable, into the revegetation
palettes discussed in the Vernal Pools
Mitigation Plan (MM-BIO-2). The
transplant plan shall be approved by the
City and resource agencies, and will meet
currently accepted standards for sensitive
species translocation. Contingency
measures, in case performance standards
are not met after 5 years, shall be
included in the plan to ensure success
(i.e., no loss of these plant species) is
achieved. Resource Agency verification
that transplant plan success criteria has
been met is required for the completion of
this measure. In addition to the transplant
plan, a cost estimate to implement the
plan shall be provided to the City and
resource agencies for approval and the
Rare Plant Transplant Plan. Prior to the
issuance of land disturbance, clearing,
grubbing, or grading permits for the project
site, the project Applicant or Developer shall
submit a rare plant transplant plan to the City
and resource agencies (USFWS and CDFW)
regarding transplanting and monitoring of
special-status plants to be impacted by the
project: San Diego button-celery, Orcutt’s
brodiaea, and thread leaved brodiaea. The
transplant plan shall be approved by the City
and resource agencies prior to implementation
and prior to issuance of clearing, grubbing,
other land disturbance, or grading permits
related to the project. The transplant plan
shall meet currently accepted standards for
sensitive plant species translocation and
include, at minimum, methods for plant
salvage, seed/bulb/corm collection,
transplantation, relocation, performance
standards, and maintenance and monitoring
to achieve establishment success. San Diego
button-celery, Orcutt’s brodiaea, and thread-
leaved brodiaea to be impacted shall be
translocated and/or replanted through
propagation on-site as specified in the
approved rare plant transplant plan. Resource
Agencies may require the rare plant transplant
plan also include off-site translocation or
replanting at one of several candidate sites in
the City having appropriate soils and habitat
for these species. Contingency or remedial
measures shall also be included in the
approved transplant plan to ensure
performance standards are achieved. Such
measures may include supplemental seeding
or transplantation of nursery grown plants,
replacing dead plants, improving weed control,
or other adaptive management techniques
required by the resource agencies. Resource
agency verification that transplant plan
performance standards have been met is
required for the completion of this measure.

In addition to the transplant plan, a cost
estimate to implement the plan shall be
provided to and approved by the City and
resource agencies. Prior to implementation,
transplantation and monitoring in accordance
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
project Applicant shall post/secure a bond
in the amount of 120% of the approved
cost estimate for financial assurance of
the plan prior to any clearing, grubbing,
grading or other land disturbance related
to the project.
with the rare plant transplant plan shall be
fully funded by the Applicant or Developer via
an endowment or other funding mechanism,
as approved by the City and pertinent permit-
issuing resource agencies.

Section 3.3.6,

and 3.3-32
(MM-BIO-2)
Vernal Pools Mitigation Plan. Prior to
any land disturbance, clearing, grubbing,
or grading permits for the project site, the
project Applicant shall submit a Vernal
Pool Mitigation Plan (VPMP) to the City
and resource agencies, describing the
creation, re-establishment, and/or
restoration, as well as maintenance and
monitoring (5 years) of vernal pools in the
mitigation plan. Vernal pool mitigation
shall occur on-site within appropriate
suitable habitat in the on-site open space
preserve, according to the conceptual
mitigation plan for the project. The VPMP
shall include, at minimum, restoration
methods, performance standards, and
contingency measures if performance
standards are not met. Vernal pool
mitigation areas shall require agency sign-
off after successful completion. If impacts
to vernal pools occupied by listed San
Diego fairy shrimp cannot be fully avoided,
a consultation shall occur with USFWS to
obtain take authorization pursuant to the
federal ESA and as described in mitigation
measure BIO-3. Measures required by
USFWS as a result of consultation shall be
implemented, which may include
preparation and implementation of a
resource salvage plan and translocation
of cysts by inoculation into existing
suitable habitat within approved preserve
areas or into created or restored habitat
on-site. Suitable habitat is located within
existing depressions (found not occupied)
near existing vernal pools to be preserved
on-site, which is located within the Vernal
Pool Major Amendment Area in the City’s
Draft Subarea Plan. Ultimately, the VPMP
shall be approved by the City and
resource agencies. In addition to the
VPMP, a cost estimate to implement the
plan shall be provided to the City and
resource agencies for approval and the
project Applicant shall post/secure a bond
Vernal Pools Mitigation Plan. Prior to
issuance of land disturbance, clearing,
grubbing, or grading permits for the project
site, the project Applicant or Developer shall
submit a Vernal Pool Mitigation Plan (VPMP) to
the City and applicable permit-issuing resource
agency (i.e. USFWS, USACE, RWQCB, and/or
CDFW) describing vernal pool creation,
expansion, and/or restoration, as well as
maintenance and monitoring of such vernal
pools. The VPMP shall be approved by the City
and permit-issuing resource agency prior to
implementation and prior to issuance of
clearing, grubbing, other land disturbance, or
grading permits related to the project. The
proposed distribution of the vernal pool
mitigation herein shall be on-site as specified
in the approved VPMP. The VPMP shall
include, at minimum, creation and restoration
methods, performance standards,
maintenance and monitoring, and contingency
measures if performance standards are not
met. Agency sign-off, as applicable per the
regulatory permit(s) issued for the project,
shall be required for verification that VPMP
criteria has been met and for completion of
this measure. If impacts to vernal pools
occupied by listed San Diego fairy shrimp
cannot be fully avoided, prior to impacts, a
consultation shall be completed with USFWS
to obtain take authorization pursuant to the
federal ESA and as described in mitigation
measure BIO-3. Measures required by USFWS
as a result of consultation shall be
implemented, which may include preparation
and implementation of a resource salvage
plan and translocation of cysts by inoculation
into suitable habitat within approved preserve
areas or into created or restored habitat.

Suitable habitat is located on-site within
existing depressions (found not occupied) near
existing vernal pools to be preserved on-site,
all of which is located within the Vernal Pool
Major Amendment Area in the City’s Draft
Subarea Plan. In addition to the VPMP, a cost
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
in the amount of 120% of the approved
cost estimate for financial assurance of
the plan prior to any clearing, grubbing,
grading or other land disturbance related
to the project.
estimate to implement the plan shall be
provided to and approved by the City and
pertinent resource agencies. Implementation
and monitoring per VPMP plan shall be fully
funded by the Applicant or Developer via an
endowment or other funding mechanism, as
approved by the City and pertinent resource
agencies.

Section 3.3.6,

(MM-BIO-3)
Listed Species Conservation Measures.

Prior to issuance of any land disturbance,
clearing, grubbing, or grading permits for
the project site, the project Applicant shall
demonstrate to the City that consultation
with USFWS for adverse effects to San
Diego Fairy shrimp, thread leaved
brodiaea, and San Diego button celery
has occurred in accordance with Section
7 or Section 10 of the federal ESA, as
applicable. Impacts to San Diego button
celery and thread leaved brodiaea shall
also require either a Section 2080.1
Consistency Determination or a Section
2081(b) Incidental Take Permit, according
to the federal action, or demonstrate to
the City that none was required. Impacts
to habitat occupied by these listed
species shall be compensated by the
implementation of habitat-based
mitigation via an HMMP and long-term
conservation and management via a PMP
(see mitigation measures MM-BIO-7a and
MM-BIO-7b).

Listed Species Conservation Measures.

Prior to issuance of any land disturbance,
clearing, grubbing, or grading permits for the
project site, the project Applicant or Developer
shall demonstrate to the City that consultation
with USFWS for adverse effects to San Diego
Fairy shrimp, thread leaved brodiaea, and San
Diego button celery has occurred in
accordance with Section 7 or Section 10 of
the federal ESA, as applicable. Impacts to San
Diego button celery and thread leaved
brodiaea shall also require either a Section
2080.1 Consistency Determination or a
Section 2081(b) Incidental Take Permit from
CDFW, according to the federal action, or
demonstrate to the City that none was
required by CDFW. Impacts to habitat
occupied by these listed species shall be
compensated by the implementation of
habitat-based mitigation via an HMMP and
long-term conservation and management via a
PMP (see mitigation measures MM-BIO-7a and
MM-BIO-7b).

Section 3.3.6,

(MM-BIO-5)
Construction Work Limits Fencing. Prior
to any clearing, grubbing, or issuance of
grading permits for the project site, it shall
be demonstrated to the City that the
approved grading boundaries and limits of
work are presented on the Final
Construction Drawings, including the
limits of work fencing. To help ensure
inadvertent/unauthorized impacts to
environmentally sensitive areas outside of
the approved limits of work footprint are
avoided, temporary construction fencing
(orange fencing or similar), including silt
fencing as appropriate, shall be installed
at the edges of the approved impact
limits. This fencing shall be installed prior
to construction and maintained for the
duration of construction activity. Fencing
Construction Work Limits Fencing. Prior to
any the issuance of land disturbance, clearing,
grubbing, or issuance of grading permits for
the project site, it the Applicant or Developer
shall be demonstrated to the City that the
approved grading boundaries and limits of
work are presented on the Final Construction
Drawings, including the limits of work fencing.

To help ensure inadvertent/unauthorized
impacts to environmentally sensitive areas
outside of the approved limits of work footprint
are avoided, temporary construction fencing
(orange fencing or similar), including silt
fencing as appropriate, shall be installed at
the edges of the approved impact limits. This
fencing shall be installed prior to construction
and maintained for the duration of
construction activity. Fencing shall be installed
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Section Original Text Proposed Change (s)
shall be installed in a manner that does
not impact sensitive species or habitats to
be avoided. Prior to installation, a
qualified biologist shall survey the fencing
location to inspect that the fencing
alignment is consistent with the Final
Construction Drawings and to verify no
special-status plant species occur within
the fencing installation location. If special-
status plants are detected, the fencing
alignment shall be adjusted to avoid those
plant individuals, or such plants shall be
relocated into the project preserve areas
to avoid their impact as a result of fence
installation. Once the fencing is installed,
the City and project biologist (see MM BIO-
6) shall determine the need for additional
inspections and monitoring activities
throughout the duration of construction. If
work occurs beyond the fenced or
demarcated limits of impact, work in the
affected areas shall cease until the
problem has been remedied and
mitigation identified satisfactory to the
City and qualified biologist. All temporary
construction fencing shall be removed
upon completion of construction.
in a manner that does not impact sensitive
species or habitats to be avoided. Prior to
installation, a qualified biologist shall survey
the fencing location to inspect that the fencing
alignment is consistent with the Final
Construction Drawings and to verify no special-
status plant species occur within the fencing
installation location. If special-status plants
are detected, the fencing alignment shall be
adjusted to avoid those plant individuals, or
such plants shall be relocated into the project
preserve areas to avoid their impact as a
result of fence installation. Once the fencing is
installed, the City and project biologist (see
MM BIO-6) shall determine the need for
additional inspections and monitoring
activities throughout the duration of
construction. If work occurs beyond the fenced
or demarcated limits of impact, work in the
affected areas shall cease until the problem
has been remedied and mitigation identified
satisfactory to the City and qualified biologist.

All temporary construction fencing shall be
removed upon completion of construction.

Section 3.3.6,

(MM-BIO-6)
Biological Construction Monitoring.

Prior to grading, the project Applicant shall
demonstrate to the City that a qualified
biologist has been retained to monitor
construction activities, including
monitoring of the temporary work/impact
limits fencing installation (see MM-BIO-5),
which clearly delineates the edge of the
approved work limits and the edges of
environmentally sensitive areas that occur
beyond the approved limits. The qualified
biologist shall conduct a preconstruction
environmental training session for
construction personnel to inform them of
the sensitive biological resources in the
local area and the avoidance measures in
place to remain in compliance. The
monitoring, at minimum, shall include
inspection of construction work areas,
including staging and storage areas, to
confirm that activities are kept within the
approved limits and that Best
Management Practices are in place. The
biologist shall regularly monitor
Biological Construction Monitoring. Prior to
any clearing, grubbing, or issuance of grading
permits for the project site grading, the project
Applicant or Developer shall demonstrate to
the City that a qualified biologist has been
retained to monitor construction activities,
including monitoring of the temporary
work/impact limits fencing installation (see
MM-BIO-5), which clearly delineates the edge
of the approved work limits and the edges of
environmentally sensitive areas that occur
beyond the approved limits. The qualified
biologist shall conduct a preconstruction
environmental training session for
construction personnel to inform them of the
sensitive biological resources in the local area
and the avoidance measures in place to
remain in compliance. The monitoring, at
minimum, shall include inspection of
construction work areas, including staging and
storage areas, to confirm that activities are
kept within the approved limits and that Best
Management Practices are in place. The
biologist shall regularly monitor construction
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Section Original Text Proposed Change (s)
construction activities throughout
construction. If items of non-compliance
are identified, the biologist shall notify the
on-site construction superintendent
immediately to discuss and implement
corrective actions. Issues of non-
compliance that result in additional
impacts to sensitive biological resources
shall be documented and provided to the
City within 72 hours of identification.

Mitigation for unauthorized impacts shall
adhere to the applicable measures in the
Biological Resources Technical Report
prepared for the project.
activities throughout construction. If items of
non-compliance are identified, the biologist
shall notify the on-site construction
superintendent immediately to discuss and
implement corrective actions. Issues of non-
compliance that result in additional impacts to
sensitive biological resources shall be
documented and provided to the City within 72
hours of identification. Mitigation for
unauthorized impacts shall adhere to the
applicable measures in the Biological
Resources Technical Report prepared for the
project.

Section 3.3.6,

(MM-BIO-7a)
Compensatory Mitigation for Impacts
to Sensitive Natural Communities. The
proposed project shall compensate for
impacts to sensitive natural communities
(i.e., Diegan coastal sage scrub, native
grassland, non-native grassland, mixed
grassland, and vernal pools) according to
the ratios provided in Table 3.3-8 below.

Mitigation shall not occur at levels below
the ratios described in Table 3.3-7 unless
otherwise conditioned in permits and/or
discretionary approvals issued by USFWS,
USACE, RWQCB, and/or CDFW, as
applicable.

Compensatory Mitigation for Impacts to
Sensitive Natural Communities. Impacts to
sensitive natural communities (e.g., Diegan
coastal sage scrub, native grassland, non-
native grassland, mixed grassland, and vernal
pools) as a result of project implementation
shall be mitigated per the following ratios. A
3:1 mitigation ratio shall be provided for
impacts to vernal pools (minimum 1:1
creation/expansion), a 2:1 ratio for impacts to
native grassland (including disturbed), a 1:1
ratio for Diegan coastal sage scrub (including
disturbed and Baccharis dominated), a 0.5:1
ratio for impacts to mixed grassland (including
disturbed), and a 0.5:1 ratio for impacts to
non-native grassland. Mitigation shall not
occur at levels below these ratios unless
otherwise conditioned in permits or
discretionary approvals issued by the City
and/or applicable permit-issuing resource
agency (USFWS, USACE, RWQCB, and/or
CDFW). The mitigation to sensitive natural
communities shall be implemented per MM-
BIO-7b.
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Section Original Text Proposed Change (s)
Section 3.3.6,

through 3.3-36
(MM-BIO-7b)
Compensatory Mitigation for
Permanent Impacts to Sensitive Natural
Communities. Prior to issuance of and
land disturbance, clearing, grubbing, or
grading permits for the proposed project,
the Applicant shall demonstrate to the City
that compensatory mitigation for direct
permanent impacts to sensitive natural
communities (i.e., Diegan coastal sage
scrub, native grassland, non-native
grassland, mixed grassland, and vernal
pools) has been adequately proposed in
accordance with the ratios described in
mitigation measure MM-BIO-7a and
secured through one or a combination of
the following mechanisms:

Implementation of on-site and/or off-site
habitat preservation, creation, restoration,
and/or enhancement
Purchase of off-site conservation credits
from a conservation bank in the region
(such as Brook Forest Mitigation Bank,
Cleveland Corridor Conservation Bank,
Heights of Pala Mesa Conservation Bank,
Manchester Avenue Conservation Bank,
Ramona Grasslands Conservation Bank,
Red Mountain Conservation Bank, or
another location deemed acceptable by
the City).

Compensatory mitigation proposed on-
and/or off-site through habitat
establishment, re-establishment, and/or
restoration areas shall be required to
prepare and implement a Habitat
Mitigation Monitoring Plan (HMMP) and a
Preserve Management Plan (PMP), which
shall be subject to City review and
approval prior to issuance of any permits
for the proposed project. Because the rare
plant transplant plan and vernal pools
mitigation plan (see Bio-1 and Bio-2
above) ultimately prescribes actions
resulting in grasslands and vernal pools
establishment, re-establishment, and/or
restoration, such plans shall suffice as the
HMMP provided the pertinent information
prescribed below is incorporated.

Compensatory Mitigation for Permanent
Impacts to Sensitive Natural Communities.

Prior to the issuance of land disturbance,
clearing, grubbing, or grading permits for the
project site, the Applicant or Developer shall
demonstrate to the satisfaction of the City,
and applicable permit-issuing agency (i.e.

USFWS, USACE, RWQCB, and/or CDFW) that
compensatory mitigation for direct permanent
impacts to sensitive natural communities (e.g.,
Diegan coastal sage scrub, native grassland,
non-native grassland, mixed grassland, and
vernal pools) has been adequately provided in
accordance with the ratios described in
mitigation measure MM-BIO-7a and secured
through one or a combination of the following
mechanisms:
▪ Implementation of on-site and/or off-site
habitat preservation, creation/expansion,
restoration, and/or enhancement; or
▪ Purchase of off-site conservation credits
from a conservation bank in the region
(such as Brook Forest Mitigation Bank,
Cleveland Corridor Conservation Bank,
Heights of Pala Mesa Conservation Bank,
Manchester Avenue Conservation Bank,
Ramona Grasslands Conservation Bank,
Red Mountain Conservation Bank, or
another location deemed acceptable by
the City).

Prior to issuance of any land disturbance,
clearing, grubbing, or issuance of grading
permits for the site, compensatory mitigation
areas proposed on- and/or off-site through
habitat creation/expansion, enhancement,
and/or restoration shall be required to prepare
and implement a Habitat Mitigation Monitoring
Plan (HMMP) and a Preserve Management
Plan (PMP), which shall be subject to City and
applicable permit-issuing resource agency (i.e.,
USFWS, USACE, RWQCB, and/or CDFW) review
and approval prior to the issuance of any
permits for the proposed project. Because the
rare plant transplant plan and vernal pool
mitigation plan (see MM-BIO-1 and MM-BIO-2
above) ultimately prescribes actions resulting
in grasslands and vernal pools establishment,
re-establishment, and/or restoration, such
plans shall suffice as the HMMP provided the
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Section Original Text Proposed Change (s)
The HMMP shall prescribe the on-/off-site
mitigation actions of creation/
establishment, re-establishment,
restoration, and/or preservation. The
HMMP shall include discussion on the
location of any creation/establishment,
re-establishment, restoration, and/or
preservation site(s); requirements for site
preparation, soil amendments, temporary
irrigation, native plant palettes,
installation methods, maintenance, and
performance monitoring, as appropriate.

The HMMP shall include graceful tarplant
into the native habitat planting seed
palette, where appropriate. The HMMP
shall also include information pertaining
to any specific rare plant translocation
plans (see MM-BIO-1) or vernal pool
resources mitigation plans (see MM-BIO-
2) as applicable. The HMMP shall require
that all mitigation (except for preservation
areas not restored) be subject to a
minimum 5-year performance monitoring
period with specific success criteria to
ensure that the impacted functions and
services are restored. A protective
instrument, such as a conservation
easement or restrictive covenant, shall be
recorded over the mitigation areas where
such a protective instrument does not
already exist. All the mitigation areas shall
be subject to long-term management as
outlined by the PMP prepared for the
proposed project.

The PMP for the proposed project site
shall prescribe the on-/off-site actions of
stewardship and perpetual management
of the preserve areas and include at
minimum: (a) the location and description
of the mitigation area; final plans for the
mitigation area; (b) the responsible
entities for the mitigation area; (c) the
management funding amount and
mechanism, based on a Property Analysis
Record (PAR) or similar cost estimation
method; (d) specific habitat and
monitoring management directives such
as: vegetation monitoring, sensitive
species monitoring, control and treatment
of non-native invasive/exotic plant
pertinent information prescribed below is
incorporated.

The HMMP shall prescribe the on-/off-site
mitigation actions of
creation/establishment/expansion, re-
establishment, restoration, enhancement,
and/or preservation. The HMMP shall include
the location of any creation/establishment, re-
establishment, restoration, enhancement
and/or preservation site(s); requirements for
site preparation, soil amendments, temporary
irrigation, native plant palettes, installation
methods, maintenance, and performance
monitoring, as appropriate. The HMMP shall
include graceful tarplant into the native
habitat planting seed palette, where
appropriate. The HMMP shall also include
information pertaining to any specific rare
plant translocation plans (see MM-BIO-1) or
vernal pool resources mitigation plans (see
MM-BIO-2) as required by MM-BIO-1 and MM-
BIO-2. The HMMP shall require that all
mitigation (except for preservation areas not
restored) be subject to monitoring with
specific performance standards to ensure that
the impacted functions and services are
restored. All the mitigation areas shall be
subject to long-term management as outlined
by the approved PMP for the project.

The PMP for the proposed project shall
prescribe the on-/off-site actions of
stewardship and perpetual management of
the preserve areas and include at a minimum:
(a) the location and description of the
mitigation area(s); final plans for the
mitigation area(s); (b) the responsible entities
for the mitigation area(s); (c) the management
funding amount and mechanism, based on a
Property Analysis Record (PAR) or similar cost
estimation method approved by the City and
applicable permit-issuing resource agency (i.e.,
USFWS, USACE, RWQCB, and/or CDFW); (d)
specific habitat and monitoring management
directives, including: vegetation monitoring,
sensitive species monitoring, water pollution,
and control and treatment of non-native
invasive/exotic plant species; (e) specific
success criteria (f) public awareness
programs/initiatives; (g) preserve barriers,
fencing management, and signage to prevent
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Section Original Text Proposed Change (s)
species; (e) specific success criteria (f)
public awareness; (g) preserve barriers or
fencing management; (h) monitoring and
reporting schedules; and (i) adaptive
management recommendations for the
preserve area. Implementation of long-
term management shall be provided by a
qualified entity approved by the City with
experience in managing preserve lands
(i.e., CDFW list of qualified entities).

Because the project proposes impacts
and mitigation that involve resources
regulated by USFWS, USACE, RWQCB,
and/or CDFW, the City shall also
coordinate concurrence approval of the
HMMP and PMP by these agencies, as
appropriate.
human intrusion and control illegal dumping;
(h) monitoring and reporting schedules; and (i)
adaptive management recommendations for
the preserve area. Implementation of long-
term management shall be provided by a
qualified entity approved by the City and
applicable permit-issuing resource agency (i.e.,
USFWS, USACE, RWQCB, and/or CDFW) with
experience in managing preserve lands.

Prior to the issuance of land disturbance,
clearing, grubbing, or grading permits for the
project, a protective instrument, such as a
conservation easement or restrictive
covenant, shall be recorded over the
mitigation areas where such a protective
instrument does not already exist (including all
on-/off-site conservation areas), and in-
perpetuity management shall be provided by a
qualified manager in accordance with the
PMP, which would be funded by an
endowment or other acceptable funding
mechanism.

The draft HMMP and PMP, including the
endowment estimate and documentation,
shall be provided to the City and applicable
permit-issuing resource agency (i.e., USFWS,
USACE, RWQCB, and/or CDFW) at least 60-
days prior to project impacts. The HMMP and
PMP shall be approved by the City and
applicable permit-issuing resource agency (i.e.,
USFWS, USACE, RWQCB, and/or CDFW) prior
to the issuance of land disturbance, clearing,
grubbing, or grading permits for the project. for
Implementation of the HMMP and PMP shall
be fully funded by the Applicant or Developer
via an endowment or other funding
mechanism, as approved by the City and
pertinent permit-issuing resource agency prior
to any land disturbance for the project.

Section 3.3.6,

(MM-BIO-8a)
Regulatory Permitting. Prior to impacts to
potentially jurisdictional resources, the
Applicant shall provide the City copies of
all applicable regulatory permits issued by
USACE, RWQCB, and/or CDFW.

Regulatory Permitting. Prior to issuance of
land disturbance, clearing, grubbing, or
grading permits for the project, the Applicant
or Developer shall provide the City copies of all
applicable regulatory permits required by the
USACE, RWQCB, and/or CDFW for project
impacts to jurisdictional aquatic resources.
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Section Original Text Proposed Change (s)

Compensatory Mitigation for Impacts to
Jurisdictional Resources. Impacts to
jurisdictional resources under the
regulation of USACE, RWQCB, and/or
CDFW that result from the proposed
project shall be mitigated at a 3:1 ratio
consisting of a minimum 1:1 creation/
establishment/re-establishment, subject
to regulatory permitting requirements of
USACE, RWQCB, and/or CDFW, as
applicable (MM-BIO-8a). Mitigation shall
be provided through one or a combination
of the following mechanisms below:
▪ Purchase of preservation,
establishment, re-establishment,
rehabilitation, and/or enhancement
credits from a mitigation bank (such
as the Brook Forest Mitigation Bank,
Ramona Grasslands Conservation
Bank, San Luis Rey Mitigation Bank,
or another bank) approved by USACE,
RWQCB, and CDFW as applicable.
▪ Implementation of permittee-
responsible preservation,
creation/establishment, re-
establishment, restoration,
rehabilitation and/or enhancement at
an on- or off-site location approved by
USACE, RWQCB, and/or CDFW.

Permittee-responsible mitigation
proposed on- and/or off-site shall be
required to prepare and implement a
Habitat Mitigation Monitoring Plan
(HMMP) and a Preserve Management
Plan (PMP) (see MM-BIO-7b), which
shall be subject to USACE, RWQCB,
and/or CDFW review and approval
prior to implementation. The HMMP
shall prescribe the on-/off-site
mitigation actions proposed, and the
PMP shall provide the parameters for
stewardship and perpetual
management.

Compensatory Mitigation for Impacts to
Jurisdictional Resources. Impacts to
jurisdictional aquatic resources under the
regulation of USACE, RWQCB, and/or CDFW
that result from the proposed project shall be
mitigated at a 3:1 ratio consisting of a
minimum 1:1 creation/expansion/
establishment/re-establishment, subject to
regulatory permitting requirements of USACE,
RWQCB, and/or CDFW, as applicable (MM-BIO-
8a). Mitigation shall be provided through one
or a combination of the following mechanisms
below:
▪ Purchase of preservation,
creation/establishment, re-establishment,
rehabilitation, and/or enhancement
credits from a mitigation bank (such as
the Brook Forest Mitigation Bank, Ramona
Grasslands Conservation Bank, San Luis
Rey Mitigation Bank, or another bank)
approved by USACE, RWQCB, and CDFW
as applicable.
▪ Implementation of permittee-responsible
preservation, creation/expansion/
establishment, re-establishment,
restoration, rehabilitation and/or
enhancement at an on- and/or off-site
location approved by the applicable
permit-issuing resource agency (i.e.,
USACE, RWQCB, and/or CDFW)as
applicable. Permittee-responsible
mitigation proposed on- and/or off-site
shall be required to prepare and
implement a Habitat Mitigation Monitoring
Plan (HMMP) and a Preserve Management
Plan (PMP) (see MM-BIO-7b), which shall
be subject to the applicable permit-issuing
resource agency (i.e., USACE, RWQCB,
and/or CDFW) review and approval prior to
implementation. The HMMP shall
prescribe the on-/off-site mitigation
actions proposed, and the PMP shall
provide the parameters for stewardship
and perpetual management.

Section 3.3.6,

and 3.3-38
(MM-BIO-8b)
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Section Original Text Proposed Change (s)
Transportation
Section 3.15.4,

3. 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
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 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.

3. 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
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 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.

Section 3.15.4,

4. 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, in conjunction with the
Urban Trail to be provided on Linda Vista
Drive and to align with the proposed
cross-section of Linda Vista Drive between
Pacific Street and Las Posas Road the
existing shared through/right-turn lane on
the westbound approach will be converted
to right turn only.

4. 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.

Alternatives
Section 4.1

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
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 Development Footprint
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Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
(Section 4.4.4), and (3) Reduced
Development Footprint Alternative
(Section 4.4.5). Other alternatives were
considered but rejected, as summarized
in Section 4.3.

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.

Section 4.4.1

— ▪ Reduced Development Footprint
Alternative – Vernal Pool Impact
Minimization (Section 4.4.6)
▪ Reduced Pacific Specific Plan Project
Alternative (Section 4.4.7)

— Reduced Development Footprint Alternative –
Vernal Pool Impact Minimization (alternative
analysis)
Section 4.4.7

through Page
4-33
— Reduced Pacific Specific Plan Project
Alternative (alternative analysis)
Section 4.5

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.

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
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
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
proposed project. This alternative would meet
most of the project objectives and reduce the
Section 4.4.6

through Page
4-26
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Section Original Text Proposed Change (s)
therefore, among the feasible alternatives
identified herein, it is considered to be
environmentally superior.
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) impacts 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 The
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.

Although this alternative would impact a
substantially larger amount of thread-leaved
brodiaea in comparison to the project; the
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 0-19
Table 0-2. Summary of Changes to the Draft EIR
Section Original Text Proposed Change (s)
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 consistent with the
regulatory agencies’ requests.

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.

— Added columns for additional alternatives,
including, Reduced Development Footprint
Alternative – Vernal Pool Impact Minimization;
and Reduced Pacific Specific Plan Project
Alternative.

Table 4-2

— Table 4-2. Comparison of Components of
Proposed Project and Alternatives
Table 4-3

— Table 4-3. Comparison of Biological Resource
Impacts by Project Alternative

through 4-47
— Figure 4-3 Reduced Development Footprint
Alternative – Vernal Pool Impact Minimization;
Figure 4-4 Reduced Pacific Specific Plan
Project Alternative;
Figure 4-5 Project Site Plan and Alternative
Comparison.

Table 4-1

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4-36
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-1
1 Executive Summary

1.1 Project Summary
The proposed Pacific Specific Plan Project (proposed project) proposes to develop 449 residential units, including a mix of apartments, rowhomes, villas, and affordable flats , on approximately 15.09 acres of a 33.2-acre project site in the City of San Marcos (City). Of the total number of proposed units, 68 units (15%) would be deed-restricted affordable units.

The project would include a total of 927 parking spaces and 134,985 square feet of common open space area.

The proposed project also includes landscaping, bio-retention areas, and circulation improvements. The remaining approximately 17.94 acres of the 33.2-acre project site would be preserved and restored open space and habitat area. The proposed project would have a density of approximately 29.8 dwelling units per acre, not including the proposed open space and habitat area. With the open space and habitat area included, the density of the proposed project site would be approximately 13.5 dwelling units per acre.

As part of the project, additional pedestrian connectivity would be provided along three of the adjacent street frontages. The project would provide a 6-foot sidewalk and Class II buffered bike lane along the project’s frontage on Pacific Street, a 12-foot urban trail (shared use path) along the project’s frontage on Linda Vista Drive , and a 12-foot urban trail (shared use path) along the project’s frontage on La Mirada Drive (please refer to Figure 2 -5, Conceptual Site Plan). In addition to the proposed sidewalk and trail connections, the project would add a bus stop and shelter with a bus turnout along South Las Posas Road adjacent to the development area and would install a four-way traffic signal at the intersection of Linda Vista Drive and Pacific Street . Furthermore, the project would upsize approximately 1,458 feet of existing water pipe from 8 inches to 12 inches and would convert approximately 1,400 feet of existing overhead power lines to underground along La Mirada.

The 33.2-acre project site is an infill site located in the western portion of the City, at the northwest corner of South Las Posas Road and Linda Vista Drive, comprised of Assessor ’s Parcel Numbers 219 -222-01, 219 -222-02, 219-222-03, and 219-222-04. La Mirada Road abuts the site ’s northern boundary, while Pacific Street abuts the property’s western boundary. The Grand Plaza shopping center is located directly across South Las Posas Road.

Light industrial uses are adjacent to the site ’s northern, southern, and western boundary, and Bradley park is located across from the site’s southwestern corner. Single- and multifamily residential uses are located to the west and south of Bradley park. The project location and project site boundary are shown on Figures 2-1 and 2-2.

The project proposes a General Plan Amendment, Rezone (GPA), Specific Plan, Tentative Map, and Multi -Family Site Development Plan. The GPA 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 implemen tation of the policies and goals of the General Plan (the Specific Plan is included as Appendix M to this Environmental Impact Report [EIR]). The Tentative Map presents specific lot configurations for the site. The Multi -Family Site Development Plan will configure the site for multifamily dwelling units, street configuration, infrastructure, recreational open space, and private open space. 1 - EXECUTIVE SUMMARY
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-2

1.2 Summary of Significant Effects And Mitigation
Measures That Reduce or Avoid the Significant Effect
Table 1-1 provides a summary of significant environmental impacts resulting from the project, mitigation measures identified to reduce and/or avoid the environmental effects, and a determination of the level of significance of each impact following implementation of the identified mitigation measures. The analysis shows that, as mitigated, all project impacts would be less than significant. Detailed analyses of significant environmental effects and mitigation are provided in Chapter 3 of this EIR.

The mitigation measures listed in Table 1-1 would reduce impacts related to air quality, biological resources, cultural resources, and tribal cultural resources to below a level of significance.

Table 1-1. Summary of Significant Environmental Impacts Impact Mitigation Measures
Level of Significance
After Mitigation
Air Quality
Impact AQ-1: Construction of the
project would exceed the
significance threshold for VOC
emissions
Implementation of MM-AQ-1, refer to
Section 3.2.5.

Less than significant
Biological Resources
Impact BIO-1: Special-Status
Species
Implementation of MM-BIO-1 through
MM-BIO-6, refer to Section 3.3.5.

Less than significant
Impact BIO-2: Riparian Habitat
and Sensitive Natural
Communities
Implementation of MM-BIO-7a and, MM-BIO-
7b and MM-BIO-7c, refer to Section 3.3.5.

Less than significant
Impact BIO-3: Jurisdictional
Wetlands and Waterways
Implementation of MM-BIO-8a and
MM-BIO-8b, refer to Section 3.3.5.

Less than significant
Cultural Resources
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
Implementation of MM-TCR-1 through
MM-TCR-3, refer to Section 3.4.5.

Less than significant
Impact CR-2: There is a potential
for project construction activities
to disturb previously unidentified
human remains on the project
site
Implementation of MM-TCR-1 through
MM-TCR-4, refer to Section 3.4.5.

Less than significant
Geology and Soils
Impact GEO-1: The project has the
potential to damage
paleontological resources during
construction
Implementation of MM-GEO-1, refer to
Section 3.6.5.

Less than significant
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-3
Table 1-1. Summary of Significant Environmental Impacts Impact Mitigation Measures
Level of Significance
After Mitigation
Tribal Cultural Resources
Impact TCR-1: Impacts to
previously unidentified Tribal
Cultural Resources
Implementation of MM-TCR-1 through
MM-TCR-4, refer to Section 3.4.5.

Less than significant

1.3 Areas of Controversy
A Notice of Preparation (NOP) was distributed on June 1, 2022, for a 30-day public review and comment period.

Additionally, a public information meeting was held on June 21, 2022, at 6:00 p.m. at the San Marcos City Hall in the Valley of Discovery Room located at 1 Civic Center Drive, in San Marcos.

Public comments were received on the NOP for this EIR and reflect concern or controversy over a number of environmental issues (refer to Appendix A for the NOP and NOP comment letters). A total of nine letters were received; concerns presented in these letters are addressed in Chapter 3 of this EIR. Issues and concerns raised in the NOP comment letters include:
▪ Transportation: scope of the study area, existing roadway congestion, trip generation and distribution, safety, project access
▪ Biological Resources: conversion of sensitive habitat, potential direct and indirect impacts to special-status species, alternatives considered, and inclusion of appropriate mitigation ▪ Cultural and Tribal Cultural Resources: compliance with Assembly Bill 52 and Senate Bill 18 ▪ Land Use: compatibility with surround land uses/development ▪ Public Services: potential impact to schools.
▪ Population and Housing: housing density
▪ Noise: concerns of noise from existing industrial land uses on the project

1.4 Issues to be Resolved by the Decision-Making Body
An EIR is an informational document intended to inform the public agency decision makers and the public of the significant effects of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project.

The lead agency must respond to each significant effect identified in the EIR by making “Findings” for each significant effect. The issues to be resolved by the decision makers for the project include whether or how to mitigate the associated significant effects, including whether to implement a project alternative. The decision makers must determine whether any of the project alternatives would substantially reduce significant effects while still meeting key objectives of the project.
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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-4

1.5 Project Alternatives
Two alternatives are proposed to provide an understanding of how environmental effects could be reduced by varying the design and scope of the project. Table 1-2 provides a comparison of the impacts of project alternatives to the impacts of the proposed project. The alternatives outlined below are more fully discussed in Chapter 4 of this EIR.

1.5.1 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.

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, t his alternative would not fulfill any of the project objectives. This alternative is further described in Section 4.4.3 in Chapter 4 of this EIR.

1.5.2 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.

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, greenhouse gas emissions, and hazards and hazardous materials, 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 project objectives, would not reduce or avoid significant environmental impacts, and would also not aid the City in achiev ing its Regional Housing Needs Assessment allocation. This alternative is further described in Section 4.4.4 in Chapter 4 of this EIR. 1 - EXECUTIVE SUMMARY
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-5

1.5.3 Reduced Development Footprint Alternative
Under the Reduced Development Footprint Alternative, the proposed project would be constructed to avoid all vernal pools and basins mapped across the site, including pools/basins found not to support vernal pool branchiopods “fairy shrimp.” In order to avoid all vernal pools and wetlands on site and achieve the 25% maximum building footprint requested by the Wildlife Agencies, the project development footprint would be constructed in three separate non-contiguous areas of the site: the northwest corner, the northeast corner, and the south-central portions of the site. In addition to the reduced development footprint, the unit count under this alternative would be reduced substantially from 449 units to 321 units. This alternative footprint would cover 8.3 acres of the

33.2-acre site, with 24.9 acres preserved.

The Reduced Development Footprint Alternative, while avoiding vernal pools, would result in impacts to the federally listed threatened and state-listed endangered thread-leaved brodiaea (Brodiaea filifolia). These impacts to thread- leaved brodiaea via implementation of this alternative would directly impact the majority of the thread-leaved brodiaea plant locations on site. Because the project site is identified as a critical and major population of this species in the region, impacts of this magnitude woul d need approval by the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife and may not be to be allowable/feasible. Therefore, although this alternative is a reduced footprint and has minimal impacts to vernal pools in comparison to the proposed project, this alternative would cause a significant impact to the endangered thread -leaved brodiaea above the Narrow Endemic threshold, impacting approximately 53% of the thread -leaved brodiaea on site. For this reason, the proposed project is considered to be a more desirable approach in protecting/avoiding the sensitive habitat on site.

Additionally, this alternative would not meet project objectives 5 and 6. This alternative would provide 128 less housing units in comparison to the proposed project. Furthermore, the reduced number of units proposed would negatively impact the amount of a ffordable housing provided by the project, thus reducing housing opportunities for lower income families. Due to the site configuration, recreation amenities would be decentralized and disconnected making accessibility to each amenity difficult to each res ident. The site configuration was designed to impact as small an area as possible to accommodate recommendations and requests of the Wildlife Agencies; however, this alternative layout results in long dead-end roads, which would potentially not meet Fire Department standards and create potential concerns for fire evacuation. Further, this detached site configuration creates challenges for utility service, drainage, and pedestrian connections.

Considering the analysis above, it is determined that impacts associated with implementation of the Reduced Development Footprint Alternative would be similar to those associated with development of the proposed project.

However, as described above, the proposed project is considered to be a more desirable approach in protecting/avoiding the sensitive habitat on site, and development of this layout and reduced unit count may not be economically feasible for the applicant/developer. This alternative is furth er described in Section 4.4.4 in Chapter 4 of this EIR.

1.5.4 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. Under the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization, development would occur within a reduced development footprint in the southern portion of the Project site. The reduced development consists of 1 - EXECUTIVE SUMMARY
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-6
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).

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).

1.5.5 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 ( this alternative reserves the option to contribute to the affordable housing fund by paying the in -lieu fee). Th is 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. This 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).

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).

1.5.64 Environmentally Superior Alternative
Table 1-2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project.

As shown in Table 1 -2, 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.

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 1 - EXECUTIVE SUMMARY
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-7
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, wWhenwhen comparing impacts to biological resources, the proposed project and The 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) wherea s this alternative would have no impacts to listed special -status animals. Additionally, this alternative would avoid all features occupied by San Diego fairy shrimp.

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 California Environmental Quality Act 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. However, after consideration o f the alternatives identified to reduce potential environmental impacts compared to the proposed project, none of the other alternatives identified herein is environmentally superior to the proposed project. Although the Reduced Development Footprint would meet most of the project objectives and potentially reduce the severity of impacts related to air quality, biological resources, cultural resources, noise, and tribal cultural resources in comparison to the proposed project due to the reduced unit count and reduced development footprint, such impacts under this alternative would still remain as less than significant with mitigation incorporated, similar to the proposed project. Additionally, although the Existing Land Use Designation Alternative would be consistent with the existing land use and zoning designation for the site and would promote infill development on site, it would not fulfill any of the project objectives, would not reduce or avoid significant environmental impacts, and would also not aid the City in achiev ing its Regional Housing Needs Assessment allocation. Therefore, in such a circumstance, it is sufficient that the EIR explain the environmental advantages and disadvantages of each alternative, as is done in Chapter 4 of this EIR.

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 1-8
Table 1-2. 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)
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.

FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-1
2 Project Description, Location, and
Environmental Setting
As required by Section 15124 of the California Environmental Quality Act (CEQA) Guidelines, this chapter describes the proposed Pacific Specific Plan Project (proposed project), and includes a statement of the project objectives, a general description of the proposed project’s technical, economic, and environmental characteristics, and a summary of the discretionary actions required to approve the proposed project. The proposed projec t provides guidelines and standards for the implementation of future development of the project site.

2.1 Project Objectives
Section 15124(b) of the CEQA Guidelines requires that an Environmental Impact Report (EIR) include a statement of the project objectives. The project objectives include the following:

1. 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.

2. 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.

3. Provide a variety of housing types, including affordable housing, to align with the City’s Regional Housing Needs Allocation requirements.

4. Restore, manage, and conserve sensitive onsite biological resources , to the extent feasible, while accommodating residential uses.

5. 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.

6. To the extent possible given site constraints, m aximize the opportunity to provide medium - density housing for the City of San Marcos up to 15.0 dwelling unit s per acre, which is comparable to other medium-density housing developments in the City of San Marcos.

2.2 Project Description
The 33.2-acre project site is an infill site located in the western portion of the City of San Marcos (City) , at the northwest corner of South Las Posas Road and Linda Vista Drive, composed of Assessor’s Parcel Numbers 219-222-01, 219-222-02, 219-222-03, and 219-222-04. La Mirada Drive abuts the site’s northern boundary, while South Pacific Street abuts the property’s western boundary. The Grand Plaza shopping center is located directly across South Las Posas Road to the east. Light industrial uses are adjacent to the site ’s northern, southern, and western boundary, and Bradley Park is located across from the site’s southwestern corner. Single- and multifamily residential uses are located to the west and south of Bradley Park. The project location and project site boundary are shown on Figures 2-1 and 2-2.

The project consists of 449 residential units, including a mix of apartments, rowhomes, villas, and affordable flats on approximately 15.09 acres of the 33 .2-acre project site. Proposed residential units would include a 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-2
mix of apartments within a five-story podium building , three-story rowhomes, three -story villas, and affordable flats within a four -story building .
68 of the 449 total units (15% of the total) would be designated as deed-restricted affordable units (alternatively, the project reserves the option to contribute to the affordable housing fund by paying the in -lieu fee). The project would also include a total of 927 parking spaces and 134,985 square feet (sf) of common open space area. The proposed project also includes landscaping, bio -retention areas, and circulation improvements. The remaining approximately 17.94 acres of the 33.2-acre project site would be preserved and restored as open space and habitat area. The proposed project would have a densit y of approximately 29.8 dwelling units per acre, not including the proposed open space and habitat area. With the open space and habitat area included, the density of the proposed project would be approximately 13.5 dwelling units per acre.

Proposed land uses are outlined in Table 2-1 below, and shown in Figure 2-5, Conceptual Site Plan.

Table 2-1. Proposed Land Uses
Land Use Acreage
Developed 15.09
Preserved Open Space 17.94
Roadway dedications as part of the proposed trail
alignment

0.17 Total Acreage 33.2
Housing Type Number of Units Square Feet
Rowhomes 101 1,200–1,890
Villas 108 1,272–1,832
Apartments 172 740–1,579
Affordable Flats 68 512–924

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) (refer to Figures 2-3a, 2-3b, 2-4a, and 2-4b). 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 Multi-Family Site Development Plan will configure the site for multi family dwelling units, street configuration, infrastructure, recreational open space, and private open space.

As part of the project, additional pedestrian connectivity would be provided along three of the adjacent street frontages. The project would provide a 6-foot sidewalk and Class II buffered bike lane along the project’s frontage on Pacific Street, a 12-foot urban trail (shared use path) along the project’s frontage on Linda Vista Drive, and a 12- foot urban trail (shared use path) along the project’s frontage on La Mirada Drive (please refer to Figure 2 -5). In addition to the proposed sidewalk and trail connections, the project would add a bus stop and shelter with a bus turnout along South Las Posas Road adjacent to the development area and would install a four-way traffic signal at the intersection of Linda Vista Drive and Pacific Street. Furthermore, the project would upsize approximately 1,458 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-3
feet of existing water pipe from 8 inches to 12 inches and would convert approximately 1,400 feet of existing overhead power lines to underground along La Mirada.

2.2.1 Discretionary Actions Required of the City
As mentioned above, the requested project entitlements/discretionary actions by the City include:
▪ General Plan Amendment
▪ Rezone
▪ Specific Plan
▪ Tentative Subdivision Map
▪ Multi-Family Site Development Plan
Discretionary actions and projects proposed within the Specific Plan area are required to demonstrate consistency with th e Specific Plan. The actions processed under th e Pacific Specific Plan that require consistency prior to approval and/or adoption by the San Marcos City Council are the General Plan Amendment and Rezone of the project site from Industrial (I) to Specific Plan Area (SPA), a Tentative Subdivision Map (TSM), and a Multi-family Site Development Plan (MFS). The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Industrial (I) to Specific Plan Area. The Tentative Map presents specific lot configurations for the site. The Multi -Family Site Developm ent Plan will configure the site for multifamily dwelling units, street configuration, infrastructure, recreational open space, and private open space.

2.2.2 Project Characteristics
Land Uses
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 of the 33.2-acre project site. Figures 2-6a through 2-6d represent renderings of the proposed residential styles by type. As outlined in Table 2-1, the proposed residential units would include 101 rowhomes ranging in size from 1,200 sf to 1,890 sf and ranging in layout from 2 bedroom s to 4 bedrooms, 108 villas ranging in size from 1,272sf to 1,832 sf and ranging in layout from 2 bedrooms to 3 bedrooms, 172 apartments ranging in size from 740sf to 1,579 sf and ranging in layout from 1 bedroom to 3 bedrooms, and affordable flats ranging in size from 512 sf to 924 sf and ranging in layout from studios to 2 -bedroom units. The proposed land use designation for the project site is Specific Plan Area.

Of the 449 total units, 68 (15% of the total) are proposed as deed-restricted affordable units. It is the desired for the development to provide affordable housing in the form of constructed income restricted dwellings as part of the development. However, should state laws change or the project be affected by the timing or availability of tax increment financing (or other impediments to completing the overall project timely), the developer may satisfy the affordable housing requirement through the city’s fee in-lieu program.

With approval of the proposed project, which includes the proposed GPA/Rezone, Specific Plan, Tentative Map, and Multi-Family Site Development Plan, the proposed development would comply with the allowable residential uses outlined in Chapter 20.250, Specific Plan Area Zone, of the City’s Municipal Code. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-4
Open Space
The project would also include a total of 134,985 sf of common open space area. The remaining 17.94 acres of the 33.2-acre project site would be conserved as open space. Proposed common open space provided as part of the residential development is outlined in Table 2-2.

Table 2-2. Proposed Common Open Space
Housing Type Common Open Space Required (sf) Common Open Space Provided (sf) Rowhomes 15,345 40,876
Villas 19,004 29,899
Apartments 18,806 47,870
Affordable Flats 4,028 16,340
Total 57,183 134,985
Note: sf = square feet.

As shown in Table 2-2, the project would provide an additional 77,802 sf of common open space area than what is required by the City. In addition to the common open space area on -site, the project would provide private open space area, as outlined in Table 2-3.

Table 2-3. Proposed Private Open Space
Housing Type Private Open Space Required (sf) Private Open Space Provided (sf) Rowhomes 5,050 6,959
Villas 5,400 6,180
Apartments 8,600 11,180
Affordable Flats 3,400 3,898
Total 22,450 28,217
Note: sf = square feet.

As shown in Table 2-3, the project would provide an additional 5,767 sf of private open space area than what is required by the City. Approximately 62 sf of private open space would be provided per unit.

As discussed above, approximately 17.94 acres of the 33.2-acre site would be preserved and restored open space and habitat area. This area would not be usable by residents of the development. The preserved 17.94 acres are described in more detail in Section 3.3, Biological Resources.

Circulation and Access
The project site is located within the undeveloped block bounded by South Las Posas Road, South Pacific Street, La Mirada Drive, and Linda Vista Drive.

The proposed project would be accessible from three points on La Mirada Drive, one gated emergency access only point on South Las Posas Road, and two points on Linda Vista Drive. The three access points on La Mirada Drive would serve the residences of the rowhomes, villas, and apartments; and the two access points on Linda Vista Drive would serve the residences of the affordable flats. The California Fire Code, along with the San Marcos Fire Department, administers the rules and regulations on fire access design. The proposed project would be designed to provide fire and emergency responders with suitable fire access roads , dimensions, and surfaces (Chapter 5, 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-5
Section 503.1 through Section 503.4 of the California Fire Code), an adequate number of emergency rated entrances to the community (Appendix D, Section D106, of the California Fire Code), and entryway gate access for first responders (Chapter 5 of the California Fire Code, Section 503.6).

The following roadway improvement recommendations proposed by the Local Transportation Analysis (LTA) (Appendix K to this EIR) would be required by condition of approval incorporated into the proposed project to ensure adequate pedestrian, bicycle, and transit facilities are provided consistent with City policies and guidelines:

1. Provide a 6’ sidewalk and Class II buffered bike lane along the Project’s frontage on Pacific Street.

2. Provide a 12’ urban trail (shared use path) along the Project’s frontage on Linda Vista Drive.

3. Provide a 12’ urban trail (shared use path) along the Project’s frontage on La Mirada Drive.

4. 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.

As described in Appendix K and Section 3.15 of this EIR, t he following intersection and roadway improvements would increase performance to acceptable or pre-project conditions:

1. At the intersection of Via Vera Cruz/Grand Avenue/SR -78 Eastbound 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 co nditions 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.

2. At the intersection of Las Posas Road/La Mirada Drive, r estripe the eastbound (La Mirada Drive) intersection approach to provide two (2) left turn lanes and one (1) 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.

3. At the intersection of 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 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.

4. At the intersection of Las Posas Road/Linda Vista Drive, in In conjunction with the Urban Trail to be provided on Linda Vista Drive, and to align the intersection of Las Posas Road/Linda Vista Drive 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 alignme nt. 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 - 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-6
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.

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 would be designed to comply with the following recommendations of the LTA, as required by conditions of approval:

1. All access points shall provide adequate driveway sight distance.

2. 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.

3. 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.

4. 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 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.

5. 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.

6. 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.

Please refer to Section 3.15, Transportation, of this EIR for a detailed description and analysis of project related traffic and transportation.

Parking
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 would 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.

Table 2-4. Proposed Parking
Housing Type Parking Spaces Required Parking Spaces Provided Rowhomes 236 234,234*
Villas 252 254**
Apartments 358 359
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-7
Table 2-4. Proposed Parking
Housing Type Parking Spaces Required Parking Spaces Provided Affordable Flats 77* 80
Total 923 927
Notes:
* Per CA 65915 (see Appendix M, Specific Plan, for details). ** Reciprocal access and parking agreement between Lot 1 and 2.

As shown in Table 2-4, 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 uncovered. 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 parking. For the convenience of tenants and guests, parking spaces s hall be located as close as po ssible to the unit or common facility it is intended to serve (City of San Marcos 2012a).

Alternative Transportation
The project site is located within 0.25 miles from two bus stops serving both Route 347 and Route 445 located along South Las Posas Road. The closest bus stops to the project site are located near the intersection of South Las Posas Road/La Mirada Drive and the intersection of South Las Posas Road/Linda Vista Drive on both sides of the street. The project site is also approximately 1 mile from Palomar College Station.

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 South Las Posas Road.

Public Utilities
Water Facilities
There is 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.

The property is within the Vallecitos Water District for both water and sewer service. Multifamily residential sites in Vallecitos Water District are typically served by on-site private water systems. Private systems consist of separate fire and domestic systems on site. Private fire systems typically supply onsite fire hydrants and building fire sprinkler systems and require a backflow preventer at the connection to the public water system.

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 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-8
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.

Sewer Facilities
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 South 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 Ro ad. The proposed affordable units would connect one 8-inch sewer line to the existing 15-inch line in Linda Vista Drive Project utilities are further described and analyzed in Section 3.17, Utilities and Service Systems, of this EIR.

Site Drainage
Stormwater 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 Los Posas Road. This drainage is collected in a corrugated metal pipe riser that drains to a reinforced concrete box in South Las Posas Road. The remainder of the site surface drains to the surrounding streets. Per the San Diego Region Municipal Separate Storm Sewer System Permit requirements, stormwater flows generated by the project site would be conveyed to biofiltration basins and detention storage, and all treated runoff from the site would follow the same drainage pattern as currently exists.

The proposed biofiltration basins and detention storage would be sized to mitigate peak 100 -year runoff rates.

Project plans have considered stormwater flows and designed the grading plan to direct all surface runoff to stormwater vaults and catch basins in private drives and drive aisles. Development of the proposed project would not substantially alter the existing drainage patterns on the site or in the immediate area. Storm drainage components would properly handle runoff to meet regulatory requirements and to ensure that post -development run-off quantifies rates that are equal to or less than pre -development conditions. The proposed project would incorporate appropriate design of on - and off-site drainage facilities and would prepare and implement a S torm Water Pollution Prevention Plan, Stormwater Quality Management Plan, and Best Management Practices.

Electrical and Gas
Electricity and natural gas would be provided by San Diego Gas & Electric (SDG&E). Electrical facilities throughout the City include a combination of aboveground and below-ground electrical distribution lines and utilities structures. The City fiber-optic network is facilitated by a 72-strand fiber-optic line that runs on various streets throughout the City. All major arterials in the City have implemented fiber optics. The proposed project would require constructing private utility lines to connect to existing electrical lines and natural gas pipeline within S. Rancho Santa Fe Road. SDG&E would be responsible for the installation of necessary cables, connectors, and pad-mounted equipment as required. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-9
To the extent feasible, the developer w ould convert approximately 1,400 feet of existing 69-kilvolt (kV) overhead power lines to underground along La Mirada , at the discretion of San Diego Gas and Electric. A guy pole may be retained in the right -of-way at the northwest corner of the project site in order to support the transition back to overhead lines west of the project site. No other new overhead utilities are proposed to serve the project. Final utility equipment design will be coordinated with a utili ty consultant, the City, and SDG&E. Undergrounding of the 69 kV distribution system would be subject to applicable federal, state, and local laws and geotechnical design recommendations for undergrounding of utilities.

In accordance with current Building Code, all buildings will be equipped with photovoltaic panels to provide solar energy to the homes. In addition, homes will include energy conservation features such as spray foam insulation, thermal breaks, low-e windows, advanced thermostats, energy star appliances, and sealed insulated ducts. Homes will be Energy Star Certified to meet U.S. Environmental Protection Agency standards.

SDG&E maintains a gas distribution system within La Mirada Drive, South Las Posas Road, Linda Vista Drive, and Pacific Street. If the project utilizes gas utilities, the gas lines will be extended to the developable area within the project site through the same joint trench alignment as electric, cable, and telephone facilities. It is likely that either a 3-inch or 4-inch pipeline will be utilized to deliver gas to the project site.

Cable and telephone service will be provided through Cox Communications, AT&T, or another telecommunications provider with infrastructure in the area. Cable connections will be stubbed for the property at the time of construction for dry utilities. Residents will be able to choose to connect to cable and telephone via several packages offered through the telecommunications provider.

Project Design Standards and Features
The Pacific Specific Plan prepared for the project site outlines Land Use Development Standards and Design Standards in Chapters 3 and 4 of the Specific Plan (Appendix M to this EIR). The Land Use Development Standards regulate the distribution and intensity of land uses and establishes development standards that would govern all future development within the Pacific Specific Plan area. The Design Standards inc lude architectural design guidelines that supplement the Land Use Development Standards. The Design Standards provide regulations for architectural style, open space design, and landscaping within the Pacific Specific Plan area. The proposed project would be required to comply with the Land Use Development Standards and all Design Standards outlined in the Pacific Specific Plan. As part of the project, approximately 517 trees would be planted on-site.

2.3 Environmental Setting

2.3.1 Existing Land Uses and Setting
The project site is currently vacant and has no existing impervious areas (see Figure 2 -2, Project Site and Surroundings). The site surface conditions generally consist of rolling unimproved earthen terrain, with native grasses and vegetation. The project site is immediately bordered by South Las Posas Road to the east, Linda Vista Drive to the south, La Mirada Drive along the northern boundary and Pacific Street abuts the property’s western boundary. The project site is surrounded by industrial uses to the north, south, and west, and commercial uses to the east, specifically the Grand Plaza shopping center is located directly across Las Posas Drive. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-10
The 24-acre Bradley Park is located across from the sites southwestern corner. Residential uses are located to the south and west of Bradley Park. The project site is located in an urban setting and is considered an infill site.

Surrounding land uses outside of the immediately adjacent industrial and commercial land uses include designated parks, single and multifamily residential, and schools/educational facilities. The closest freeway is State Route 78 located approximately 0.44 miles north of the project site.

2.3.2 Existing Land Use and Zoning Designations
Existing General Plan Land Use Designation
As described above, the existing General Plan land use designation for the project site is Industrial (I). Development allowed under this land use designation must be consistent with those uses outlined in the City’s municipal code and zoning ordinance, as well as the Industrial land use designation of the General Plan. Please refer to Figure 2-3a, General Plan Land Use.

Existing Zoning Designation
Existing zoning of the project site is Industrial (I). 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” (City of San Marcos 2018 .) The I ndustrial Zone is intended t o implement and be consistent with the Industrial land use designation of the General Plan. (City of San Marcos 2018) Please refer to Figure 2-4a, Existing Zoning.

2.3.3 Regional Setting
The following provides a general description of various aspects of the proposed project’s environmental setting.

Additional descriptions of the proposed project’s environmental setting as it relates to environmental issue areas can be found in Chapters 3, Environmental Analysis, and 5, Environmental Effects Found Not to Be Significant, of this EIR.

Climate
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average summertime high tempera ture in the region is approximately 74°F. The average wintertime low temperature is approximately 49°F. Average precipitation in the local area is approximately 10 inches per year, with the bulk of precipitation falling between December and March (WRCC 2017).

Air Basin
The City and project site is within the San Diego Air Basin (SDAB) and is under the jurisdiction of the San Diego Air Pollution Control District. The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB lies in the southwest corner of California and comprises the entire San Diego region, covering 4,260 square miles, and it is an area of high air pollution potential. The SDAB experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-11
The SDAB is currently classified as a federal nonattainment area for ozone and a state nonattainment area for particulate matter less than or equal to 10 microns (coarse particulate matter), particulate matter less than or equal to 2.5 microns (fine particulate matter), and ozone (Appendix B to this EIR).

Soils
Based on field observations and review of published geologic maps, the project site is locally underlain by recent alluvium and Santiago Formation bedrock. Undocumented fill soils were observed on-site as sporadic end -dump piles from illegal dumping (Appendix F). These soils are not considered suitable for support of structural site improvements but may be reused as engineered fill if properly processed and placed.

The most recent regional geologic map reviewed showed the geology for the eastern portion of the site along South Los Posas Road to be alluvial deposits; however, based on the site evaluation, alluvium appears to be limited to a smaller extent along a natural drainage swale along South Los Posas Road. The alluvium generally consisted of silty fine sands. Additionally, the most recently dated regional geologic map showing the overall site geology indicates Santiago Formation sedimentary bedrock at the surface on the western majority of the project site; however, based on the project site evaluation the Santiago Formation appears to be near the surface across most of the project site. The Santiago Formation was observed as a dark brown to black clay over sandstone (Appendix F).

Terrain and Topography
The project site is characterized by undeveloped terrain and has no existing impervious areas. As previously described, site surface conditions generally consist of rolling unimproved earthen terrain with native grasses and vegetation. Under existing conditions, total relief across the site is on the order of 28 feet with drainage directed towards the southern corner of the site.

Watersheds and Hydrology
The City’s General Plan area, including the project site , is located within the Carlsbad Hydro graphic Unit. The Carlsbad Hydrographic Unit (904.00) is a triangular area covering approximately 210 square miles. This hydrologic unit is bordered by San Luis Rey Hydrologic Unit to the north and San Dieguito Hydrologic Unit to the east and south.

The Carlsbad Hydrographic Unit is separated into four primary sub -watersheds based on topographical drainage areas to creek systems, including 904.1 San Luis Rey Ri ver (Moosa Creek), 904.3 Agua Hedionda Creek , 904.5 San Marcos Creek , and 904.6 Escondido Creek. The project site is located within the City’s Business/Industrial District Neighborhood, which is associated with the Agua Hedionda Creek watershed and San Marcos Creek watershed. The Carlsbad Hydrologic Unit includes one small coastal lagoon (Loma Alta Slough) and four major coastal lagoons, including Buena Vista, Agua Hedionda, Batiquitos, and San Elijo (City of San Marcos 2012b).

Habitat
As shown on Figures 3.3-1 through 3.3-4 in Section 3.3 of this EIR, vernal pools have been identified on the project site. In addition to vernal pools, other sensitive natural communities and habitats that have been identified on-site include Diegan Coastal Sage Scrub, Native Grasslands, and Non-Native Grasslands. Please refer to Section 3.3 of this EIR for a detailed analysis of biological resources. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-12

2.3.4 Public Services
The following provides a general description of public services within the City that would serve the proposed project.

Additional detail on public services can be found in Section 3.13, Public Services, of this EIR.

Fire Protection
The project site is located within the San Marcos Fire Protection District boundary. The City of San Marcos Fire Department (SMFD) would provide fire protection and emergency medical services to the project. The SMFD provides structural fire protection and advanced life support-level emergency medical services within the City limits; unincorporated territory adjacent to the City’s northern boundary; discontinuous, unincorporated areas between the City of San Marcos and the City of Escondido; and the community of Lake San Marcos. The SMFD operates two Fire Stations (Stations 1 and 2 3) that would respond to an incident at the proposed project site.

Police Protection
Police protection services for the proposed project would be provided by the San Diego County Sheriff’s Department under contract with the City. The project site would be served by the Sheriff’s San Marcos Station, located at 182 Santar Place in the northeast quadrant of the City.

Schools
The project site is located within the San Marcos Unified School District, which provides kindergarten through 12th grade education. The San Marcos Unified School District is 44 square miles in size and encompasses most of the City of San Marcos and portions of the Cities of Vista, Escondido, and Carlsbad, as well as unincorporated areas of the County of San Diego between these cities. There are a variety of public and private schools in the vicinity of the project site. The schools expected to serve the project include La Mirada Academy and San Marcos High School.

Will-serve letters issued by the District would be required for the future development proposal to ensure servicing schools have adequate capacity.

Higher education campuses are also located within the City, including Palomar Community College, and California State University San Marcos.

Parks
There are 16 major community parks and 18 mini parks located throughout the City. The City residents in the project area are currently served by several nearby parks. The closest park to the project site is Bradley Park located immediately adjacent to the project site to the west. This 24 -acre park offers baseball diamonds, a soccer field, a playground, picnic areas, restrooms, and parking.

Libraries
The City is served by the San Diego County Library, San Marcos Branch located at 2 Civic Center Drive, approximately 2 miles east of the project site.
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-13

2.4 Intended Uses for EIR
This EIR was prepared in accordance with CEQA (California Public Resources Code, Section 21000 et seq.), CEQA Guidelines (14 CCR 15000 et seq.), and the City’s Environmental Review Procedures.

The EIR is an informational document that will provide the City’s decision makers, public agencies, responsible and trustee agencies, and members of the public with information about (1) the potential for significant adverse environmental impacts that would result from the development of the proposed project, (2) possible ways to minimize any significant environmental impacts, and (3) feasible alternatives to the proposed project that would reduce or avoid significant impacts associated with the proposed project (California Public Resources Code, Section 21002.1[a]; 14 CCR 15121[a]). Responsible and trustee agencies may use this EIR to fulfill their legal authority to issue permits for the proposed project. The analysis and findings in this EIR reflect the independent judgment of the City.

Lead Agency
As defined by CEQA Guidelines Section 15367, a “Lead Agency” means the public agency that has the principal responsibility for carrying out or approving a project. The City is the lead agency for the proposed project because it will perform the entitlement processing of the proposed project. As the designated lead agency, the City has assumed responsibility for preparing this EIR, and the analysis and findings in this EIR reflect the City’s independent judgment. When deciding whether to approve the proposed project, the City will use the information in this EIR to consider potential impacts to the physical environment associated with the proposed project.

Responsible Agencies
As defined by CEQA Guidelines Section 15381, a “Responsible Agency” includes all public agencies, other than the lead agency, that have discretionary approval over the project, such as the Vallecitos Water District. Subsequent to certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project will use the Final EIR as the basis for their evaluation of environmental effects related to the proposed project that will culminate with the approval or denial of applicable permits.

Trustee Agencies
As defined by CEQA Guidelines Section 15386, a “Trustee Agency” is a public agency having jurisdiction by law over natural resources affected by a project that are held in trust for the people of the State of California. For example, trustee agencies include the California Department of Fish and Wildlife (CDFW) with regard to the fish and wildlife of the state, to designated rare or endangered native plants, and to game refuges, ecological reserves, and other areas administered by CDFW.

2.4.1 Scope of the EIR
For the proposed project, the City determined that a project EIR, as defined by CEQA Guidelines, Section 15161, was required. The City made this determination based on the development proposed for the project site and the discretionary actions requested. This EIR evaluates all subject areas listed in Appendix G to the CEQA Guidelines with the exception of those subject areas determined to have no impact on the environment, which are addressed in Chapter 5 of this EIR. Chapter 3 of this EIR evaluates the following subject areas in detail: aesthetics, air quality, biological resources, cultural resources, energy conservation, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services, recreation, transportation, tribal cultural resources, utilities and service systems, cumulative impacts, and growth-inducing impacts. Chapter 4 analyzes alternatives to the proposed project. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-14
As a “Project EIR,” this EIR is “focused primarily on the changes in the environment that would result from the project” ( CEQA Guidelines Section 15161). In addition, as a Project EIR, this EIR examines all phases of the proposed project including planning, construction, and operation ( CEQA Guidelines Section 15161). Where environmental impacts have been determined to be significant, this EIR recommends mitigation measures directed at reducing or avoiding those significant environmental impacts. Alternatives to the proposed project are identified to evaluate whether there are ways to minimize or avoid significant impacts associated with the proposed project.

2.4.2 Notice of Preparation and Scoping
CEQA establishes mechanisms to inform the public and decision makers about the nature of the proposed project and the extent and types of impacts that the proposed project and alternatives to the proposed project would have on the environment should the proposed project or alternatives be implemented. Pursuant to Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated June 1, 2022 , to interested agencies, organizations, and parties. The NOP was also sent to the State Cl earinghouse at the California Office of Planning and Research. The State Clearinghouse assigned a state identification number (SCH No. 2022050650) to this EIR.

The NOP is intended to encourage interagency and public communication regarding the proposed action so that agencies, organizations, and individuals are afforded an opportunity to respond with specific comments and/or questions regarding the scope and content of the EIR. A public scoping meeting was held on June 21, 2022, at San Marcos City Hall (1 Civic Center Drive) to gather additional public input. The 30-day public scoping period ended on July 1, 2022. Comments received during the NOP public scoping period were considered part of the preparation of this EIR. The NOP and written comments are included in Appendix A to this EIR. Comments covered numerous topics, including biological resources, cultural resources, traffic, parking, land use, public services, population and housing, and noise. Public scoping comments regarding the proposed project’s potential impact on the environment have been incorporated in the analysis in Chapters 3, 4, 5, and 6 of this EIR.

2.4.3 Draft EIR and Public Review
This Draft EIR was prepared under the direction and supervision of the City. The Draft EIR will be made available to members of the public, responsible agencies, and interested parties for a 45-day public review period in accordance with CEQA Guidelines, Section 15105.

Public review of the Draft EIR is intended to focus “on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated” (14 CCR 15204). The Notice of Completion of the Draft EIR will be filed with the State Clearinghouse as required by CEQA Guidelines, Section 15085. In addition, the Notice of Availability of the Draft EIR will be distributed pursuant to CEQA Guidelines, Section 15087 . Interested parties may provide comments on the Draft EIR in written form. This EIR and related technical appendices are available for review during the 45 -day public review period at the following locations:

City of San Marcos Planning Division
1 Civic Center Drive
San Marcos, California 92069
San Diego County Library San Marcos Branch
2 Civic Center Drive
San Marcos, California 92069
City of San Marcos website: https://www.san-marcos.net/departments/ development-services/planning/environmental-review-sustainability/environmental-documents. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-15
Interested agencies and members of the public may submit written comments on the adequacy of the Draft EIR to the City’s Development Services Department at the address above, addressed to Saima Qureshy, Principal Planner, or emailed at [email protected]. Comments on the Draft EIR must be received by the close of business on the last day of the 45 -day review period. Electronic filing and posting of the EIR would be in compliance with Assembly Bill 819, as applicable.

2.4.4 Final EIR Publication and Certification
Once the 45-day public review period has concluded, the City will review all public comments on the Draft EIR and provide a written response to all written comments pertaining to environmental issues as part of the Final EIR. Thise Final EIR will includes all written comments received during the public review period, responses to comments, and, if applicable, edits and errata made to the Draft EIR. The City will then consider certification of the Final EIR (14 CCR 15090). If the EIR is certified, the City may consider project approval (14 CCR 15092).

The Draft Environmental Impact Report (EIR) was circulated for public review from March 2, 2023, through April 17, 2023, in accordance with Section 15105(a) of the CEQA Guidelines. A total of eight (8) written comment letters were received on the Draft EIR from agencies and organizations, as shown in Table 0-1 in Chapter 0, Introduction, of the Final EIR . Appendix P, which includes both public comment letters and responses to each comment letter received, has been included as part of the Final EIR.

When deciding whether to approve the proposed project, the City will use the information provided in the Final EIR to consider potential impacts to the physical environment. The City will also consider all written comments received on the Draft EIR during the 45-day public review period in making its decision to certify the Final EIR as complete and compliant with CEQA and in making its determination whether to approve or deny the proposed project.

Environmental considerations, as well as economic and social factors, will be weighed by the City to determine the most appropriate course of action.

Prior to approving the proposed project, the City must make written findings and adopt a Statement of Overriding Considerations with respect to any significant and unavoidable environmental effect identified in the Draft EIR (14 CCR 15091, 15093). If the proposed project is approved, the City will file a Notice of Determination with the State Clearinghouse and San Diego County Clerk within 5 working days after project approval (14 CCR 15094.) Subsequent to certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project may use the Final EIR’s evaluation of the proposed project’s environmental effects in considering whether to approve or deny applicable permits.

2.4.5 Matrix of Project Approvals and Permits
Consistent with the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20, the proposed project requires certain entitlements be submitted, reviewed, and approved by the City (see Table 2 -5). The requested entitlements include a General Plan Amendment and Rezone to change the General Plan designation and Zoning from Industrial (I) to Specific Plan Area (SPA), a Tentative Map , which will present specific lot configurations for the site, a Multi-Family Site Development Plan, and a Specific Plan, which will configure the site for multifamily dwelling units, street configuration, infrastructure, recreational open space, and private open space. 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-16
The City will use this EIR and associated documentation in its decision to approve or deny the required discretionary permits. The City may also use this EIR in its consideration of any future development proposal, together with any additional or supplemental information or CEQA analysis as may be required. Other responsible and/or trustee agencies can use this EIR and supporting documentation in their decision -making process to issue additional approvals. These additional approvals may include , but are not limited to , approval of sewer and water connection s and resource agency approval of biological resources mitigation .

Table 2-5. Required Actions and Approvals
Agency Required Action/Approval
City of San Marcos
(Lead Agency)
General Plan Amendment – A General Plan Amendment would be required to re-designate the project site from Industrial (I) (as currently designated by the City of San Marcos) to Specific Plan Area (SPA).

Rezone - A rezone would be required to re-designate parcels 219-22-01, 219- 22-02, 219-22-03, and 219-22-04 from an Industrial (I) General Plan Land Use designation to Specific Plan Area (SPA).

Tentative Map – A Tentative Map will present specific lot configurations for the site.

Multi-Family Site Development Plan – A Multi-Family Site Development Plan will configure the site for multifamily dwelling units, street configuration, infrastructure, recreational open space, and private open space.

Specific Plan – A Specific Plan would be required 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.

City review and approval of project grading plans and issuance of building permits.

Environmental Impact Report Approval and Certification.

United States Army Corps of
Engineers (USACE)
It is anticipated that a 404 Permit from USACE would be needed.

Regional Water Quality
Control Board (RWQCB)
It is anticipated that a 401 Certification from RWQCB would be needed. If the wetlands or waters on-site are ruled non-jurisdictional by USACE, it is anticipated that a Waste Discharge Requirements Permit from RWQCB would be required.

California Department of Fish
and Wildlife (CDFW)
It is anticipated that a 1602 agreement from CDFW would be needed.

Note: Implementation of the proposed project would affect federally protected wetlands and other potential jurisdictional features.

There is the potential for federal USFWS permits.

2.5 Project Inconsistencies with Applicable Regional and General Plans
Throughout Chapter 3 of this EIR, the proposed project has been evaluated in relation to the applicable goals, policies, and objectives of the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20 (Section 3.10, Land Use and Planning ), San Diego Forward: The Regional Plan (Section 3.10, Land Use and Planning), Regional Air Quality Strategy (Section 3.2, Air Quality ), San Diego Air Pollution Control District policies (Section 3.2, Air Quality ), City’s Climate Action Plan (Section 3.7, Greenhouse Gas Emissions ), Regional Water Quality Control Board plans and permits (Section 3.9, Hydrology and Water Quality ), the Multiple Habitat 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-17
Conservation Program (Section 3.3, Biological Resources ), Airport Land Use Compatibility Plans (Sections 3.8, Hazards and Hazardous Materials ; 3.10, Land Use and Planning; and 3.11, Noise), and various other applicable regional and local plans and policies.

As described previously, a General Plan Amendment and Rezone is proposed in order to change the designated land use and zoning for the site from Industrial (I) to Specific Plan Area (SPA), to allow for the proposed residential development of the project site. As discussed in Section 3.10 of the EIR, the proposed project would be consistent with the applicable goals of the various elements and overall vision of the City’s General Plan, including the General Plan Housing Element.

2.6 List of Past, Present, and Reasonably Anticipated
Future Projects in the Project Area
CEQA requires an EIR to analyze cumulative impacts. Section 15355 of 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 practicality and reasonableness” (14 CCR 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.

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. a list of past, present, and probable activities producing related or cumulative impacts; or B. 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 is on an air basin and global scale.

An inventory of past, present, and reasonably foreseeable future projects within the vicinity of the project site is presented in Table 2-6 and Figure 2 -7, Cumulative Project Map . 2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-18
Table 2-6. 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
16 Approved Pacifica
San Marcos
S. Rancho Santa Fe Rd.
and Creek St.

Mixed use development of
31-unit apartment complex
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-19
Table 2-6. Cumulative Projects
No. Status
Project
Name/Developer Location Description
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 Drive (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 Budhi Hill
Buddhist Center
Poinsettia Ave. s/o
Linda Vista Dr.

Development of a 36,501
sf. Fellowship Happ and
7,612 sf. Monk Dormitory
31 Proposed Mercy Hill and
Marian Center
Borden Rd. 31,105 sf. Christian Center
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
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-20
Table 2-6. Cumulative Projects
No. Status
Project
Name/Developer Location Description
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
Street widening, Levee
construction,
Promenade, and Creek
Channel Wetland
Restoration
San Marcos Creek Phase 1
Infrastructure, Discovery
Street (east/west segment),
Bent Avenue to Discovery
Street (north/south
segment)
36 Funded CIP 88179 Smilax Road/South
Santa Fe Ave.

Intersection Intersection
re-alignment
Smilax Road/South Santa
Fe Avenue Intersection
Intersection re-alignment
37 Under Construction CIP 86002 San Marcos Blvd. at
Discovery Street
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 Boulevard
Slope Stabilization Project
40 Proposed Pacific Grand
Ventures

1.49-acre lot east of S.

Pacific at Seminole St.
26,156-square-foot
industrial building
41 Proposed Twin Oaks Valley
Winery
1451 Mulberry Dr. 3,121-square-foot 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.
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
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-21
Table 2-6. Cumulative Projects
No. Status
Project
Name/Developer Location Description
46 Proposed Lonnie Tavvaa –
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 Prolley
Apartments
North side of Prolley 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 Bl,
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
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
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-22
Table 2-6. Cumulative Projects
No. Status
Project
Name/Developer Location Description
58 Approved San Elijo Town
Center East
NE corner of San Elijo
Road and Elfin Forrest
Road at 1093 San Elijo
Road.

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

78 RICHMARAVE

DESCANSO AVE
ALTURA
DR
CRAVEN
RD

BUSINESS PARKDR

LAKERIDGEDR

ACACIADR

POINSETTIA AVE

WHITESANDSDR

LA SOMBRA DR

W SAN MARCOS BLVD

ECHO LN
W

MISSION
RD

SANT ABARBARADR

SMILAX RD

LAFLORA
DR

SANMARINO
DR

OLEANDER AVE

SSANTAFEAVE

SYCAMOREAVE

NLASPOSASRD

VIA PORTOLA

KNOLL RD
GREEN
OAKRD

PALOMARCOSAVE

TESOROAVE

PLUMOSAAVE

SANDYLN

VIA LAVENTA

MCMAHR RD

DISCOVERY ST

NAVAJO ST

MIMOSAAVE

GLENDALEAVE

RUSH DR

SRANCHOSANTAFERD
01ST ST
QUAIL
HILLDR

AVENIDAAGUILA

GRANDON AVE

SPECIALTYDR

PAWNEE ST

SANPABLODR

S PACIFIC ST

PRIVATERD

LAS FLORES DR
W
BORDEN
RD
POPPY
RD

VIEWPOINTDR
SHENAN

DOAHAVE

LA TIERRA DR
LAN
OCHEDR

CAPALINA RD

CAMINODELSOL

BINGHAM DR

N PACIFIC ST
APPLE

WILDEDR

HILLHAVENDR

GRAND AVE

HOLLENCREST RD
KIRKW
ALLDR

VIOLETAVE

BLUESAGE DR

LA MIRADA DR

AUTUMN DR
CORT
ELOREN

HONEYSUCKLEDR

PRIVATERD
PARKW
O
ODAVE

CASITALN

AVENIDAAZUL

WINDRIDGECIR

PROGRESSST

VIA VERA CRUZ

ARBORVIEW
DR

CREEK ST

LA MIRADA DR
LINDA VISTA DR09TH ST
ALLEY

BIRCHST

COMMERCE WAYG

RANDAVE

CADESWAY

HAPPY HILL LN

HELMSDALERD
JOYCT

LOSVALLECITOSBLVD

DOGWOODWAY

SCOTTST

LA COLUSA DR

COMETCIR

CURRY COM BDR

S BENT AVE

WESTLAKEDR

DECISION
ST

ARMORLITE DR
ASHST

TOYONTER

TILLEY LN

PRIVATERD

TI G ER WAY

VIRGINIA PL

LACASITADR

JUNIPER LN

ACTIVITYDR

SEQUOIAS
T

PIONEERAVE

LOMAALTADR

DELEONERD
FIRELN

PRIVATE
RD

PRIVATE
RD
Project Location
Pacific Project EIR
SOURCE: SANGIS 2020
Date: 10/26/2021 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-1_ProjectLocation.mxd 02 , 0 0 0 1,000
Feet
Project Boundary
FIGURE 2-1
Chula Vista
Solana Beach
Encinitas
San Diego
Carlsbad
Oceanside
Santee
Poway
San Marcos
Escondido
Vista
Imperial
Beach
National City
Del Mar
Coronado
Riverside
County
Mexico
905
209
75 52
94 241
9854
73 125
274
195
56 86
111
67 74
74 76 79
78 805
215
15 5
8 Project Site
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-24

INTENTIONALLY LEFT BLANK

78 S RANCHO SANTA FE RD

S LAS POSAS RD

NAVAJO ST

PAWNEE ST

PRIVATE RD

ALPINEPL

GRAND AVE

S PACIFIC ST

TAULBEES LN

RYAN DR

LA MIRADA DR

LINDA VISTA DR

PRIVATE RD

STONE DR

VIA VERA CRUZ
William Bradley
Park
Project Site and Surroundings
Pacific Project EIR
SOURCE: SANGIS 2020
Date: 10/26/2021 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-2_ProjectSite.mxd 0 400 200
Feet
Project Boundary
FIGURE 2-2
Grand Plaza
Shopping Mall
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-26

INTENTIONALLY LEFT BLANK

S RANCHO SANTA FE RD

LINDA VISTA DR

NAVAJO ST

S LAS POSAS RD

ALPINEPL

CHEROKEE ST

PAWNEE ST

PRIVATE RD

VIA VERA CRUZ

S PACIFIC ST

GRAND AVE

TA ULB EES LN

RYAN DR

LA MIRADA DR

STONE DR
P
PI
I
I
I
I
I
I
LI
LI
LI
C
C
C
C
C
MU1
MU1
MU1
OS
OS
OS
General Plan Land Use
Pacific Project EIR
SOURCE: City San Marcos 2021; SANGIS 2021
Date: 4/27/2022 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-3a_Existing_GPLU.mxd 0 400 200
Feet
Project Boundary
Existing General Plan Land Use
MU1 - Mixed Use 1
C - Commercial
LI - Light Industrial
I - Industrial
PI - Public/Institutional
P - Parks
OS - Open Space
FIGURE 2-3a
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-28

INTENTIONALLY LEFT BLANK

S RANCHO SANTA FE RD

LINDA VISTA DR

NAVAJO ST

S LAS POSAS RD

ALPINEPL

CHEROKEE ST

PAWNEE ST

PRIVATE RD

VIA VERA CRUZ

S PACIFIC ST

GRAND AVE

TA ULB EES LN

RYAN DR

LA MIRADA DR

STONE DR
P
PI
I
SPA
I
I
I
I
LI
LI
LI
C
C
C
C
C
MU1
MU1
MU1
OS
OS
OS
Proposed General Plan Land Use
Pacific Project EIR
SOURCE: City San Marcos 2021; SANGIS 2020, 2021
Date: 4/27/2022 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-3b_Proposed_GPLU.mxd 0 400 200
Feet
Project Boundary
Proposed General Plan Land Use
MU1 - Mixed Use 1
C - Commercial
LI - Light Industrial
I - Industrial
PI - Public/Institutional
SPA - Specific Plan Area
P - Parks
OS - Open Space
FIGURE 2-3b
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-30

INTENTIONALLY LEFT BLANK

S RANCHO SANTA FE RD

LINDA VISTA DR

NAVAJO ST

S LAS POSAS RD

ALPINEPL

CHEROKEE ST

PAWNEE ST

PRIVATE RD

VIA VERA CRUZ

S PACIFIC ST

GRAND AVE

TA ULB EES LN

RYAN DR

LA MIRADA DR

STONE DR
P-I
P-I
I
I
I
I
I
I
L-I
L-IL-I
C
C
C
C
I/C
MU-1
MU-1
MU-1
O-S
O-S
O-S
I
L-I/MU-1
Existing Zoning
Pacific Project EIR
SOURCE: City San Marcos 2021; SANGIS 2021
Date: 4/27/2022 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-4a_Existing_Zoning.mxd 0 400 200
Feet
Project Boundary
MU-1 - Mixed-Use-1
L-I/MU-1 - Light Industrial/Mixed-Use-1
C - Commercial
I/C - Industrial/Commercial
L-I - Light Industrial
I - Industrial
P-I - Public-Institutional
O-S - Open Space
FIGURE 2-4a
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-32

INTENTIONALLY LEFT BLANK

S RANCHO SANTA FE RD

LINDA VISTA DR

NAVAJO ST

S LAS POSAS RD

ALPINEPL

CHEROKEE ST

PAWNEE ST

PRIVATE RD

VIA VERA CRUZ

S PACIFIC ST

GRAND AVE

TA ULB EES LN

RYAN DR

LA MIRADA DR

STONE DR
P-I
P-I
I
SPA
I
I
I
I
L-I
L-IL-I
C
C
C
C
I/C
MU-1
MU-1
MU-1
O-S
O-S
O-S
I
L-I/MU-1
Proposed Zoning
Pacific Project EIR
SOURCE: City San Marcos 2020; SANGIS 2020
Date: 4/27/2022 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-4b_Proposed_Zoning.mxd 0 400 200
Feet
Project Boundary
MU-1 - Mixed-Use-1
L-I/MU-1 - Light Industrial/Mixed-Use-1
C - Commercial
I/C - Industrial/Commercial
L-I - Light Industrial
I - Industrial
P-I - Public-Institutional
SPA - Specific Plan Area
O-S - Open Space
FIGURE 2-4b
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-34

INTENTIONALLY LEFT BLANK
REC
REC

24.0 24.0

24.0 24.0

24.0 24.0

24.0 24.0

19.0 19.9

19.2 24.0

24.0 24.0

24.0 24.0

24.0 24.0

16.0 7.210.0

8.8 10.2

16.2 16.0 14.0

24.0 24.0

24.0 24.0

24.0 24.0

24.0 10.0

12.2 15.1

17.9 20.1

47.8 22.0

17.4 24.0

24.0 24.0

8.2 24.0

24.0 24.0

24.0 24.0

24.0 AC UNITS TYP.

USPS PARKING LOCATION
AVAILBLE FROM 9AM TO 5PM

USPS PARKING

LOCATION AVAILABLE
FROM 9AM TO 5PM

TRASH PICK UP LOCATION

LOADING/TRASH

PICK UP

LOCATION

TRASH PICK UP

LOCATION

LOADING/TRASH

PICK UP

LOCATION
RECLSG
MIN. PRIVATE

GROUND FLOOR

OPEN SPACE
250 SF TYPICAL

24.0 24.0

24.0 146.9
150.0
APARTMENTS - LOT 3
86 1B/1BA 740 SF
62 2BD/2.5BA 1,256 SF
24 3BD/2.5BA 1,579 SF
172 4.308 AC = 39.93 DU/AC
PARKING SUMMARY PER CA 65915
1BD 86 X 1.0 = 86 SPACES
2&3BD 86 X 1.5 = 129 SPACES
TOTAL REQUIRED 215 SPACES
PROVIDED COVERED (1:1) 172 GARAGE SPACES
PROVIDED OPEN 187 SPACES
TOTAL PROVIDED 359 SPACES
(LOT 3 EV = 359 SP X 5% = 18 EV LEVEL 2 CHARGERS INSTALLED)

PRIVATE OPEN SPACE REQUIRED PROVIDED
172 X 50 SF 8,600 SF 11,180 SF

COMMON OPEN SPACE REQUIRED PROVIDED
GROUND FLOOR SF X 30% 15,606 SF
TOT LOT (1:25 DU) 6X400 SF 2,400 SF
PLAYGROUND 800 SF
TOTAL 18,806 SF 47,870 SF
AFFORDABLE - LOT 4

UNIT MIX
8 STUDIO/1BA 512 SF
42 1BD/1BA 625 SF
18 2BD/2BA 924 SF
68 1.781 AC = 38.18 DU/AC
PARKING PROVIDED PER CA 65915
50 X 1.0 SP/DU = 50 SPACES
18 X 1.5 SP/DU = 27 SPACES
TOTAL REQUIRED 77 SPACES
TOTAL PROVIDED 80 SPACES
(LOT 4 EV = 80 SP X 5% = 4 EV LEVEL 2 CHARGERS INSTALLED)

PRIVATE OPEN SPACE REQUIRED PROVIDED
68 X 50 SF 3,400 SF 3,111 SF

COMMON OPEN SPACE REQUIRED PROVIDED
GROUND FLOOR SF X 30% 2,828 SF
TOT LOT (1:25 DU) 3X400 SF 1,200 SF
TOTAL 4,028 SF 16,340 SF
TOTAL EV = 927 SP X 5% = 47 EV LEVEL 2 CHARGERS INSTALLED (PROJECT SHALL MEET THE MINIMUM CGBSC STANDARDS FOR EV CHARGING

FOR NEW CONSTRUCTION AT TIME OF PERMIT APPLICATION)
VILLAS - LOT 2
60 2BD/2BA 1,272 SF
24 3BD/2.5BA 1,486 SF
24 3BD/3BA 1,832 SF
108 4.583 AC = 23.57 DU/AC
PARKING SUMMARY PER CA 65915
2&3 BD 108 X 1.5 = 162 SPACES
TOTAL REQUIRED 162 SPACES
TOTAL PROVIDED 254 SPACES* (38 OPEN/216 PRIVATE GARAGES) *NOTE: RECIPROCAL ACCESS & PARKING AGREEMENT BETWEEN LOT 1 & 2 (LOT 2 EV = 254 SP X 5% = 13 EV LEVEL 2 CHARGERS INSTALLED)

PRIVATE OPEN SPACE REQUIRED PROVIDED
108 X 50 SF 5,400 SF 6,180 SF

COMMON OPEN SPACE REQUIRED PROVIDED
GROUND FLOOR SF X 30% 16,204 SF
TOT LOT (1:25 DU) 5X400 SF 2,000 SF
PLAYGROUND 800 SF
TOTAL 19,004 SF 29,899 SF
RESIDENCES 449 HOMES
GROSS SITE AREA 33.229 ACRES (15.091 ACRES NET)
GROSS DENSITY 13.51 DU/AC (29.75 DU/AC NET)
ROWHOMES - LOT 1
23 2BD/2BA 1,200 SF
23 3BD/3BA 1,310 SF
28 3BD/3.5BA 1,736 SF
27 4BD/3.5BA 1,890 SF
101 4.419 AC = 22.86 DU/AC
PARKING SUMMARY PER CA 65915
2&3 BD 74 X 1.5 = 111 SPACES
4 BD 27 X 2.5 = 68 SPACES
TOTAL REQUIRED 179 SPACES
TOTAL PROVIDED 234 SPACES* (32 OPEN/202 PRIVATE GARAGES) *NOTE: RECIPROCAL ACCESS & PARKING AGREEMENT BETWEEN LOT 1 & 2 (LOT 1 EV = 234 SP X 5% = 12 EV LEVEL 2 CHARGERS INSTALLED)

PRIVATE OPEN SPACE REQUIRED PROVIDED
101 X 50 SF 5,050 SF 6,959 SF

COMMON OPEN SPACE REQUIRED PROVIDED
GROUND FLOOR SF X 30% 12,945 SF
TOT LOT (1:25 DU) 4X400 SF 1,600 SF
PLAYGROUND 800 SF
TOTAL 15,345 SF 40,876 SF
Conceptual Site Plan
Pacific Project EIR
FIGURE 2.5
SOURC
E: Summ
a Architecture,
2023
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR

2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-36

INTENTIONALLY LEFT BLANK

BLDG ABLDG A

BLDG BBLDG B
Villas - Renderings
Pacific Project EIR
FIGURE 2-6a
SOURC
E: Summ
a Architecture,
2022
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-38

INTENTIONALLY LEFT BLANK

BUILDING ABUILDING B

BUILDING CBUILDING D
Rowhomes - Renderings
Pacific Project EIR
FIGURE 2-6b
SOURC
E: Summ
a Architecture,
2022
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-40

INTENTIONALLY LEFT BLANK
Apartments - Renderings
Pacific Project EIR
FIGURE 2-6c
SOURC
E: Summ
a Architecture,
2022
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-42

INTENTIONALLY LEFT BLANK

SOUTHWEST (LINDA VISTA DRIVE)

NORTH EAST
Affordable Units - Renderings
Pacific Project EIR
FIGURE 2-6d
SOURC
E: Summ
a Architecture,
2022
Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-44

INTENTIONALLY LEFT BLANK
Date: 2/16/2023 - Last saved by: agreis - Path: Z:\Projects\j1317001\MAPDOC\DOCUMENT\EIR\Figure2-7_CumulativeProjectMap.mxd 78 15
W

VALLEYPKY

BORDEN RD

COUNTRY
CLUB
DR

CORONADO

HILLSDR
S

MELROSEDR

SHADOWRIDGE DR

L EIS URE VILLAGEWAY

DESCANSO AVE

ALTUR A DR

WOODLAND
PKY

L OBELIA DR

N HALE AVE
N

NUTMEGST

UNICORNIO ST

L I VEOAK RD

VISTALA

G O TER

DEODARRD

MELROSEDR

LUPINE HI LLS DR

W EL NORTE PKY

BUSINESS
PARKDR

MULBERRY DR

JESMOND DENE RD

W MISSION AVE

LA MOREE RD

VINEYARD RD

E MISSION RD

ROCK SPRINGS RD

ACAC I A
DR

POINSETTIAAVE
DOVELN
CAMINO

DELARROYO
DR

VILLAG E RD

LIVE OAKRD

LASOMBRADR

HARMONY GROVE VI LLAGEPKY

W SAN MARCOS BLVD

COTTAGEW
AY

S RANCHO SANTA FE RD
ECHO
LN

GAMBLE LN
RANCHO

SANTAFERD

EUCALYPTUS AVE
SANTA

BARBARA DR VILLAGEDR

CHERIMOYADR

HAMILTON LN
CAN

D LELI GHTGLEN

METCALF ST
N
TW
IN
OAKS

VALLEYRD
SAN

MARINO DR

PIRAGUAST

LA BONITA DR

HIGH B LUFF AVE

NORDAHL RD

W LINCOLN AVE

OLEANDER AVE

CALAVO DR

SSANTAFE AVE

E LACIENEGARD

PICO AVE

DELRO Y DR

COUNTRY CLUB LN

RANCHEROS DR

SYCAMOREAVE

AVENIDA DEL DIABLO
SIRIS
LN
N
LAS
POSAS
RD

W WASHINGTON AVE
XANAW
AY

DEL DIOS
RD

VIA PORTOLA

DAVIDDR

ALICANTERD

KNOLLRD
ELFIN

FORESTRD
WATSON
WAY
SH
ELLYDR
COR
T
EZ AVE

W MISSION RD
W
OODLAN
D

HEIGHTSGL EN

TESOROAVE
W 11TH AVE

FARADAYAVE

QUAIL RD

BARHAM LN

CITRACADO PKY

JOHNSTON RD

BOUGHER RD
RUBY
C
T

ATTEBURYRD

VIATERESA
COUR

AGE S T
HOWARD
AVE
COCOS
DR

TOWNGARDEN RD
HERM
O

S ITA D R

RICHLAND
RD

MAGELLAN LN

GREENHAVEN DR

FULTON RD

H O LLOW BROOK CT

BREWLEY LN

BRESSI RANCH WAY

GARY LN

PALOMAR AIRPORT RD
VIALA
VENTA

ISLAND DR

MCMAHR RD

LUCIERNAGAST

STARRYNIGHTDR

TRAILBLAZER
LN

WASHI N

GTONIADR

DASSIA WAY

VENADO ST

ESFERAST

SANPABLO
DR

KNOB HILL RD

DISCOVERY ST

NAVAJO ST

MI MOSAAVE
AUTO

PARK WAY

ROSS DR

LAKERIDGEDR
GOLDEN

CIRCLEDR

VEGAWAY

MONTIEL RD
ARCHER
RD
BRESA

D E LOMA DR
RUSH
DR

HILL VALLEY DR

ABEDUL ST

S HALE AVE

HARMONY GROVE RD

CARRIAGE
DR

MISSION RD

KAUANALOADR

ROCK V I EW GLEN

QUESTHA VENRD

BARHAM DR
DANEDR

F OREST
GLEN
01ST ST

QUAIL HILL DR

L E DGE ST

VIADELCABA L LO

LONGHORNDR

BUENAVISTADR

ROMA DR

PAMELALN

WOODWARD ST

HALITEPL
VIADEL
SUR

CORIN TI A ST

GRANDON AV E

BROOKHAVEN PAS
S

DEERGRASSDR

N IRIS LN
W
HITE

BIRCH DR

AVENIDALEON

PASEO MONON
A
N
CENTRE

CITYPKY

CRIMSONDR

PASEO CA NDELERO

PAWNEE ST

BENNETT AVE

VIACAFETAL

M I CARD

PLUMOSA AVE

GREE N OAK RD

CONTINENTAL LN
S TWIN
OAKS
VALLEY
RD

AR ENAL RD

CADENCIAST

PLEASANTHILL
ST

LAS FLORES DR

VIA LARANCHITA

LAPISRD

LAGOLONDRINA ST

W BORDEN RD

LACEBARKST

GOLDSTONE R D
W
ILGEN
RD

GALENAAVE

LATIERRADR

LANOCHE DR
WILD
C

ANYONDR

CAPALINA RD

CAMIN O DELSOL
CAZ

A D ERO DR

LINDSLEY

PARK D R

DAWS ON DR
ANTIGU
ADR

OAKVIEW
W
AY

VIABAHIA
OAK
GLENDR
W 09TH AVE

LA PLAZ A DR

APPLEWILDEDR

TUCANA DR
OB

EL I S C
O
CIR

PAL O MARDR
W

HITESANDS
DR

CACATUAST

RAN CHO CORT ES

VIACON QUISTADOR

BORDEN RD

COL U MBUS WAY

LONG TROT DR

WISTERIA D R

GRAND AVE
COUN
TRYS

I D E DR

ARGON AUTAST

VISTAVERDE

SHADOW HI LLS DR

AMBERLN
HA

B ERO D R

GATEWAY RD

WINDEMERE DR

CARRI L LO WAY

TOPIARY ST

KIRKW ALL DR

MARIN DR
SEVEN
OAKES
RD

HAZEN D R

VIOLET AVE

RANCHO PANCHO

ESTREL LADE
M
ARRD

ARIANARD

EDGEWATERDR

ROSERANCH RD

CIMA DR

BLUESAGE DR

SHADETREE DR

AVENIDAABEJA

RANCHO BR AVADO

BELLAVISTADR

SETTLERSCT

LA MIRADA DR

MIRASOL

DIAMONDST

SEQUOIA
CRES T
FAL

L SVI EW RD

LASS E N DR

GLENDALE AVE

AVOCADO
AVE
ELM

RIDGE DR

REES RD

AVENIDAVALERA

CRAVEN DR

ORANGE AVE
REDW
ING
S
T

CAMINOMAGNIFICO
HO

NEYSU CKLE D R

EAGLEDR

ALGA RD
ASH
LN
ALLEY

E CARMEL ST
SAN

ELIJORDN

SANELIJO
RDS

INDUSTRIAL AVE
DOVE

TAIL DR

THIBODO RD

SKYRIDGE LN
GALLO
PWAY

IMPERIAL DR

N ANDREASEN
DR
FOSCA
ST
OPPER
ST

AVENIDA AZUL

LAKEBLVD

WINDRIDGE CIR

PROGRESS S T
SCENIC
DR

RANCHO RIOCH
ICO

OAKRIDGEWAY

CRAVEN RD
SCHOO
LHOU
SEWAY

S ANDREASENDR

CORDREY
DR

W LACIE NEGARD

CITRINEDR

LOKERAVEE

VI A BARQUERO

DAL E C T

BOLERO S T

POINSETTIA LN

SANELIJORD

CENT ERDR

ENTERPRISE ST

ELFUERTEST

HILL DR
VIKING
LN

DON LEE PL

VIA VERA CRUZ

WHIPTAIL LOOP

PORTOLA AVE

VIALASVILLAS

CANNON RD
DOUBLE
PEAKDR
SAN JU
LIAN
DR

EL CAMINO REAL

SITIOCORAZON
09TH ST
CAMINO
DR

ALTISMAWAY

ALMADEN
LN

BIRCHS T

NAVARRA DR
MEYER
S
AVE

PARKCENTERDR

ENGINEER
ST

GLENCREST
DR
VIEW

CRESTGLEN

SIMPSON WAY

COYOTE HILL GLEN

LOS VALLECITOS BLVD
COX RD

CAMPUSVIEWDR

STATEPL

GENOAWAY
PASEO

PRIVADO

ROLLING HILLS RD
SCOTT
ST

AMBERLN
W

ILLOWBROOK S T

LINDA VISTA DR

COMETCIR

PEARL DR

LATERRAZABLVD
W

ESTLAKEDR
A

LI CANTE WAY

PEBBLEBEACH
DR
ALLEY

MISTYSEA
WAY

COAS T AVE

DECISI ON ST

ARMORLITE DR

SUNSTONEDR
WILD
W

ILLOWHOLLOW

R OBINHOOD
RD
ASHST

SUNNYCREEKRD

N TULIP ST

ALTIVAPL
IV O R
YP
L

PUB LICRD

ACTIVITYDR
CALICO
LN

TORRY CT

SEQUOIA ST

LIONS HEAD AVE

PIONEERAVE
LOMA
ALTA
DR

VIAALLONDRA

DE LEONERD
PUBLIC
TRAIL

CORDOBAWAY

BABILONIA ST

CRESTWI N DRD

GALICIAWAY

UNIVERSITY DR

FIRE LN

LOKER AVEW

MORNINGVIEW
DR

CITY OF VISTA

CITY OF ESCONDIDO

CITY OF CARLSBAD
S.D. COUNTY
S.D. COUNTY
S.D. COUNTY
S.D. COUNTY
S.D. COUNTY
S.D. COUNTY
S.D. COUNTY
S.D. COUNTY
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16 17
18 19
20 21
2223
24 25
26 27
2829
30 31
32 33
34 35
36 37
38 39
40 41
42 43
44 45
4647
48 49
Cumulative Project Map
Pacific Project EIR
SOURCE: SANGIS 2020
0 10.5
Miles
Project Boundary
City of San Marcos
Approved
1 - Block 3 Student Housing
4 - Discovery Village North
6 - San Elijo Hills
7 - Pacific Commercial
12 - Montield Road Partners
14 - Meadowlardk Canyon LLC
15 - JR Legacy II, LLC/Global
16 - Mariposa-Phase 1
19 - Pacifica San Marcos
25 - Southlake Park Phase 1
26 - MacDonald Group
31 - Artis Senior Housing
33 - Jump Ball LLC
38 - Karl Strauss Brewery
Proposed
2 - Carmel Street Apartments
5 - Main Square
13 - Sandy Lane Estates
17 - Mariposa-Phase 2
21 - Breaker Real Estate
22 - Hall Land Compnay
23 - Carkel SM-Starbucks
29 - Lanikai
34 - Montiel Commercial
36 - Budhi Hill Buddhist Center
37 - Mercy Hill and Marian Center
39 - Kiddie Academy
40 - Edenpark
47 - OCRR Redevelopment
48 - AOA/Lab/Artist’s Village
49 - Gran Vista (Meritage Homes)
49 - North City West
Under Construction
3 - Kaiser Permanente Plan
8 - Brookfield Residential
9 - San Marcos Highlands
11 - Villa Serena
18 - Murai-Sab
20 - Discovery Village South
28 - Mission 316 West
30 - Mesa Rim Climbing Gym
32 - Sunrise
41 - San Marcos Creek Phase 1 CIP
Completed
10 - El Dorado II Specific Plan
24 - Fitzpatrick Viewpoint
27 - Mission 24
35 - California Allstars
Funded
42 - CIP 88179
43 - CIP 86002
44 - Park CIP
45 - ST006
FIGURE 2-7
Project Site
2 - PROJECT DESCRIPTION, LOCATION, AND ENVIRONMENTAL SETTING FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 2-46

INTENTIONALLY LEFT BLANK

FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.1-1
3 Environmental Analysis

3.1 Aesthetics
This section describes the existing visual setting of the proposed Pacific Specific Plan Project (proposed project) and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed project.

Table 3.1-1 summarizes the project and cumulative level aesthetics impacts, by threshold.

Table 3.1-1. Aesthetics Summary of Impacts
Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1 – Have a substantial adverse impact on a scenic
vista.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2 – Substantially damage scenic resources,
including but not limited to trees, rock outcroppings,
and historic buildings within a state scenic highway.

No Impact No Impact No Impact
No. 3 – In non-urbanized areas, substantially degrade
the existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage
point). If the project is in an urbanized area, would the project conflict with applicable zoning and other
regulations governing scenic quality?
Less than
Significant
Less than
Significant
Less than
Significant
No. 4 – Create a new source of substantial light or glare which would adversely affect day or nighttime views in
the area.

Less than
Significant
Less than
Significant
Less than
Significant

3.1.1 Existing Conditions
Existing Visual Resources and Environment
Scenic Highways
According to the California Department of Transportation California Scenic Highway Mapping System, the project site is not located adjacent to, or in the vicinity of, a designated state scenic highway (Caltrans 2021). The nearest officially designated state scenic highway is State Route (SR) 78. SR 78 is a designated state scenic highway from the west boundary of the Anza-Borrego Desert State Park to the east boundary of the State Park. SR 78 is located approximately 0.44 miles east of the project site, however the portion designated as a state scenic highway begins approximately 41 miles east of the project site. The project site is located approximately 26 miles west of the closest portion of SR 78 identified as an eligible state scenic highway. The nearest eligible state scenic highway is Interstate (I) 5. I-5 is located approximately 7.3 miles west of the project site.

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At a local level, the City has designated SR 78 as a view corridor for its unobstructed visual passageway. The highway corridor provides views of the Merriam Mountains, Mt . Whitney, Double Peak, California State University San Marcos, and Palomar Community College. Views of the project site from SR 78 are generally obscured for motorists due to existing commercial and residential developments and tall vegetation south of the highway, and due to the speed of motorists on SR 78 (please refer to Figure 3.1-1, Existing Views from State Route 78).

Scenic Vista
A scenic vista is typically defined as a panoramic view or vista from an identified view/vista point, public road, public trails, public recreational areas, or scenic highways. Potential scenic views from private properties are not under consideration in this analysis , as it is not required by the City . The City ’s General Plan does not identify any designated scenic vistas; however, the General Plan more generally aims to protect the City’s scenic resources such as the San Marcos, Merriam, and Double Peak Mountains, creek corridors, mature trees, rock outcroppings, and ocean views (City of San Marcos 201 2). The project site is surrounded by urban development areas. Potential vantage points in the City include Mt. Whitney and Franks Peak, located approximately 3 miles southwest of the project site. There is a potential for the project site to be visible from the Mt. Whitney peak; however, this peak is accessible only by a private road and peak access is prohibited to the public. The Franks Peak summit is accessible by various public recreational trails, which could serve as potential vantage points of the project site. Views of the project site from Franks Peak and associated trails would be partially obstructed by Mt. Whitney. Double Peak is also a prominent landform with long and broad views located approximately 3 miles southwest of the project site; however, views of the project site from Double Peak are entirely obstructed by various ridgelines.

Visual Character istics
The following is a description of the existing visual characteristics and quality of the project site and surroundings.

Project Site
The approximately 33-acre project site is an undeveloped lot located in the western portion of the City at the northwest corner of South Las Posas Road and Linda Vista Drive . La Mirada Road abuts the site ’s northern boundary, while Pacific Street abuts the property’s western boundary. The Grand Plaza shopping center is located directly across Las Posas Drive. Light industrial uses are adjacent to the site ’s northern, southern, and western boundary, and Bradley park is located across from the site ’s southwestern corner. Single - and multifamily residential uses are located to the west and south of Bradley park. The project location and project site boundary are shown on Figures 2-1 and 2-2 in Chapter 2, Project Description, of this Environmental Impact Report (EIR). The project site is immediately visible from adjacent streets and surrounding land uses.

The undeveloped project site is 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, Biological Technical Report). 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 above mean sea level in the northwest corner of the project site. As described in the Biological Technical Report (Appendix C), seven vegetation communities or habitat types occur within the project site: vernal pools, Diegan coastal sage scrub (including disturbed and baccharis-dominated), native grassland, non-native grassland, disturbed habitat, and urban/developed.

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Surrounding Area
The project site is immediately bordered by Las Posas Road to the east, Linda Vista Drive to the south, La Mirada Road along the northern boundary and Pacific Street abuts the property ’s western boundary. The project site is surrounded by industrial uses to the north, south, and west, and commercial uses to the east, specifically the Grand Plaza shopping center is located directly across Las Posas Drive. The 24 -acre Bradley park is located across from the sites ’ southwestern corner. Residential uses are located to the south and west of Bradley park.

The project site is located in an urban setting and is considered an infill site. Surrounding land uses outside of the immediately adjacent industrial and commercial land uses inclu de designated parks, single and multifamily residential, and schools/educational facilities. The closest freeway is SR 78 located approximately 0. 44 miles east of the project site.

The existing Industrial developments to the north, northwest, and west of the project site , and the existing Light Industrial developments to the south and southwest of the project site, are characterized by one to two story buildings with white or tan smooth exteriors.

The existing Commercial development to the east is a local mall that is comprised of various retail department stores and restaurants. These buildings are one to two story buildings with tan or white exteriors and with grey brick accents. The existing park to the southwest of the project site is Bradley park, which is located at 1587 Linda Vista Drive and contains an arena soccer field, a ballfield, BBQs, a horseshoe court, a multi-purpose field, picnic shelters, picnic tables, and play equipment.

Existing Light and Glare Conditions
The project site is currently undeveloped and thus does not contain any existing sources of light or glare.

Additionally, the project site does not contain any reflective surfaces that would act as sources for glare. Commercial and industrial developments surrounding the project site contain sources of light ing typical of these land uses .

Sources of nighttime lighting in this area could occur from exterior building lighting, street lighting, lighting in parking lots, and vehicles traveling along the adjacent roadways. No sources of substantial glare are present in this area.

3.1.2 Regulatory Setting
State
California Public Resources Code , Section 20199
California Public Resources Code (PRC) Section 20199 (d)(1) stipulates that “ aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment.” The proposed project would qualify as a residential project on an infill site within a transit priority area. This is further addressed in Section 3.1.4, Project Impact Analysis.

California Scenic Highway Program
The California State Legislature created the California Scenic Highway Program in 1963 with the intent “to protect and enhance the natural scenic beauty of California highways and adjacent corridors, through special conservation treatment.” The state laws that govern the Scenic Highway Program are Sections 260 through 263 of the Streets and Highways Code. A highway may be designated scenic based on the natural landscape visible by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the views of the highway. The Scenic

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Highway Program includes both officially designated scenic highways and highways that are eligible for designation. A highway may be designated as scenic based on aesthetic quality of viewable landscape, extent of views upon the natural landscape, and the degree to which development impedes these views. It is the responsibility of local jurisdictions to apply for scenic highway approval, which requires the adoption of a Corridor Protection Program (Caltrans 2022). There are no state-designated scenic highways in the vicinity of the project site.

Local
City of San Marcos General Plan
The City’s Conservation and Open Space Element identifies one goal and associated policies to protect natural resources that have scenic value. Landforms such as the mountain ranges in the northern and southern portions of the City contribute to its scenic corridors. The following goal and policies from the City of San Marcos General Plan Conservation and Open Space Element pertain to aesthetics and visual quality (City of San Marcos 2012):

Goal COS-3 Protect natural topography to preserve and enhance the natural beauty of San Marcos.

Policy COS-3.1: Preserve scenic resources, including prominent landforms such as Double Peak, Owens Peak, San Marcos Mountains, Merriam Mountains, Cerro de Las Posas, Franks Peak, and canyon areas through conservation and management policies.

Policy COS-3.2: Encourage and maintain high-quality architectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character in San Marcos.

Policy COS -3.3: Continue to work with new development and redevelopment project applicants in designing land use plans that respect the topography, landforms, view corridors, wildlife corridors, and open space that exists.

Policy COS-3.4: Evaluate potential impacts to visual and aesthetic resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

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 3.10.4, Project Impact Analysis, the project is consistent with the applicable goals and policies pertaining to aesthetics.

San Marcos Municipal Code Zoning Ordinance , Title 20
The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance. The San Marcos Municipal Code Zoning Ordinance Title 20 is the primary implementation tool for the policies of the General Plan. The Zoning Ordinance provides more detailed direction related to design and development standards; permitted, conditionally permitted, and prohibited uses; and other regulations such as lighting and sign regulations.

The land uses specified in the Zoning Ordinance are based upon and consistent with the land use policies set forth in the General Plan. Specifically, building design, setbacks, lighting, and signage standards as well as open space requirements for development to protect open space and ambient light levels in the City. Lighting standards of the Ordinance require energy -efficient lighting that limits light and glare for private projects, with exceptions for specialized streetscape lighting. Private developments are required to submit lighting plans to ensure consistency with dark sky needs of the region (City of San Marcos Municipal Code Zoning Ordinance, Title 20).

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Title 20, Section 20.300.080, Site Planning and General Development Standards The City of San Marcos Street Lighting Standards and Specifications describes the lighting and glare standards for the City. These standards require lighting to be directed downward and limit the type and spacing of lighting to maintain reasonable lighting levels that do not contribute to light pollution. The City uses International Dark Sky Association thresholds to inform its own testing, leading to a policy that allows for the use of energy-efficient lighting sources that include, but are not limited to, LED and induction lighting technologies (City of San Marcos 2022).

Title 20, Chapter 20.260, Ridgeline Protection and Management Overlay Zone The City of San Marcos adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008-1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, mi nimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, or Ridgeline Overlay Zones, surrounding these ridgelines (City of San Marcos 20 22). No primary or secondary ridgelines are located within or adjacent to the project site; the nearest ridgeline is a secondary ridgeline located approximately 1.25 miles west of the project site. The nearest primary ridgeline is located approximately

1.75 miles southwest of the project site.

3.1.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to aesthetics 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 aesthetics would occur if the project would:

Threshold No. 1: Have a substantial adverse effect on a scenic vista.

Threshold No. 2: Substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway.

Threshold No. 3: In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Threshold No. 4: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

3.1.4 Project Impact Analysis
As described in Chapter 2 of this EIR, the proposed project consists of development of 449 residential units, including a mix of apartments, rowhomes, villas, and affordable flats on approximately 15.09 acres within the approximately 33.2-acre project site. Proposed residential units would include a mix of apartments within a five- story podium building, three-story rowhomes, three-story villas, and affordable flats within a four-story building. The project would also include a total of 927 parking spaces and a 134,985-square-foot common open space area. The project would incorporate landscaping, bio-retention areas, and circulation improvements. The remaining 17.94 acres of the approximately 33.2-acre project site would be preserved and restored open space and habitat area.

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The proposed project would have a density of approximately 29.8 dwelling units per acre, not including the proposed open space and habitat area. With the open space and habitat area included, the density of the proposed project would be approximately 13.5 dwelling units per acre.

The proposed project site is considered an infill site within an urbanized area under CEQA but is not located within a transit priority area such that aesthetic impacts are conclusively not significant under PRC Section 20199 (d)(1).

As described in Section 3.1.2, Regulatory Setting, PRC Section 20199 (d)(1) states that “aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment.” According to Section 21099(d)(1), an “infill site” is defined as “a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 % of the perimeter of the site adjoins, or is separated only by an improved public right -of-way from, parcels that are developed with qualified urban uses.” The project site is located on a vacant lot and more than 75% of the project boundary is adjacent to “qualified urban uses” (i.e., residential and commercial) per PRC Section 21072, such that the site is an “infill site.”
PRC Section 21071 defines an “urbanized area” as “(a) an incorporated city that meets either of the following criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.” As of 2020, the City of San Marcos has an estimated population of 97,209 (see Section 3.12, Population and Housing ). While this is less than 100,000 persons, the City of San Marcos is contiguous with the City of Escondido, which has an estimated population of 151,625 persons as of 2019 (U.S. Census Bureau 2019). The combined estimated population of these two contiguous cities is 248,834 persons, which is well over the 100,000 persons threshold. Thus, the City of San Marcos would be considered an urbanized area per CEQA.

A “transit priority area” is defined as “an area within one-half mile of a major transit stop that is existing or planned.” The project site is located approximately 0.6 miles from the North County Transit District (NCTD) Palomar College Station, and therefore just outside of the transit priority area. Accordingly, while the proposed project is a residential project on an infill site in an urbanized area in close proximity to transit, further analysis is needed to evaluate the significance of aesthetic impacts.

Threshold No. 1: Would the project have a substantial adverse effect on a scenic vista? The City’s General Plan does not identify any designated scenic vistas; however, the General Plan more generally aims to protect the City’s scenic resources such as the San Marcos, Merriam, and Double Peak Mountains, creek corridors, mature trees, rock outcroppings, and ocean views. The project site and surrounding valley terrain are encompassed by mountains to the west and south that provide opportunities for elevated vantage points offering long and broad views, which may include views of the project site. However, due to the relatively flat terrain of the project site and surrounding area, and the project site’s location on an infill site in an urbanized area, development of the proposed project is not expected to impede views of existing scenic vistas, nor is the project site considered a scenic vista. Therefore, impacts related to aesthetic impacts are considered less than significant.

Threshold No. 2: Would the project substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway? SR 78 is located 0. 44 miles east of the project site. However, as previously discussed, the section of SR 78 proximate to the project site is not identified as a Scenic Highway per the California Department of Transportation State Scenic Highways Program, although the City has designated SR 78 as a view corridor to surrounding

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ridgelines. Additionally, a portion of SR 78 is also identified as an Eligible State Scenic Highway; however, this eligible segment begins 26 miles east of the project site in Santa Ysabel. The nearest eligible state scenic highway is I-5. I-5 is located approximately 7.3 miles west of the project site and is not visible due to distance . Therefore, the project site is not located within a viewshed of a state scenic highway.

As described above, views of the project site from SR 78 are generally limited due to existing commercial and residential developments, existing vegetation, and the speed of motorists on SR 78. Even with development of the proposed project, views of the surrounding hillsides and ridgelines would not be substantially obstructed from SR 78 (please refer to Figure 3.1 -2, Proposed Views from State Route 78 ). The project site is not located within a ridgeline or view corridor and is surrounded on all sides by existing development.

Further, the project site is currently undeveloped and does not support any historic buildings. There are also no rock outcroppings or trees on site. Therefore, implementation of the proposed project would not substantially damage scenic resources within a state scenic highway, and no impact would occur.

Threshold No. 3: Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
As previously discussed, the City of San Marcos (which includes the project site) is considered an urbanized area pursuant to PRC Section 21071. Therefore, the first question of Threshold No. 3 does not apply to the proposed project, as it is directed at non-urbanized areas.

The visual character of the site would be altered by the proposed project, as it would change the existing vacant and undeveloped site to residential development. While the proposed project would change the existing visual character on the site, it is not characterized as substantial degradation since few public vantage points of the project site exist and the site is entirely surrounded by adjacent development in a highly urbanized area. Although the proposed residential uses would differ in land use designation and visual character in comparison to the immediately surrounding industrial land uses, the proposed residential development would conform to the existing urbanized character of the surrounding area and would not substantially change the views from any public viewpoint. With City approval of the proposed land use and zoning change from Industrial to Specific Plan Area, the proposed project would be required to comply with design standards of the approved Specific Plan for the project site. Renderings of the proposed villas, rowhomes, apartments, and affordable units are sho wn in Figures 2 -6a through 2-6d in Chapter 2 of this EIR. Additionally , a landscape plan would be implemented to soften the visual impact of the proposed residential development from adjacent roadways and land uses.

The Conservation and Open Space Element of the City ’s General Plan recognizes the habitat and scenic value of natural and cultural open spaces within the City and lists goals and policies that ensure long -term stewardship of these resources. As outlined in Section 3.10, Land Use and Planning, of this EIR, the project would not conflict with the goals of the Conservation and Open Space Element , nor any other City goals or policies , or zoning ordinance related to scenic quality, including the City’s Ridgeline Protection and Management Overlay Zone. As the proposed project would not substantially degrade the existing visual character or quality of the site and its surroundings , impacts are considered to be less than significant.

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Threshold No. 4: Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Lighting
Lighting in the project vicinity is associated with roadway lighting and lighting associated with the existing commercial and industrial uses that surround the project site. Development of the proposed project would result in new sources of light from the residential units, landscaping lighting, security lighting, and internal circulation and pedestrian lighting. These proposed land uses would introduce lighting to a site that is currently undeveloped and has no existing source of lighting.

All lighting associated with the project would be required to comply with the City’s Municipal Code Section 20.300.080, Light and Glare Standards. Although the proposed project would result in new sources of light in the area, the project site is in an urbanized area and is surrounded by existing development with existing sources of day and nighttime lighting. Compliance with the City’s Municipal Code would minimize and restrict nighttime light pollution and light trespass on adjacent properties. Therefore, new sources of day or nighttime lighting associated with the project would not be considered substantial, and impacts related to lighting would be considered less than significant.

Glare
Implementation of the proposed project could potentially include sources of glare from architectural finishes or amenities on-site. The project developer would be required by the City’s Municipal Code Section 20.300.080, Light and Glare Standards, 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-generated glare. As shown in the project renderings (Figures 2 -6a through 2 -6d in Chapter 2 of this EIR), the proposed developme nt would incorporate materials and finishes that would minimize the potential for glare, including set back windows, window awnings, and neutral colors for building facades. The proposed project would not propose any features that would be characterized as creating a substantial new source of glare that would adversely affect daytime or nighttime views in the area. Project impacts related to aesthetic impacts are considered less than significant.

3.1.5 Mitigation Measures
No significant impacts to aesthetics were identified. Therefore, no mitigation measures are required.

3.1.6 Conclusion
In summary , the project would not be built upon any primary or secondary ridgelines , nor would the project substantially affect a scenic vista. The project site is not located in close proximity to a designated State Scenic Highway per the California Department of Transportation State Scenic Highway Program . Although the City has designated SR 78 as a view corridor to surrounding ridgelines, the project would not significantly change views from SR 78, and the project would not impede views to any primary or secondary ridgelines from SR 78.

The project site is located in an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality , including the scenic resource protection policies in the Conservation and Open Space Element of the City’s General Plan (refer to Section 3.10). Implementation of the proposed project would reasonably result in changes to the visual character of the site by allowing residential development; however, the potential for a significant visual impact to occur would be reduced due to a general lack of public vantage points and visual

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conformance with adjacent development. Landscaping associated with the project would also reduce views of the project from adjacent uses by blending the buildings into the visual setting and/or providing visual screening.

Concerning lighting and glare, the proposed project would not include highly reflective finishes or excessive lighting.

Further, any exterior nighttime lighting associated with the project would be required to comply with the City’s Street Lighting Standards and Specifications and Municipal Code.

It has been determined that implementation of the proposed project would not result in any potential impacts related to aesthetics, and impacts would be less than significant with no mitigation required.

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Pacific Project EIR
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3.2 - AIR QUALITY
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3.2 Air Quality
This section evaluates the potential impacts on air quality of the proposed Pacific Specific Plan Project (proposed project) and their contribution to regional air quality conditions , identifies associated regulatory requirements, and recommends mitigation measures to reduce impacts to a level below significant . This section is based on the Air Quality and Greenhouse Gas Emissions Technical Report for the Pacific Project (Air Quality and Greenhouse Gas Emissions Technical Report) prepared by Dudek in February 2023. The complete Air Quality and Greenhouse Gas Emissions Technical Report is included as Appendix B of this environmental impact report (EIR).

Table 3.2 -1 summarizes the project - and cumulative -level air quality impacts under each applicable threshold of significance .

Table 3.2-1. Air Quality Summary of Impacts
Threshold of Significance
Project
Direct
Impact
Project
Cumulative
Impact
Significance
Determination
No. 1 - Conflict with or obstruct implementation of
the applicable air quality plan.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2 - Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is in non-attainment under an
applicable federal or state ambient air quality
standard.

Less than
Significant
with
Mitigation
Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
No. 3 - Expose sensitive receptors to substantial
pollutant concentrations.

Less than
Significant
with
Mitigation
Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
No. 4 - Result in other emissions (such as those
leading to odors) adversely affecting a substantial
number of people.

Less than
Significant
Less than
Significant
Less than
Significant

The project would consist of a GPA/Rezone to convert the existing Industrial (I) land use designation to Specific Plan Area. The project would be required to adhere to the following regulatory measures to ensure compliance with the applicable City of San Marcos (City) Climate Action Plan Checklist measures (City of San Marcos 2020a):

Electric Vehicle Charging Stations. The project will include 927 total parking spaces. 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.

Bicycle Infrastructure. The project will include the following roadway and bicycle improvements:

Active Transportation Improvements
Construct sidewalks to close sidewalk gaps on the site frontage on La Mirada Drive, Pacific Street, and Linda Vista Drive.

Construct or preserve space for the portions of proposed bicycle facilities on Linda Vista Drive from Pacific Street to South Las Posas Road immediately adjacent to the site.

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Provide transit stop amenities including, at a minimum, bench, shelter, and trash can at the southbound stop at the intersection of South Las Posas Road/Linda Vista Drive located on the southwest corner of the intersection.

Transportation Demand Management. The project will develop and implement a Transportation Demand Management plan that will include all of the strategies below:
▪ Provide discounted monthly transit pass or provide at least 25% transit fare subsidy to residents/employees. ▪ Provide designated car-share, carpool, vanpool, and/or park-and-ride parking spaces. ▪ Provide pedestrian connections between all internal uses and to all existing or planned external streets around the project site(s).
▪ Provide secure bicycle parking spaces or bicycle racks, showers, and clothes lockers. ▪ Encourage telecommuting for employees (allow 1 telecommute day per week or compressed work weeks) or provide a telecommute work center with common office space and equipment available to residents.

Water Heaters. The project will install one of, or a combination of, the following water heater types in place of natural gas water heaters:
▪ Electric heat pump water heater
▪ Instantaneous electric water heater
▪ Electric tank
▪ Solar water heater with heat pump water heater backup ▪ Solar water heater with electric tank backup
Landscaping Water Use. The project's landscaping would meet the requirements within the City's Water Efficient Landscape Ordinance. As prescribed in Section 4.3.1 of the specific plan, The selected plants are well suited to the local soils and have proven to flourish within the project area’s climate and are consistent with Assembly Bill 1881 requirements and the City of San Marcos Water Efficient Landscape Ordinance and Municipal Code, Title 20. The project will include composting, climate adapted plants, mulch, minimal use of turf, and smart water -efficient irrigation systems to minimize water use.

Urban Tree Canopy. The project is providing 927 parking spaces and will plant approximately 517 trees.

3.2.1 Existing Conditions
This section introduces the environmental setting of the proposed project area, including the meteorological/ climate conditions for the project area, current physical setting, and pollutant levels in proximity to the proposed project.

Climate and Topography
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average summertime high temperature in the region is approximately 74°F. The average wintertime low temperature is approximately 49°F. Average precipitation in the local area is approximately 10 inches per year, with the bulk of precipitation falling between December and March (WRCC 2017).

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The topography in the San Diego region varies greatly, from beaches on the west to mountains and desert on the east; along with local meteorology, topography influences the dispersal and movement of pollutants in the air basin.

The mountains to the east prevent dispersal of pollutants in that direction and help trap them in inversion layers.

The interaction of ocean, land, and the Pacific High-Pressure Zone maintains clear skies for much of the year and influences the direction of prevailing winds (westerly to northwesterly). Local terrain is often the dominant factor inland, and winds in inland mountainous areas tend to blow through the valleys during the day and down the hills and valleys at night.

Baseline Air Quality
Regional
The project site is located in the land use jurisdictions of the City of San Marcos (City) , within the San Diego Air Basin (SDAB) under the jurisdiction of the San Diego Air Pollution Control District (SDAPCD). The SDAB is 1 of 15 air basins that geographically divide the State of California.

The SDAB lies in the southwest corner of California and comprises the entire San Diego region, covering 4,260 square miles, and it is an area of high air pollution potential. The SDAB experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The SDAB experiences frequent temperature inversions. Subsidence inversions occur during the warmer months as descending air associated with the Pacific High-Pressure Zone meets cool marine air. The boundary between the two layers of air creates a temperature inversion that traps pollutants. Another type of inversion, a radiation inversion, develops on winter nights when air near the ground cools by heat radiation and the air aloft remains warm. The shallow inversion layer formed between these two air masses also can trap pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur that produce ozone (O3), commonly known as smog (CARB 2019a).

Regional air quality can be best characterized from ambient measurements made by the SDAPCD. SDAPCD operates a network of ambient air monitoring stations throughout San Diego County, which measure ambient concentrations of pollutants and determine whether the ambient air quality meets the California Ambient Air Quality Standards (CAAQS) and the National Ambient Air Quality Standards (NAAQS). These standards are set by the U.S.

Environmental Protection Agency (EPA) or California Air Resources Board (CARB) for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare.

Pursuant to the 1990 Clean Air Act (CAA) amendments, the EPA classifies air basins (or portions thereof) as “attainment” or “nonattainment” for each criteria air pollutant, based on whether the NAAQS have been achieved.

Generally, if the recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that pollutant. If an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. If there is not enough data available to determine whether the standard is exceeded in an area, the area is designated as “unclassified” or “unclassifiable.” The designation of “unclassifiable/attainment” means that the area meets the standard or is expected to meet the standard despite a lack of monitoring data. Areas that achieve the standards after a nonattainment designation are re-designated as maintenance areas and must have approved maintenance plans to ensure continued attainment of the standards. The California Clean Air Act, like its federal counterpart, calls for the designation of areas as “attainment” or “nonattainment,” but based on the CAAQS rather than the NAAQS.

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Current attainment designations for the SDAB for the criteria pollutants are presented in Table 3.2 -2. As shown, SDAB is currently classified as a federal nonattainment area for O3 and a state nonattainment area for particulate matter less than or equal to 10 microns (coarse particulate matter [PM10]), particulate matter less than or equal to

2.5 microns (fine particulate matter [PM 2.5]), and O 3. The portion of the SDAB where the project site is located is designated as attainment or unclassifiable/unclassified for all other criteria pollutants under the NAAQS and CAAQS (Appendix B).

Table 3.2-2. San Diego Air Basin Attainment Classification Pollutant Federal Designation State Designation
O3 (1-hour) Attainmenta Nonattainment
O3 (8-hour–1997)
(8-hour–2008)
Attainment (maintenance)
Nonattainment (moderate)
Nonattainment
NO2 Unclassifiable/attainment Attainment
CO Attainment (maintenance) Attainment
SO2 Unclassifiable/attainment Attainment
PM10 Unclassifiable/attainment Nonattainment
PM2.5 Unclassifiable/attainment Nonattainment
Lead Unclassifiable/attainment Attainment
Sulfates No federal standard Attainment
Hydrogen sulfide No federal standard Unclassified
Visibility-reducing particles No federal standard Unclassified Vinyl chloride No federal standard No designation
Sources: EPA 2020 (federal); CARB 2021a (state).

Notes: O3 = ozone; NO2 = nitrogen dioxide; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter.

Attainment = meets the standards; attainment/maintenance = achieve the standards after a nonattainment designation; nonattainment = does not meet the standards; unclassified or unclassifiable = insufficient data to classify; unclassifiable/attainment = meets the standard or is expected to be meet the standard despite a lack of monitoring data. a The federal 1-hour standard of 0.12 parts per million (ppm) was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in State Implementation Plans.

Local
As previously mentioned, SDAPCD operates a network of ambient air monitoring stations throughout San Diego County that measure ambient concentrations of pollutants and determine whether the ambient air quality meets the CAAQS and NAAQS. SDAPCD monitors air quality conditions at 11 locations throughout the SDAB. Camp Pendleton monitoring station is the closest to the project site for O3 and NO2. The Escondido–East Valley Parkway monitoring station ceased to collect data post -2015; thus, due to proximity to the site and similar geographic and climactic characteristics, the San Diego –11403 Rancho Carmel Drive monitoring station concentrations are considered most representative for the project site. Data at this station also was available for CO. The El Cajon – Lexington Elementary School monitoring station was used for sulfur dioxide ( SO2), PM 10, and PM 2.5. Ambient concentrations of pollutants from 2019 through 2021 are presented in Table 3.2 -3. Air quality within the project region was in compliance with the CAAQS and NAAQS for nitrogen dioxide (NO2), carbon monoxide (CO), SO2, and PM10 (NAAQS only) during this monitoring period (Appendix B).

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Table 3.2-3. Local Ambient Air Quality Data
Averaging
Time Unit
Agency/
Method
Ambient
Air
Quality
Standard
Measured Concentration
by Year Exceedances by Year
201 9 2020 2021 2019 2020 2021
Ozone (O 3) – Camp Pendleton
Maximum
1-hour
concentration
ppm State 0.09 0.075 0.094 0.074 0 0 0
Maximum
8-hour
concentration
ppm State 0.070 0.065 0.074 0.059 0 3 0
Federal 0.070 0.064 0.074 0.059 0 3 0
Nitrogen Dioxide (NO 2) – Camp Pendleton
Maximum
1-hour
concentration
ppm State 0.18 0.053 0.058 0.059 0 0 0
Federal 0.100 0.053 0.058 0.059 0 0 0
Annual
concentration
ppm State 0.030 0.005 0.006 0.006 — — —
Federal 0.053 0.005 0.006 0.006 — — —
Carbon Monoxide (CO) – San Diego – 11403 Rancho Carmel Dr ive Maximum
1-hour
concentration
ppm State 20 4.1 3.3 3.0 0 0 0
Federal 35 4.1 3.3 3.0 0 0 0
Maximum
8-hour
concentration
ppm State 9.0 2.5 1.7 1.8 0 0 0
Federal 9 2.5 1.7 1.8 0 0 0
Sulfur Dioxide (SO 2) – El Cajon – Lexington Elementary School Maximum
1-hour
concentration
ppm Federal 0.075 0.0008 0.002 0.002 0 0 0
Maximum
24-hour
concentration
ppm Federal 0.14 0.0003 0.0004 0.0003 0 0 0
Annual
concentration
ppm Federal 0.030 0.0001 0.0001 0.0001 — — —
Coarse Particulate Matter (PM 10)a – El Cajon – Lexington Elementary School Maximum
24-hour
concentration
g/m3 State 50 37.4 55.0 40.0 0.0 (0) 0.0 (0) 0.0 (0)
Federal 150 38.7 55.0 40.0 0.0 (0) 0.0 (0) 0.0 (0)
Annual
concentration
g/m3 State 20 ND ND ND — — —

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Table 3.2-3. Local Ambient Air Quality Data
Averaging
Time Unit
Agency/
Method
Ambient
Air
Quality
Standard
Measured Concentration
by Year Exceedances by Year
201 9 2020 2021 2019 2020 2021
Fine Particulate Matter (PM 2.5 )a – El Cajon – Lexington Elementary School Maximum
24-hour
concentration
g/m3 Federal 35 23.8 38.2 30.2 — — —
Annual
concentration
g/m3 State 12 8.6 10.3 9.7 — — —
Federal 12.0 8.6 10.3 9.7 — — —
Sources: CARB 2021b; EPA 2021.

Notes: ppm = parts per million by volume; ND = insufficient data available to determine the value; — = not available; g/m3 = micrograms per cubic meter.

Data taken from CARB iADAM (http://www.CARB.ca.gov/adam) and EPA AirData (http://www.epa.gov/airdata/) represent the highest concentrations experienced over a given year.

Daily exceedances for particulate matter are estimated days because PM 10 and PM 2.5 are not monitored daily. All other criteria pollutants did not exceed federal or state standards during the years shown. There is no federal standard for 1 -hour ozone, annual PM10, or 24-hour SO2, nor is there a state 24-hour standard for PM2.5.

Camp Pendleton monitoring station is located at 21441 West B Street, Camp Pendleton, California.

San Diego monitoring station is located at 11403 Rancho Carmel Drive, San Diego, California.

The El Cajon-Lexington Elementary School monitoring station is located at 533 First Street, El Cajon, California. a Measurements of PM10 and PM2.5 are usually collected every 6 days and every 1 to 3 days, respectively. Number of days exceeding the standards is a mathematical estimate of the number of days concentrations would have been greater than the level of the standard had each day been monitored. The numbers in parentheses are the measured number of samples that exceeded the standard.

Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by CARB, include children, older adults, and people with cardiovascular and chronic respiratory diseases. Sensitive receptors include residences, schools, playgrounds, childcare centers, long -term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes. The SDAPCD identifies sensitive receptors as those who are especially susceptible to adverse health effects from exposure to toxic air contaminants, such as children, the elderly, and the ill. Sensitive receptors include schools (grades Kindergarten through 12), day care centers, nursing homes, retirement homes, health clinics, and hospitals within 2 kilometers of the facility (SDAPCD 2019). The closest existing sensitive receptors to the project site are single -family residents located approximately 150 feet west of the northwest corner of the project site, 1,420 feet southwest of the project site, TERI Country School located approximately 1,100 feet (0.2 miles) southeast of the project site, and La Mirada Academy located approximately 1,600 feet (0.4 miles) northwest of the project site.

Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. Pollutants of concern include O3, NO2, CO, SO2, PM10, PM2.5, and lead. These pollutants, as well as toxic

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air contaminants (TACs), are discussed in the following text.1 In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility-reducing particles are also regulated as criteria air pollutants.

Ozone. O3 is a strong -smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O 3 precursors. These precursors are mainly oxides of nitrogen ( NOx) and volatile organic compounds (VOCs). The maximum effects of precursor emissions on O3 concentrations usually occur several hours after they are emitted and many miles from the source. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists in the upper atmosphere O 3 layer (stratospheric O3) and at the Earth’s surface in the troposphere (ground-level O3/ozone).2 The O3 that the EPA and CARB regulate as a criteria air pollutant is produced close to the ground level, where people live, exercise, and breathe. Ground-level O3 is a harmful air pollutant that causes numerous adverse health effects and is thus considered “bad” O3. Stratospheric, or “good,” O3 occurs naturally in the upper atmosphere, where it reduces the amount of ultraviolet light (i.e., solar radiation) entering the Earth’s atmosphere.

Without the protection of the beneficial stratospheric O3 layer, plant and animal life would be seriously harmed.

O3 in the troposphere causes numerous adverse health effects. Short-term exposures (lasting for a few hours) to O3 at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes (EPA 2013). Inhalation of O3 causes inflammation and irritation of the tissues lining human airways, causing and worsening a variety of symptoms. Exposure to O 3 can reduce the volume of air that the lungs breathe in, thereby causing shortness of breath. O 3 in sufficient doses increases the permeability of lung cells, rendering them more susceptible to toxins and microorganisms. The occurrence and severity of health effects from O 3 exposure vary widely among individuals, even when the dose and the duration of exposure are the same. Research shows adults and children who spend more time outdoors participating in vigorous physical activities are at greater risk from the harmful health effects of O 3 exposure. Available studies show that children are no more or less likely to suffer harmful effects than adults. However, it has been posited that children may be more susceptible to O 3 and other pollutants compared to adults for several reasons. Children and teens spend nearly twice as much time outdoors and engaged in vigorous activities as adults. Children breathe more rapidly than adults and inhale more pollution per pound of their body weight than adults. Also, children are less likely than adults to notice their own symptoms and avoid harmful exposures. Further research may be able to better distinguish between health effects in children and adults. Children, adolescents , and adults who exercise or work outdoors, where O 3 concentrations are the highest, are at the greatest risk of harm from this pollutant (CARB 2019b). Health problems are also particularly acute in sensitive receptors such as the sick and elderly.

Nitrogen Dioxide. NO2 is a brownish, highly reactive gas that is present in all urban atmospheres. The major mechanism for the formation of NO 2 in the atmosphere is the oxidation of the primary air pollutant nitric oxide, which is a colorless, odorless gas. NO x plays a major role, together with VOCs, in the atmospheric reactions that produce O 3. NO x is formed from fuel combustion under high temperature or pressure. In addition, NO x is an important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. The two major emissions sources are transportation and stationary fuel combustion sources such as electric utility and industrial boilers.

1 The descriptions of health effects for each of the criteria air pollutants associated with project construction and operation s are based on the U.S. Environmental Protection Agency’s “Criteria Air Pollutants” (EPA 2016) and CARB’s “Glossary of Air Polluti on Terms” (CARB 2019a).
2 The troposphere is the layer of the Earth’s atmosphere nearest to the surface of the Earth. The troposphere extends outward about 5 miles at the poles and about 10 miles at the equator.

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Exposure to NO2 can induce adverse health effects. NO 2 exposure can intensify responses to allergens in allergic asthmatics. A number of epidemiological studies have demonstrated associations between NO 2 exposure and premature death, cardiopulmonary effects, decreased lung function growth in children, respiratory symptoms, emergency room visits for asthma, and intensified allergic responses. Infants and children are particularly at risk because they have disproportionately higher exposure to NO2. Long--term NO2 exposure during childhood can lead to smaller lungs at maturity in children with higher levels of exposure compared to children with lower exposure levels. Children with asthma have a greater degree of airway responsiveness compared with adult asthmatics. In adults, the greatest risk is to people who have chronic respiratory diseases, such as asthma and chronic obstructive pulmonary disease (CARB 2019c).

Carbon Monoxide. CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon, or fossil fuels.

CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains. In urban areas, such as the project location, automobile exhaust accounts for the majority of CO emissions. CO is a nonreactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal distributions of vehicular traffic. CO concentrations are influenced by local meteorological conditions—primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface-based temperature inversions are combined with calm atmospheric conditions, which is a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during the colder months of the year, when inversion conditions are more frequent.

CO is harmful to humans in terms of health effects because it binds to hemoglobin in the blood, reducing the ability of blood to carry oxygen. This interferes with oxygen delivery to the body’s organs. The most common effects of CO exposure are fatigue, headaches, confusion and reduced mental alertness, light-headedness, and dizziness due to inadequate oxygen delivery to the brain. For people with cardiovascular disease, short-term CO exposure can further reduce their body’s already compromised ability to respond to the increased oxygen demands of exercise, exertion, or stress. Inadequate oxygen delivery to the heart muscle leads to chest pain and decreased exercise tolerance. Unborn babies whose mothers experience high levels of CO exposure during pregnancy are at risk of adverse developmental effects. Unborn babies, infants, elderly people, and people with anemia or with a history of heart or respiratory disease are most likely to experience health effects with exposure to elevated levels of CO (CARB 2019d).

Sulfur Dioxide. SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfur -containing fossil fuels. The main sources of SO 2 are coal and oil used in power plants and industries; as such, the highest levels of SO 2 are generally found near large industrial complexes. In recent years, SO 2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the sulfur content of fuels.

SO2 is of concern both because it is a direct respiratory irritant and because it contributes to the formation of sulfate and sulfuric acid in particulate matter (NRC 2005). Controlled human exposure and epidemiological studies show that children and adults with asthma are more likely to experience adverse responses with SO2 exposure, compared with the non-asthmatic population (CARB 2019e). Effects at levels near the 1 -hour standard are those of asthma exacerbation, including bronchoconstriction accompanied by symptoms of respiratory irritation such as wheezing, shortness of breath, and chest tightness, especially during exercise or physical activity. People with asthma are thus of particular concern, both because they have increased baseline airflow resistance and because their SO 2- induced increase in airflow resistance is greater than in healthy people, and it increases with the severity of their asthma (NRC 2005). SO2 is thought to induce airway constriction via neural reflexes involving irritant receptors in the airways (NRC 2005). In addition, exposure at elevated levels of SO2 (above 1 part per million [ppm]) results in increased incidence of pulmonary symptoms and disease, decreased pulmonary function, and increased risk of

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mortality (CARB 2019e). The elderly and people with cardiovascular disease or chronic lung disease (such as bronchitis or emphysema) are most likely to experience these adverse effects (CARB 2019e).

Particulate Matter. Particulate matter (PM) pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. PM can form when gases emitted from industries and motor vehicles undergo chemical react ions in the atmosphere. PM 2.5 and PM 10 represent fractions of particulate matter. PM10 consists of particulate matter that is 10 microns or less in diameter and is about 1/7 the thickness of a human hair. Major sources of PM10 include crushing or grinding operations; dust stirred up by vehicles traveling on roads; wood-burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; a nd atmospheric chemical and photochemical reactions. PM2.5 consists of particulate matter that is 2.5 microns or less in diameter and is roughly 1/28 the diameter of a human hair. PM 2.5 results from fuel combustion (e.g., from motor vehicles and power generation and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOx), NOx, and VOCs.

PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM 2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the bloodst ream, causing damage elsewhere in the body. Additionally, these substances can transport adsorbed gases such as chlorides or ammonium into the lungs, also causing injury.

Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and discolor surfaces on which they settle and produce haze and reduce regional visibility.

A number of adverse health effects have been associated with exposure to PM 2.5 and PM10. For PM2.5, short-term exposures (up to 24-hour duration) have been associated with premature mortality, increased hospital admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory symptoms, and restricted activity days. These adverse health effects have been reported primarily in infants, children, and older adults with preexisting heart or lung diseases. In a ddition, of all of the common air pollutants, PM2.5 is associated with the greatest proportion of adverse health effects related to air pollution, both in the United States and worldwide based on the World Health Organization’s Global Burden of Disease Project. Short -term exposures to PM 10 have been associated primarily with worsening of respiratory diseases, including asthma and chronic obstructive pulmonary disease, leading to hospitalization and emergency department visits (CARB 2017).

Long-term exposure (months to years) to PM2.5 has been linked to premature death, particularly in people who have chronic heart or lung diseases, and reduced lung function growth in children. The effects of long-term exposure to PM10 are less clear, although several studies suggest a link between long -term PM 10 exposure and respiratory mortality. The International Agency for Research on Cancer published a review in 2015 that concluded that PM in outdoor air pollution causes lung cancer (CARB 2017).

Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline , the manufacturing of batteries, paints, ink, ceramics, and ammunition , and secondary lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of airborne lead by nearly 95 %. With the phaseout of leaded gasoline, secondary lead smelters, battery recycling, and manufacturing facilities are becoming lead -emissions sources of greater concern.

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Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases, neuromuscular and neurological dysfunction. Of particular concern are low-level lead exposures during infancy and childhood. Such exposures are associated with decrements in neurobehavioral performance, including IQ performance, psychomotor performance, reaction time, and growth. Children are highly susceptible to the effects of lead.

Sulfates. Sulfates are the fully oxidized form of sulfur, which typically occur in combination with metals or hydrogen ions. Sulfates are produced from reactions of SO 2 in the atmosphere and can result in respiratory impairment, as well as reduced visibility.

Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor, which has been detected near landfills, sewage plants, and hazardous waste sites, due to the microbial breakdown of chlorinated solvents. Short -term exposure to high levels of vinyl chloride in air can cause nervous system effects, such as dizziness, drowsiness, and headaches. Long-term exposure through inhalation can cause liver damage, including liver cancer.

Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs.

Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage treatment plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing difficulties at higher concentrations.

Visibility-Reducing Particles. Visibility-reducing particles are any particles in the air that obstruct the range of visibility. Effects of reduced visibility can include obscuring the viewshed of natural scenery, reducing airport safety, and discouraging tourism. Sources of visibility-reducing particles are the same as for PM2.5.

Volatile Organic Compounds. Hydrocarbons are organic gases that are formed from hydrogen and carbon, and sometimes other elements. Hydrocarbons that contribute to formation of O3 are referred to and regulated as VOCs.

Combustion engine exhaust, oil refineries, and fossil -fueled power plants are sources of hydrocarbons. Other sources of hydrocarbons include evaporation from petroleum fuels, solvents, dry-cleaning solutions, and paint.

The primary health effects of VOCs result from the formation of O3 and its related health effects. High levels of VOCs in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs. There are no separate health standards for VOCs as a group.

Non -Criteria Air Pollutants
Toxic Air Contaminants. A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects.

A toxic substance released into the air is considered a TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “ Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires facilities emitting toxic substances to provide local air po llution control districts with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources, location of resulting hotspots, notification of the public exposed to significant risk, and development of effective strategies to reduce potential risks to the public over 5 years.

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Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos. TACs are generated by a number of sources, including stationary sources, such as dry cleaners, gas stations, combustion sources, and laboratories, mobile sources, such as automobiles, and area sources, such as landfills. Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer -causing) and noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short-term (acute) or long-term (chronic) exposure to a given TAC.

Diesel Particulate Matter. Diesel particulate matter (DPM) is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks. More than 90% of DPM is less than 1 micrometer in diameter (about 1/70 the diameter of a human hair), and thus is a subset of PM2.5 (CARB 2019f). DPM is typically composed of carbon particles (“soot,” also called black carbon) and numerous organic compounds, including more than 40 known cancer -causing organic substances. Examples of these chemicals include polycyclic aromatic hydrocar bons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene (CARB 2019f). CARB classified “particulate emissions from diesel -fueled engines” (i.e., DPM) (17 CCR 93000) as a TAC in August 1998. DPM is emitted from a broad range of diesel engines: on-road diesel engines of trucks, buses, and cars, and off -road diesel engines including locomotives, marine vessels, and heavy -duty construction equipment, among others.

Approximately 70% of all airborne cancer risk in California is associated with DPM (CARB 2000). To reduce the cancer risk associated with DPM, CARB adopted a diesel risk reduction plan in 2000 (CARB 2000). Because it is part of PM2.5, DPM also contributes to the same non-cancer health effects as PM2.5 exposure. These effects include premature death; hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma; increased respiratory symptoms; and decreased lung function in children. Several studies suggest that exposure to DPM may also facilitate development of new allergies. Those most vulnerable to non-cancer health effects are children, whose lungs are still developing, and older adults, who often have c hronic health problems (CARB 2019f).

Odorous Compounds. Odors are generally regarded as an annoyance rather than a health hazard. Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). The ability to detect odors varies considerably among the population and overall is quite subjective. People may have different reactions to the same odor. An odor that is offensive to one person may be perfectly acceptable to another (e.g., coffee roaster). An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recogniti on may only occur with an alteration in the intensity. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source, wind speed and direction, and the sensitivity of receptors.

Valley Fever. Coccidioidomycosis, more commonly known as “Valley Fever,” is an infection caused by inhalation of the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States. When fungal spores are present, any activity that disturbs the soil, such as digging, grading, or other earth -moving operations, can cause the spores to become airborne and thereby increa se the risk of exposure. The ecologic factors that appear to be most conducive to survival and replication of the spores are high summer temperatures, mild winters, sparse rainfall, and alkaline sandy soils.

Valley Fever has been reported in most counties in California with approximately 70% of the cases occurring within six counties including Kern, Kings, San Luis Obispo, Fresno, Tulare, and Madera Counties. The reported number of cases in California was 7,51 5 cases in 2018, with the Coccidioidomycosis incidence rate of 18.8 per 100,000

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population in 2018. In San Diego County, the numbers of Valley Fever cases reported was 1,765 cases in 2018, or an incidence rate of 5.5 per 100,000 population (CDPH 2019; Nelson, pers. comm. , 2019). The project site is wholly contained within the 92078 zip code, and within the 92078 zip code there were 3.1 cases per 100,000 people per year of Coccidioidomycosis between 2009 and 2018 (Nelson, pers. comm., 2019).

Even if present at a site, earth-moving activities may not result in increased incidence of Valley Fever. Propagation of Coccidioides immitis is dependent on climatic conditions, with the potential for growth and surface exposure highest following early seasonal rains and long dry spells. Coccidioides immitis spores can be released when filaments are disturbed by earth-moving activities, although receptors must be exposed to and inhale the spores to be at increased risk of developing Valley Fever. Moreover, exposure to Coccidioides immitis does not guarantee that an individual will become ill—approximately 60% of people exposed to the fungal spores are asymptomatic and show no signs of an infection (USGS 2000).

3.2.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to air quality, including federal, state, and local guidelines.

Federal
Federal Clean Air Act
The federal CAA, passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The U.S. Environmental Protection Agency is responsible for implementing most aspects of the CAA, including setting NAAQS for major air pollutants, setting hazardous air pollutant standards, approving state attainment plans, setting motor vehicle emission standards, issuing stationary source emission standards and permits, and establishing acid rain control measures, stratospheric O3 protection measures, and enforcement provisions. Under the CAA, NAAQS are established for the criteria pollutants O3, CO, NO2, SO2, PM10, PM2.5, and lead.

The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The NAAQS (other than for O3, NO2, SO2, PM10, PM2.5, and those based on annual averages or arithmetic mean) are not to be exceeded more than once per year. NAAQS for O 3, NO2, SO2, PM10, and PM 2.5 are based on statistical calculations over 1- to 3-year periods, depending on the pollutant. The CAA requires EPA to reassess the NAAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a state implementation plan that demonstrates how those areas will attain the standards within mandated time frames.

State
The federal CAA delegates the regulation of air pollution control and the enforcement of the NAAQS to the states.

In California, the task of air quality management and regulation has been legislatively granted to CARB, with subsidiary responsibilities assigned to air qua lity management districts and air pollution control districts at the regional and county levels. CARB, which became part of the California Environmental Protection Agency in 1991, is responsible for ensuring implementation of the California Clean Air Act of 1988, responding to the federal CAA, and regulating emissions from motor vehicles and consumer products.

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CARB has established CAAQS, which are generally more restrictive than the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before a basin can attain the standard. Air quality is considered “in attainment ” if pollutant levels are continuously below the CAAQS and violate the standards no more than once each year. The CAAQS for O3, CO, SO2 (1-hour and 24-hour), NO2, PM10, PM2.5, and visibility-reducing particles are values that are not to be exceeded. All other criteria air pollutants regulated in California (e.g., sulfates, vinyl chloride, hydrogen sulfide, and visibility-reducing particles) are not to be equaled or exceeded. The NAAQS and CAAQS are presented in Table 3.2-4.

Table 3.2-4. Ambient Air Quality Standards
Pollutant Averaging Time
CAAQS a NAAQS b
Concentration c Primary c,d Secondary c,e
O3 1 hour 0.09 ppm (180 g/m3) — Same as primary
standardf 8 hours 0.070 ppm (137 g/m3) 0.070 ppm
(137 g/m3)f
NO2g 1 hour 0.18 ppm (339 g/m3) 0.100 ppm
(188 g/m3)
Same as primary
standard
Annual arithmetic
mean

0.030 ppm (57 g/m3) 0.053 ppm
(100 g/m3)
CO 1 hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) None
8 hours 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3)
SO2h 1 hour 0.25 ppm (655 g/m3) 0.075 ppm
(196 g/m3)
—
3 hours — — 0.5 ppm
(1,300 g/m3)
24 hours 0.04 ppm (105 g/m3) 0.14 ppm
(for certain areas)g
—
Annual — 0.030 ppm
(for certain areas)g
—
PM10i 24 hours 50 g/m3 150 g/m3 Same as primary
standard Annual arithmetic
mean
20 g/m3 —
PM2.5i 24 hours — 35 g/m3 Same as primary
standard
Annual arithmetic
mean
12 g/m3 12.0 g/m3 15.0 g/m3
Leadj,k 30-day average 1.5 g/m3 — —
Calendar quarter — 1.5 g/m3
(for certain areas)k
Same as primary
standard
Rolling 3-month
average
— 0.15 g/m3
Hydrogen
sulfide
1 hour 0.03 ppm (42 µg/m3) — —
Vinyl
chloridej
24 hours 0.01 ppm (26 µg/m3) — —
Sulfates 24 hours 25 µg/m3 — —

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Table 3.2-4. Ambient Air Quality Standards
Pollutant Averaging Time
CAAQS a NAAQS b
Concentration c Primary c,d Secondary c,e
Visibility
reducing
particles
8 hours
(10:00 a.m. to
6:00 p.m. PST)
Insufficient amount to
produce an extinction
coefficient of 0.23 per
kilometer due to particles
when the relative
humidity is less than 70%
— —
Source: CARB 2021c.

Notes: CAAQS = California Ambient Air Quality Standards; NAAQS = National Ambient Air Quality Standards; O 3 = ozone; ppm = parts per million by volume; g/m3 = micrograms per cubic meter; NO 2 = nitrogen dioxide; CO = carbon monoxide; mg/m3= milligrams per cubic meter; SO2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter. a California standards for O3, CO, SO2 (1-hour and 24-hour), NO2, suspended particulate matter—PM10, PM2.5, and visibility-reducing particles, are values that are not to be exceeded. All others are not to be equaled or exceeded. CAAQS are listed in the Tabl e of Standards in Section 70200 of Title 17 of the California Code of Regulations. b National standards (other than O3, NO2, SO2, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once a year. The O 3 standard is attained when the fourth -highest 8 -hour concentration measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PM 10, the 24-hour standard is attained when the expected number of days per calendar year with a 24 -hour average concentration above 150 µg/m3 is equal to or less than 1. For PM 2.5, the 24-hour standard is attained when 98% of the daily concentrations, averaged over 3 years, are equal to or less than the standard.
c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
d National primary standards: the levels of air quality necessary, with an adequate margin of safety to protect the public health. e National secondary standards: the levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
f On October 1, 2015, the primary and secondary NAAQS for O3 were lowered from 0.075 ppm to 0.070 ppm. g To attain the 1 -hour national standard, the 3 -year average of the annual 98th percentile of the 1 -hour daily maximum concentrations at each site must not exceed 100 parts per billion (ppb). Note that the national 1-hour standard is in units of ppb.

California standards are in units of ppm. To directly compare the national 1 -hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. h On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until 1 year after an area is designated for the 2010 standard, except that in areas designated nonattainment of the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. i On December 14, 2012, the national annual PM 2.5 primary standard was lowered from 15 g/m3 to 12.0 g/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 g/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 g/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years. j CARB has identified lead and vinyl chloride as TACs with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. k The national standard for lead was revised on October 15, 2008, to a rolling 3 -month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until 1 year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

California Clean Air Act
The California Clean Air Act, signed into law in 1988, requires all areas of the state to achieve and maintain the CAAQS by the earliest practical date. Air pollution from commercial and industrial facilities is regulated by local air quality management districts, whereas mobile sources of air pollution are regulated by CARB and the EPA. All air pollution control districts have been formally designated as “attainment” or “nonattainment” for each state air quality standard,

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as shown in Table 3.2-2. Areas in California where ambient air concentrations of pollutants are higher than the state standard are considered to be in “non -attainment” status for that pollutant. Non -attainment designations are categorized into three levels of severity: (1) moderate, (2) serious, and (3) severe. If there are inadequate or inconclusive data to make a definitive attainment designation, districts are considered “unclassified.” Toxic Air Contaminants
The state Air Toxics Program was established in 1983 under AB 1807. The California TAC list identifies more than 700 pollutants, of which carcinogenic and noncarcinogenic toxicity criteria have been established for a subset of these pollutants pursuant to the California Health and Safety Code. In accordance with AB 2728, the state list includes the (federal) hazardous air pollutants. In 1987, the Legislature enacted the Air Toxics “Hot Spots” Information and Assessment Act of 1987 (AB 2588) to address publi c concern over the release of TACs into the atmosphere. AB 2588 requires facilities emitting toxic substances to provide local air pollution control districts with information that will allow an assessment of the air toxics problem, identification of air t oxics emissions sources, location of resulting hotspots, notification of the public exposed to significant risk, and development of effective strategies to reduce potential risks to the public over 5 years. TAC emissions from individual facilities are quantified and prioritized. “High-priority” facilities are required to perform a health risk assessment, and if specific thresholds are exceeded, the facility operator is required to communicate the results to the public in the form of notices and public meetings.

In 2000, CARB approved a comprehensive Diesel Risk Reduction Plan to reduce diesel emissions from new and existing diesel-fueled vehicles and engines (CARB 2000). The regulation is anticipated to result in an 80% decrease in statewide diesel health risk by 2020 compared with the diesel risk in 2000. Additional regulations apply to new trucks and diesel fuel, including the On -Road Heavy Duty Diesel Vehicle (In -Use) Regulation, the On -Road Heavy Duty (New) Vehicle Program, the In -Use Off-Road Diesel Vehicle R egulation, and the New Off -Road Compression- Ignition (Diesel) Engines and Equipment Program. These regulations and programs have timetables by which manufacturers must comply and existing operators must upgrade their diesel -powered equipment. There are several airborne toxic control measures that reduce diesel emissions, including In -Use Off -Road Diesel -Fueled Fleets (13 CCR 2449 et seq.) and In-Use On-Road Diesel-Fueled Vehicles (13 CCR 2025).

California Health and Safety Code , Section 41700
Section 41700 of the Health and Safety Code states that a person must not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public; or that endanger the comfort, repose, health, or safety of any of those persons or the public; or that cause, or have a natural tendency to cause, injury or damage to business or property. This section also applies to sources of objectionable odors.

Local
San Diego Air Pollution Control District
Although CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources. The project site is located within the SDAB and is subject to SDAPCD guidelines and regulations.

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SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB.

The Regional Air Quality Strategy (RAQS) for th e SDAB was initially adopted in 1991 and is updated every 3 years (most recently in 2020). The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O3. The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of development of their general plans.

The 8-Hour Ozone Attainment Plan for San Diego County indicated that local controls and state programs would allow the region to reach attainment of the federal 8-hour O3 standard by 2018 (SDAPCD 2016). In this plan, SDAPCD relied on the RAQS to demonstrate how the region will comply with the federal O3 standard. The RAQS details how the region will manage and reduce O3 precursors (NOx and VOCs) by identifying measures and regulations intended to reduce these contaminants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, including those under the authority of CARB and the EPA. Incentive programs for reduction of emissions from heavy -duty diesel vehicles, off -road equipment, and school buses are also established in the RAQS. In response to court decisions, some elements in the 8-hour Ozone Attainment Plan for San Diego County required updates. CARB staff prepared the 2018 Updates to the California State Implementation Plan (SIP) to update SIP elements for nonattainment areas throughout the state. The applicable ozone attainment date for San Diego County is in 2032. The 2020 Ozone Attainment Plan this complies with the Severe Nonattainment Area classification planning requirements and includes demonstrations for attainment of the 75 part per billion and 70 part per billion ozone standards by 2026 and 2032, respectively. The 2020 Plan includes a regionwide inventory of O 3 forming emissions, a reasonably further progress demonstration showing emissions reductions during the years leading to the attainment dates, an assessment of Reasonably Available Control Technology and Reasonably Available Control Measures , and contingency measures in the event the emissions controls fall short of achieving the needed reductions.

In December 2005, the SDAPCD also prepared a report titled “Measures to Reduce Particulate Matter in San Diego County” to address implementation of Senate Bill 656 in San Diego County ( Senate Bill 656 required additional controls to reduce ambient concentrations of PM 10 and PM 2.5). In the report, the SDAPCD evaluates implementation of source -control measures that would reduce PM emissions associated with residential wood combustion (SDAPCD 2005).

In addition to SDAPCD’s regional planning efforts, the following SDAPCD rules and regulations also would apply to the project:
▪ SDAPCD Regulation II: Permits; Rule 20.2: New Source Review Non -Major Stationary Sources. Requires new or modified stationary source units (that are not major stationary sources) with the potential to emit 10 pounds per day or more of VOC, NOx, SOx, or PM10 to be equipped with best available control technology.

For those units with a potential to emit above Air Quality Impact Assessments Trigger Levels, the units must demonstrate that such emissions would not violate or interfere with the attainment of any national air quality standard (SDAPCD 1998).
▪ SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than 3 minutes in any period of 60 consecutive minutes that is darker in shade than that designated

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as Number 1 on the Ringelmann Chart, as published by the United States Bureau of Mines , or of such opacity as to obscure an observer’s view to a degree greater than does smoke of a shade designated as Number 1 on the Ringelmann Chart (SDAPCD 1997).
▪ SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property (SDAPCD 1976). ▪ SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust emissions from any commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, as well as track -out and carry -out onto paved roads beyond a project site (SDAPCD 2009).
▪ SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2021).

City of San Marco s General Plan
The City’s General Plan (City of San Marcos 201 2) includes various policies related to reducing air pollutant emissions. Applicable policies include the following:

Land Use and Community Design Element
Goal LU -2: Promote development standards and land use patterns that encourage long -term environmental sustainability.

Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use.

Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.

Policy LU-3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.

Mobility Element
Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network.

Goal M -3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City.

The proposed project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning, and throughout Chapter 3, Environmental Analysis, of this EIR.

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3.2.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to air quality are based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to air quality would occur if the project would:

Threshold No. 1 Conflict with or obstruct implementation of the applicable air quality plan.

Threshold No. 2 Result in a cumulatively considerable new increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard .

Threshold No. 3 Expose sensitive receptors to substantial pollutant concentrations.

Threshold No. 4 Result in othe 5r emissions (such as those leading to odors) adversely affecting a substantial number of people.

Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) indicates that, where available, the significance criteria established by the applicable air quality management district or pollution control district may be relied upon to determine whether the project would have a significant impact on air quality. For purposes of this EIR, reference has been made to thresholds established by SDAPCD in Rule 20.2 for permitted stationary sources. SDAPCD sets forth quantitative emission thresholds in Rule 20.2 below which a stationary source would not have a significant impact on ambient air quality. For CEQA purposes, these thresholds can be used to demonstrate that a project’s total emissions (e.g., stationary and fugitive emissions, as well as emissions from mobile sources) would not result in a significant impact to air quality. While the proposed project is a land use development project (and not a stationary source project), the Rule 20.2 thresholds provide a representative and relevant proxy for purposes of assessing project impacts. Therefore, project-related air quality impacts assessed in this EIR would be considered significant if any of the applicable significance thresholds developed by SDAPCD for Rule 20.2 , as presented in Table 3.2-5, are exceeded. Emissions below the screening-level thresholds would not cause a significant impact. For nonattainment pollutants, if emissions exceed the thresholds shown in Table 3.2-5, a project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality.

Table 3.2-5. San Diego Air Pollution Control District Air Quality Significance Thresholds Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Respirable particulate matter (PM10) 100
Fine particulate matter (PM2.5) 55
Oxides of nitrogen (NOx) 250
Sulfur oxides (SOx) 250
Carbon monoxide (CO) 550
Volatile organic compounds (VOC) 137a

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Table 3.2-5. San Diego Air Pollution Control District Air Quality Significance Thresholds Operational Emissions
Pollutant
Total Emissions
Pounds per
Hour
Pounds per
Day
Tons per
Year
Respirable particulate matter (PM10) — 100 15
Fine particulate matter (PM2.5) — 55 10
Oxides of nitrogen (NOx) 25 250 40
Sulfur oxides (SOx) 25 250 40
Carbon monoxide (CO) 100 550 100
Lead and lead compounds — 3.2 0.6
Volatile organic compounds (VOC) — 137a 13.7
Source: SDAPCD Rules 1501 and 20.2(d)(2).
a VOC threshold based on South Coast Air Quality Management District (SCAQMD) levels per the SCAQMD and the Monterey Bay Air Pollution Control District, which have similar federal and state attainment status to San Diego.

Construction
Construction assumptions, including timing, phasing, and equipment type and quantity, as well as worker and vendor truck trips, were based on information provided by the applicant. Default values provided by the California Emissions Estimator Model (CalEEMod) were used where detailed project information was not available.

Construction is anticipated to occur in five phases consisting of site preparation, grading, building construction, paving, and architectural coating. The analysis contained herein is based on the following assumptions (the duration of phases is approximate):
▪ Site Preparation: 10 days
▪ Grading: 2 months
▪ Building Construction: 14 months
▪ Paving: 1 month
▪ Architectural Coating: 1 month
The construction equipment mix used for estimating construction emissions herein is based on CalEEMod defaults and is shown in Table 3.2-6. Project construction would be subject to implement dust control strategies as required by SDAPCD Rule 55 regulating fugitive dust . To reflect implementation of proposed dust control strategies, the following was assumed in CalEEMod:
▪ Water exposed area two times per day (55% reduction in PM10 and PM2.5) ▪ Limit unpaved road travel to 15 miles per hour

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Source: Appendix B.

Health Risk Assessment
A health risk assessment (HRA) was performed to assess the impact of construction on sensitive receptors proximate to the project (see Appendix B to Appendix B of the EIR). The analysis includes an HRA associated with emissions from construction of the project based on the methodologies prescribed in the Office of Environmental Health Hazard Assessment Air Toxics Hot Spots Program Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments (OEHHA 2018). To implement the Office of Environmental Health Hazard Assessment Guidelines based on Project information, the SDAPCD has developed a three -tiered approach where each successi ve tier is progressively more refined, with fewer conservative assumptions. The SDAPCD Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessments provides guidance with which to perform HRAs within SDAB (SDAPCD 2022).

Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SDAPCD recommends a carcinogenic (cancer) risk threshold of 10 in a million. Additionally, some TACs increase non -cancer health risk due to long -term (chronic) e xposures. The Chronic Hazard Index is the sum of the individual substance chronic hazard indices for all TACs affecting the same target organ system. The SDAPCD recommends a Chronic Hazard Index significance threshold of 1.0 (project increment). The exhaus t from diesel engines is a complex mixture of gases, vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk factors and relative exposure values for long -term chronic health hazard impacts. No short -term, acute re lative exposure level has been established for DPM; therefore, acute impacts of DPM are not addressed in this Table 3.2-6. Construction Scenario Assumptions
Construction
Phase
One -Way Trips
Equipment Quantity
Hours
Per Day
Daily
Workers
Daily
Vendor
Trucks
Total
Haul
Trucks
Site Preparation 18 4 0 Rubber-Tired Dozers 3 8
Tractors/Loaders/Backhoes 4 8
Grading 20 4 0 Excavators 2 8
Graders 1 8
Rubber-Tired Dozers 1 8
Scrapers 2 8
Tractors/Loaders/Backhoes 2 8
Building
Construction
474 108 0 Cranes 1 7
Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/Backhoes 3 7
Welders 1 8
Paving 16 4 0 Pavers 2 8
Paving Equipment 2 8
Rollers 2 8
Architectural
Coating
96 4 0 Air Compressors 1 6

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assessment. This HRA evaluated the risk to future residents from diesel emissions from exhaust from on -site construction equipment and diesel haul and vendor trucks.

The dispersion modeling of DPM was performed using the American Meteorological Society/EPA Regulatory Model (AERMOD), which is the model SDAPCD requires for atmospheric dispersion of emissions. AERMOD is a steady - state Gaussian plume model that incorporate s air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of surface and elevated sources, building downwash, and simple and complex terrain (Appendix B). For the project, AERMOD was run with all sources emitting unit emissions (1 gram per second) to obtain the “Χ/Q” values. Χ/Q is a dispersion factor that is the average effluent concentration normalized by source strength and is used as a way to simplify the representation of emissions from many sources.

The Χ/Q values of ground-level concentrations were determined for construction emissions using AERMOD and the maximum concentrations determined for the 1 -hour and Period averaging periods. Principal parameters of this modeling are presented in Table 3.2-7.

Table 3.2-7. AERMOD Principal Parameters
Parameter Details
Meteorological Data The latest 3-year meteorological data (2010–2012) for the Escondido Station (Station ID 3177) from SDAPCD were downloaded and then input to AERMOD. For cancer or chronic noncancer risk assessments, the average cancer risk of all years modeled was used.

Urban versus Rural
Option
Urban areas typically have more surface roughness, as well as structures and low- albedo surfaces that absorb more sunlight—and thus more heat—relative to rural areas.

However, based on the SDAPCD guidelines, the rural dispersion option was selected due to the Project’s proximity to the ocean.

Terrain
Characteristics
The terrain in the vicinity of the modeled Project site is generally flat. The elevation of the modeled site is about 545 feet above sea level. Digital elevation model files were imported into AERMOD so that complex terrain features were evaluated as appropriate.

Elevation Data Digital elevation data were imported into AERMOD, and elevations were assigned to the emission sources and receptors. Digital elevation data were obtained through AERMOD View in the United States Geological Survey’s National Elevation Dataset format with a 10-meter resolution.

Emission Sources
and Release
Parameters
Air dispersion modeling of DPM from construction equipment was conducted using emissions estimated using the CalEEMod, assuming emissions would occur 8 hours per day, 5 days per week. The Project area was modeled as a series of volume sources.

Source Release
Characterizations
Based on EPA methodology, the modeled line volume sources would result in a release height of 3.4 meters, a plume height of 6.8 meters, and a plume width of 8.6 meters for off-road equipment and diesel trucks (EPA 2015).

Discrete Receptors A uniform Cartesian grid overlaying residential receptors in close proximity to the project with 20-meter resolution was placed. Additional discrete receptors were placed over residences not within the uniform Cartesian grid.

Note: See Appendix B.

Dispersion model plot files from AERMOD were then imported into CARB’s Hotspots Analysis and Reporting Program Version 2 to determine health risk, which requires peak 1-hour emission rates and annual-averaged emission rates for all pollutants for each modeling source. For the residential health risk, the HRA assumes exposure would start in the third trimester of pregnancy. The results of the HRA are provided in Appendix B to Appendix B of the EIR.

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Operation
Residential uses are anticipated to generate air pollutant emissions from area sources, including emissions from consumer product use, architectural coating, landscape maintenance equipment , and natural gas fireplaces .

Emissions associated with the operations phase of the proposed project were estimated using CalEEMod.

Operational year 2024 was assumed because it would coincide with completion of construction.

Area Sources
Consumer products are chemically formulated products used by household and institutional consumers, including detergents, cleaning compounds, polishes, floor finishes, cosmetics, personal care products , home, lawn, and garden products, disinfectants, sanitizers, aerosol paints, and automotive specialty products. Other paint products, furniture coatings, or architectural coatings are not considered consumer products (CAPCOA 2021). The CalEEMod default values for consumer products were modeled.

VOC off-gassing emissions result from evaporation of solvents contained in surface coatings, such as in paints and primers used during building maintenance. CalEEMod calculates the VOC evaporative emissions from application of surface coatings based on the VOC emissions factor, the building square footage, the assumed fraction of surface area, and the reapplication rate.

Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chainsaws, and hedge trimmers. Emissions from landscape equipment use are estimated based on CalEEMod default v alues for emission factors (grams per square foot of nonresidential building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days. Emissions associated with potential landscape maintenance equip ment were included to conservatively capture potential project operational emission sources.

It is anticipated that proposed residential uses could include natural gas fireplaces. Thus, natural gas fireplaces are included in the CalEEMod analysis.

Energy Sources
As represented in CalEEMod, energy sources would include emissions associated with building electricity and natural gas usage (non-hearth). Electricity use would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use are only quantified for greenhouse gases in CalEEMod, because criteria pollutant emissions occur at the site of the power plant, which is typically off site.

Therefore, for the purposes of the air quality analysis, the energy source parameters focus on criteria air pollutants generated as a result of natural gas consumption within the built environment. Natural gas consumption is attributed to systems like HVAC and water heating. The current Title 24, Part 6 standards, referred to as the “2019 Title 24 Building Energy Efficiency Standards, ” became effective on January 1, 2020. The current version of CalEEMod assumes compliance with the 2019 Title 24 Building Ene rgy Efficiency Standards (CAPCOA 2021).

CalEEMod defaults were assumed for electricity and natural gas.

Mobile Sources (Motor Vehicles)
The proposed project would generate air quality emissions from mobile sources (vehicular traffic) as a result of the residents traveling to and from the project site. CalEEMod was used to estimate emissions from such mobile

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sources (refer to Appendix B), with t he default trip generation rates in CalEEMod adjusted to reflect the overall weekday daily trips based on the Vehicle Miles Traveled (VMT) Analysis (Appendix J), and Local Transportation Analysis (Appendix K). The project-specific trip length from the VMT Analysis based on the SANDAG regional travel demand model was incorporated into the modeling as well. CalEEMod default data, fleet mix, and emissions factors were used for the model inputs. CalEEMod default vehicle emission factors and vehicle fleet mix for 2024, as based on the CARB EMFAC2017 model, were used to estimate emissions associated with vehicular sources.

3.2.4 Project Impact Analysis
Threshold No. 1: Would the project conflict with or obstruct implementation of the applicable air quality plan? As mentioned in Section 3.2.2, Regulatory Setting, the SDAPCD is responsible for developing and implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the SDAB—specifically, the SIP and RAQS. 3 SANDAG is responsible for developing growth projection forecasts and data that are used by the SDAPCD in preparing the SIP and RAQS.

Although the SDAPCD and City do not provide guidance regarding the analysis of impacts associated with air quality plan conformance, the County’s Guidelines for Determining Significance and Report and Format and Content Requirements – Air Quality does discuss conformance with the RAQS (County of San Diego 2007). The guidance indicates that, if the project, in conjunction with other projects, contributes to growth projections that would not exceed SANDAG’s growth projections for a City, the project would not be in conflict with the RAQS. If a project includes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might be in conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality (County of San Diego 2007). The project’s proposed zoning is compared to the existing zoning on the site and then the project’s growth inducing impacts are compared to those included in the SANDAG’s growth projections for the City.

The project site is currently zoned Industrial (I) with a floor -to-area ratio of 0.50. The floor-to-area ratio means the ratio of gross building area of the development, excluding structured parking areas, proposed for the project divided by the net lot area. According to the City of San Marcos Municipal Code, the Industrial (I) land use zone is intended 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, and may be permitted according to the standards of this chapter. The I Zone is intended to implement and be consistent with the Industrial land use designation of the General Plan” (City of San Marcos 2020 b). Based on the existing land use designation/zoning of Industrial (I), the most intensive land use is an industrial park, and the setback, landscaping, and parking requirements per the zoning code were used to determine the maximum size for the industrial park (City of San Marcos 2020b). Implementation of the existing Industrial (I) land use/zoning at the site may generate 11,721,243 VMT annually (Appendix J).

The project proposes development of 449 residential units on 15.28 acres within the approximately 33-acre project site. The project is estimated to generate 7,692,187 VMT annually as estimated in the Transportation Impact Analysis (LLG 2022).

3 For the purpose of this discussion, the relevant federal air quality plan is the Ozone Attainment Plan (SDAPCD 2020). The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.

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The City projects an increase of 3,170 housing units between 2020 and 2035, as reported in the SANDAG Series 13 forecast used in formulating the SIP and RAQS (SANDAG 2013). The proposed project’s 449 residential units would account for 16% of the projected housing unit increase in the City between 2020 and 2035. Furthermore, when added to the cumulative projects in Table 2 -3, the City would not exceed the projected increase in housing units as forecasted by SANDAG. Because the proposed project would not exceed the City’s growth projections, the project would result in regional growth that is accounted for within the RAQS. Therefore, implementation of the proposed project would not conflict with the RAQS or SIP, and project development would be consistent with the growth in the region.

It also is noted that the project site’s infill location near existing retail uses, jobs, and recreation, and its proximity to State Route 78 , the Palomar College Sprinter station, and bus station make for ideal connectivity to a regional transportation network, employment centers, and shopping and services. In addition, the project would implement applicable measures in the City’s 2020 Climate Action Plan Consistency Checklist (see Appendix C of Appendix B), which would result in co-benefits to air quality attributable to installing electric vehicle charging stations, installing bicycle infrastructure, implementing a Transportation Demand Management Plan, and reducing parking near transit.

The project would not conflict with or obstruct implementation of the applicable air quality plan because the project would not propose growth in excess of that within the RAQS or SIP and the project may generate fewer emissions than what is currently zoned for the site as VMT is the main driver of emissions. Impacts would be less than significant.

Threshold No. 2: Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? 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 CAAQS and NAAQS. 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 emiss ions 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 contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumula tive air quality impact).

Construction
Construction of the proposed residential uses would result in the temporary addition of pollutants to the local airshed caused by soil disturbance, fugitive dust emissions, and combustion pollutants from on -site construction equipment, as well as from off -site trucks hauling construction materials. Co nstruction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions. Therefore, such emissions levels can only be estimated, with a corresponding uncertainty in precise ambient air quality impacts. Fugitive dust (PM10 and PM2.5) emissions would primarily result from grading and site preparation activities. NO x and CO emissions would primarily result from the use of construction equipment and motor vehicles.

Construction emissions were calculated using CalEEMod for the estimated worst -case day over the construction period associated with each phase and reported as the maximum daily emissions estimated during each year of construction ( 2023 and 2024). Construction schedule assumptions, including phase type, duration, and sequencing, were based on information provided by the applicant, and is intended to represent a reasonable

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scenario based on the best information available. A detailed depiction of the construction schedule —including information regarding phasing, equipment used during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Section 2.4.2.1, Construction, of EIR Appendix B. The information contained in Appendix A (CalEEMod Output Files) of EIR Appendix B was used for the CalEEMod inputs.

Construction of proposed residential uses would generate temporary air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, architectural coatings, and asphalt pavement application. Entrained dust results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM10 and PM2.5 emissions. The proposed project would be subject to SDAPCD Rule 55, Fugitive Dust Control. This rule requires that a project take steps to restrict visible emissions of fugitive dust beyond the property line.

Compliance with Rule 55 would limit fugitive dust (PM 10 and PM 2.5) that may be generated during grading and construction activities. To account for dust control measures in the calculations, it was assumed that the active sites would be watered at least two times daily, resulting in an approximately 5 5% reduction of PM. Compliance with Rule 55 would be required as a standard condition of project approval or for issuance of a grading permit.

Exhaust from internal combustion engines used by construction equipment, hauling trucks (dump trucks), vendor trucks (delivery trucks), and worker vehicles would result in temporary emissions of NOx, VOC, CO, SO x, PM10, and PM2.5. Application of architectural coatings, such as exterior/interior paint and other finishes, would also produce VOC emissions; however, the contractor is required to procure architectural coatings from a supplier in compliance with the requirements of SDAPCD Rule 67.0.1, Architectural Coatings. This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015). The proposed project would comply with SDAPCD Rule 67.0.1 through the incorporation of low-VOC architectural coatings. The VOC content assumed for the analysis was 50 g/L for interior coatings and 100 g/L for exterior coatings.

Table 3.2-8 shows the estimated maximum daily construction emissions associated with the construction of the proposed residential uses. Details of the emissions calculations are provided in Appendix B of this EIR.

Table 3.2-8. Estimated Maximum Daily Construction Emissions – Unmitigated Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
2023 3.39 34.73 29.46 0.08 10.29 5.76
2024 188.94 19.15 28.57 0.08 5.35 1.88
Maximum daily
emissions
188.94 34.73 29.46 0.08 10.29 5.76
Emission threshold 75 250 550 250 100 55
Threshold exceeded? Yes No No No No No
Source: Appendix B.

Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns ; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than 2.5 microns.

See Appendix A of Appendix B for output files and modeling details.

The values shown are the maximum summer or winter daily emissions results from CalEEMod and provided in Appendix A of Appendix B. The maximum emissions assume compliance with SDAPCD Rule 67.0.1, Architectural Coatings, and SDAPCD Rule 55, Fugitive Dust Control.

As shown in Table 3.2-8, daily construction emissions would not exceed the significance thresholds for NO x, CO, SO x, PM10, or PM 2.5; however, the proposed project would exceed the significance threshold for VOC.

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Operation
Following completion of construction activities, proposed residential uses would generate VOC, NOx, CO, SOx, PM10, and PM2.5 emissions from mobile sources, including vehicular traffic generated by residents; area sources, including the use of landscaping equipment and consumer products; and from architectural coatings.

Table 3.2 -9 presents the maximum daily emissions associated with operation of the proposed residential uses. The values shown for mobile sources ( motor vehicles ), energy sources, and area sources are the maximum of either the summer or winter daily emissions results from CalEEMod , whichever is greater .

Table 3.2-9. Estimated Project Maximum Daily Operational Emissions – Unmitigated Emission Source
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
Area 12.77 7.88 40.29 0.05 0.81 0.81
Energy 0.10 0.82 0.35 0.01 0.07 0.07
Mobile 7.76 8.55 71.42 0.15 16.31 4.42
Total 20.63 17.25 112.06 0.21 17.19 5.30
Emission threshold 55 250 550 250 100 55
Threshold
exceeded?
No No No No No No
Source: Appendix B.

Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns ; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than 2.5 microns.

See Appendix A of Appendix B for output files and modeling details.

As shown in Table 3.2-9, the daily operational emissions from implementation of the proposed project would not exceed the significance thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5.

However, as shown in Table 3.2 -8 above, the proposed project would exceed the significance threshold for VOC during construction (Impact AQ -1). Because VOC is a precursor to the formation of ozone, and because SDAB is a nonattainment area under the ozone NAAQS and CAAQS , the potential for the proposed project 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 is less than significant with mitigation incorporated.

Threshold No. 3: Would the project expose sensitive receptors to substantial pollutant concentrations? Air quality varies as a direct function of the amount of pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing meteorological conditions. Air quality problems arise when the rate of pollutant emissions exceeds the rate of dispersion. Reduced visibility, eye irritation, and adverse health impacts on those persons termed “sensitive receptors” are the most serious hazards of existing air quality conditions in the area. Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by CARB, include children, older adults, athletes, and people with cardiovascular and chronic respiratory diseases; however, for the purposes of this analysis, residents are also considered sensitive receptors. As such, sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long -term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes.

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Health Impacts of Toxic Air Contaminants
In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as TACs or hazardous air pollutants. State law has established the framework for California’s TAC identification and control program, which is generally more stringent than the federal program and aimed at TACs that ar e a problem in California. The s tate has formally identified more than 200 substances as TACs, including the federal hazardous air pollutants, and is adopting appropriate control measures for sources of these TACs. The greatest potential for TAC emissions during construction would be diesel particulate emissions from heavy-duty equipment operations and heavy-duty trucks, and the associated health impacts to sensitive receptors.

The following measures are required by state law to reduce diesel particulate emissions:
▪ Fleet owners of mobile construction equipment are subject to the CARB Regulation for In-use Off-road Diesel Vehicles (13 CCR, Chapter 9, Section 2449), the purpose of which is to reduce DPM and criteria pollutant emissions from in-use (existing) off-road diesel-fueled vehicles. ▪ All commercial diesel vehicles are subject to 13 CCR 2485, limiting engine idling time. Idling of heavy-duty diesel construction equipment and trucks during loading and unloading shall be limited to 5 minutes; electric auxiliary power units should be used whenever possible.

The greatest potential for TAC emissions during construction would be DPM emissions from heavy -duty equipment operations and heavy-duty trucks during construction of the project and the associated health impacts to sensitive receptors.

An HRA was performed to evaluate the risk from diesel exhaust emissions on existing sensitive receptors and future on-site receptors from construction activities. The HRA methodology was described in Section 3.2.3, Thresholds of Significance, and the detailed assessment is provided in Appendix B. Table 3.2-10 summarizes the results of the HRA for proposed project construction.

Table 3.2-10. Construction Activity Health Risk Assessment Results Impact Parameter Units
Project
Impact
CEQA
Threshold Level of Significance
Cancer Risk Per Million 6.4 10.0 Less than Significant
HIC Not Applicable 0.005 1.0 Less than Significant
Source: Appendix B.

Notes: CEQA = California Environmental Quality Act; HIC = Chronic Hazard Index.

The results of the HRA demonstrate that the TAC exposure from construction diesel exhaust emissions would result in cancer risk on site below the 10 in 1 million threshold, as well as Chronic Hazard Index less than 1.0. Therefore, TAC emissions from construction of the proposed project would not expose sensitive receptors to substantial pollutant concentrations and would result in a less than significant impact. Upon completion of construction, the project would not generate substantial TAC emissions. As such, impacts would be less than significant during operation.

Health Impacts of Carbon Monoxide
As described previously, exposure to high concentrations of CO can result in dizziness, fatigue, chest pain, headaches, and impairment of central nervous system functions. Mobile-source impacts, including those related to CO, occur on two scales. Regionally, project -related construction travel would add to regional trip generation and increase the VMT within the local airshed and the SDAB. Locally, construction traffic would be added to the roadway

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system in the vicinity of the project site. Although the SDAB is currently an attainment area for CO, there is a potential for the formation of microscale CO “hotspots” to occur immediately around points of congested traffic. Hotspots can form if such traf fic occurs during periods of poor atmospheric ventilation, is composed of a large number of vehicles cold -started and operating at pollution -inefficient speeds, and/or is operating on roadways already crowded with non-project traffic. Because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SDAB is steadily decreasing. The SDAB is a CO maintenance area (western and central part of the SDAB only).

The Governor’s Office of Planning and Research and the California Natural Resources Agency have issued new CEQA Guidelines for analyzing transportation impacts. By July 1, 2020, all CEQA lead agencies must analyze a project’s transportation impacts using VMT. VMT measures the distances vehicles will travel to and from a project, rather than congestion levels at intersections (level of service LOS, graded on a scale of A –F). To account for this shift from level of service to VMT—such that vehicle congestion is no longer modeled and available —but to nonetheless evaluate the potential for CO hotspots for the hypothetical development scenario, this EIR utilizes CO modeling analyses performed by the South Coast Air Quality Management District (SCAQMD) relative to 1-hour and 8-hour concentrations as follows.

The SCAQMD conducted CO modeling for the 2003 Air Quality Management Plan (SCAQMD 2003, Appendix V) for the four worst -case intersections in the South Coast Air Basin: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century Boulevard, and (4) Long Beach Boulevard and Imperial Highway. At the time, the 2003 Air Quality Management Plan was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of about 100,000 vehicles per day. Using CO emission factors for 2002, the peak modeled CO 1 -hour concentration was estimated to be 4.6 ppm at the intersection of Wilshire Boulevard and Veteran Avenue.

A daily traffic volume of 100,000 vehicles (as considered in the SCAQMD modeling) as a result of the proposed project, would be at least double the traffic volumes of nearby intersections (LLG 2022).4 However, if “peak” modeled 1-hour concentration from SCAQMD ’s analysis of 100,000 vehicle traffic volumes of the 4.6 ppm were added to the maximum 1-hour CO concentration from 2019 through 2021 at the San Diego–11403 Rancho Carmel Drive monitoring station (see Table 3 .2-3) of 4.1 ppm (in 2019), the 1-hour CO concentration in the project area would total 8.7 ppm. This “worst case scenario”—modeling at least double the traffic compared to that experienced in the proposed project area —would still result in 1 -hour CO concentrations well below the CAAQS 1-hour CO threshold of 20 ppm.

Concerning 8 -hour concentrations, SCAQMD modeled future year 8 -hour CO concentrations at the Central Los Angeles monitoring site of 4.6 ppm in 2020. Adding the 4.6 ppm to the maximum 8 -hour CO concentration from 2019 through 2021 at the San Diego–11403 Rancho Carmel Drive monitoring station (see Table 3.2-3) of 2.5 ppm (in 2019) would result in a total 8-hour CO concentration of 7.1 ppm. Again, this “worst case scenario” 8-hour CO concentration assuming traffic counts far above that experience d in the proposed project area would still be well below the CAAQS 8-hour threshold of 9.0 ppm.

Said another way, CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected daily traffic would cause area traffic volumes to exceed 100,000 vehicles per day. The proposed project would not increase daily traffic volumes at any study intersection to more than 100,000 vehicles per day

4 For each study intersection in each scenario evaluated in the VMT Analysis, all 10 study intersections were estimated to result in less than 100,000 vehicles per day in every scenario evaluated (ranging from 4,649 vehicles to 44,977 vehicles).

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(LLG 2022). Therefore, the proposed project is not anticipated to create a CO hotspot. As such, impacts to sensitive receptors with regard to potential CO hotspots resulting from the project and hypothetical development scenario’s contribution to cumulative traffic-related air quality impacts would be less than significant.

Health Impacts of Criteria Air Pollutants
The California Supreme Court’s Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502 decision (referred to herein as the Friant Ranch decision) (issued on December 24, 2018) addresses the need to correlate mass emission values for criteria air pollutants to specific health consequences, and contains the following dire ction from the California Supreme Court: “The Environmental Impact Report (EIR) must provide an adequate analysis to inform the public how its bare numbers translate to create potential adverse impacts or it must explain what the agency does know and why, given existing scientific constraints, it cannot translate potential health impacts further” (italics original). (For further discussion of the Friant Ranch decision, please see Appendix C of this EIR.) For purposes of this EIR, it is first noted that the SDAPCD, CARB, and EPA currently have not approved a quantitative method to reliably, meaningfully, and consistently translate the mass emissions’ estimates for the criteria air pollutants resulting from a project to specific health effects. In addition, there are numerous scientific and technological complexities associated with correlating criteria air pollutant emissions from an individual project to specific health effects or potential additional nonattainment days. Appendix B to this EIR, however, further describes the general health effects associated with criteria air pollutants, which also are summarized here in Section 3.2.1, Existing Conditions.

As previously described, construction of the proposed project would result in emissions that exceed the threshold for VOC without mitigation; however, construction would not exceed significance thresholds for NOx, CO, SOx, PM10, or PM2.5 (refer to Table 3.2-8). Operation of the proposed project would not exceed significance thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5 (refer to Table 3.2-9). As such, it is not anticipated that the project would contribute to exposure of sensitive receptors to substantial pollutant concentrations with regard to such emissions.

VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect to the NAAQS and CAAQS (the SDAB is designated by the EPA as an attainment area for the 1-hour O3 NAAQS standard). The health effects associated with O3 are generally associated with reduced lung function. The contribution of VOCs and NOx to regional ambient O3 concentrations is the result of complex photochemistry. The increases in O3 concentrations in the SDAB due to O 3 precursor emissions tend to be found downwind from the source location to allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O3 concentrations also depends on the time of year that the VOC emissions occur because exceed ances of the O 3 CAAQS/NAAQS tend to occur between April and October when solar radiation is highest. The holistic effect of a single project’s emissions of O 3 precursors is speculative due to the lack of quantitative methods to assess this impact.

Operation of the proposed project would not exceed the significance threshold for NO x; therefore, the proposed project would contribute minimally to regional O3 concentrations and the associated health effects. However, due to exceedances in construction-generated emissions of VOC, the proposed project could result in potential health effects associated with VOCs.

In summary, because construction of the proposed project could result in exceedances of the significance thresholds for VOC, the potential health effects associated with criteria air pollutants, specifically O3, would be less than significant with mitigation incorporated. With implementation of MM-AQ-1, impacts would be reduced to a level of less than significant.

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As emissions during operation would not exceed any significance threshold for criteria air pollutants, impacts during operation would be considered less than significant.

Valley Fever Exposure
Valley Fever is not highly endemic to San Diego County, and within San Diego County, the incidence rate in the project area is below the County and statewide average. The proposed project would be required to comply with SDAPCD Rule 55, which limits the amount of fugitive dust generated during construction. Strategies the project would implement to comply with SDAPCD Rule 55 and control dust include watering two times per day and limiting speed on unpaved roads to 15 miles per hour.

Based on the low incidence rate of Coccidioidomycosis in San Diego County and the implementation of dust control strategies for the proposed project , it is not anticipated that earth -moving activities during construction of the project would result in exposure of nearby sensitive receptors to Valley Fever. Therefore, the project would have a less than significant impact with respect to Valley Fever exposure for sensitive receptors.

Threshold No. 4: Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Odors would be generated from vehicle and equipment exhaust emissions during construction of the proposed project. Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and from architectural coatings. Such odors would disperse rapidly from the project site and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be less than significant.

Land uses and industrial operations associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (CARB 2005). The proposed project would not allow for any of these activities. Moreover, typical odors generated from operation of the proposed project residential land uses would primarily include vehicle exhaust generated by residents and through the periodic use of landscaping and maintenance equipment. Therefore, the proposed project would result in an odor impact that is less than significant.

3.2.5 Mitigation Measures
Mitigation Measure (MM) AQ-1 would be implemented to reduce VOC emissions generated during construction of the proposed project (Impact AQ-1).

MM-AQ-1 Architectural Coatings. The project shall use low volatile organic compound (VOC) architectural coatings for interior application that do not exceed VOC content of 10 grams per liter, for exterior application that do not exceed VOC content of 50 grams per liter, and for parking application do not exceed VOC content of 100 grams per liter.

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3.2.6 Conclusion
The proposed project would change the allowable land use and zoning designation of Industrial (I) to allow for residential uses under a proposed Specific Plan Area. However, the project’s proposed growth would be within the growth projections for the City, and, at a regional level, the proposed project is consistent with the underlying growth forecasts in the SIP and RAQS. Therefore, implementation of the proposed project would not conflict with the RAQS or SIP, and proposed development would be consistent with the anticipated growth in the region.

Implementation of the proposed project also would not violate any air quality standards or contribute substantially to an existing or projected air quality violation during construction with mitigation or operation. Additionally, the proposed project would not expose a substantial number of people to objectionable odors.

As construction of the proposed project would likely exceed the significance threshold for VOC prior to mitigation, the potential for the proposed project to result in a cumulatively considerable net increase of any criteria pollutant (i.e., O3) for which the project region is nonattainment under an applicable national or California ambient air quality standard is potentially significant. Because construction could result in exceedance of the VOC significance threshold, the potential health effects associat ed with exposure of sensitive receptors to criteria air pollutants, specifically O3, were also considered potentially significant.

However, with implementation of mitigation measure MM-AQ-1, VOC emissions generated during construction of the proposed project would be reduced to a less-than-significant level. Specifically, as shown in Table 3.2-11, daily construction emissions would not exceed the significance thresholds for VOC, NO x, CO, SO x, PM 10, or PM 2.5 with mitigation incorporated. Therefore, the potential for the project to result in a cumulatively considerable net increase of any criteria pollutant for which the project region i s 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.

Table 3.2-11. Estimated Maximum Daily Construction Emissions – Mitigated Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
2023 3.39 34.73 29.46 0.08 10.29 5.76
2024 61.80 19.15 28.57 0.08 5.35 1.88
Maximum Daily
Emissions

61.80 34.73 29.46 0.08 10.29 5.76
Emission Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Source: Appendix B.

Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns ; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than 2.5 microns.

See Appendix A of Appendix B to this EIR for output files and modeling details.

The values shown are the maximum summer or winter daily emissions results from CalEEMod and provided in Appendix A of Appendix B to this EIR. The maximum emissions assume compliance with SDAPCD Rule 55, Fugitive Dust Control and implementation of MM - AQ-1, use of low-VOC architectural coatings.

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INTENTIONALLY LEFT BLANK

3.3 - BIOLOGICAL RESOURCES
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3.3 Biological Resources
This section describes the existing biological 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. This section is based on the Draft Biological Resources Technical Report (BTR) prepared by HELIX Environmental Planning Inc. (HELIX) in January 2023 (revised May 2024), which is included as Appendix C to this environmental impact report (EIR).

Table 3.3-1 summarizes the project- and cumulative-level biological resource impacts, by threshold.

Table 3.3-1. Biological Resources Summary of Impacts
Threshold of Significance Project Impact
Project
Cumulative
Impact
Significance
Determination
No. 1 - Have a substantial adverse effect, either
directly or through habitat modifications, on any
species identified as a candidate, sensitive, or
special status species in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service.

Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
No. 2 - Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, regulations or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service.

Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
No. 3 - Have a substantial adverse effect on
state or federally protected wetlands (including,
but not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling, hydrological
interruption, or other means.

Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
No. 4 - Interfere substantially with the movement
of any native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use of
native wildlife nursery sites.

No impacts No impacts No impacts
No. 5 - Conflict with any local policies or
ordinances protecting biological resources, such
as a tree preservation policy or ordinance.

No impacts No impacts No impacts
No. 6 - Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan.

Less than
Significant with
Mitigation
Less than
Significant with
Mitigation
Less than
Significant with
Mitigation

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-2

3.3.1 Existing Conditions
The approximately 33.2-acre project site consists of primarily undeveloped land in the western portion of San Marcos. Although undeveloped, the project site reflects a history of disturbance. Vegetation is disturbed by an abundance of invasive and weedy plant species . Unpaved roads crossing the project site are visible on historic aerials since 1978 through today (Historical Aerials 2021). Additionally, the project site has been subject to ongoing unauthorized routine dumping of trash, potentially hazardous/toxic materials, and other debris, which are most evident by dump piles in the northwest, southeast, and northwest portions of the project site. Trash and debris are scattered throughout the project site. Furthermore, based on the prevalent tire tracks and road ruts across the project site, most of the site seems to be frequently used for off-highway vehicle recreation. Based on aerial imagery and recent biological surveys of the project site since 2018, the trash/debris dumping and the off-highway vehicle disturbances on site have increased and impacted sensitive biological resources on site, such as vernal pools, sensitive vegetation, and rare plants and animals including federally listed endangered species. Additionally, during the biological surveys conducted in 2021 and 2022, potential evidence of plant harvesting/poaching ( i.e., hand digging tools and small patches of shallow excavations within sensitive plant species locations) in several areas of the site were observed. Due to the relatively high level of continuous anthropogenic disturbances of the project site via trash dumpin g an d off-highway vehicle recreation, the potential sensitive plant harvesting/poaching, unsanctioned community gatherings for 4th of July Holiday celebration parties and fireworks spectating, as well as the abundance of non -native invasive species, it is likely such disturbances would continue in the future and substantially result in ongoing degradation of the biological resources on site (Appendix C).

The project site is immediately adjacent to roadways. The site is located at the northwest corner of South Las Posas Road and Linda Vista Drive. La Mirada Road abuts the site’s northern boundary, while Pacific Street abuts the property’s western boundary. Existing development occurs on all sides of the site. The Grand Plaza shopping center is located directly across South Las Posas Road. Light industrial uses are adjacent to the site’s northern, southern, and western boundary, and Bradley park is located across from the site’s southwestern corner.

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. Three soil types have been mapped on the projec t site: Las Flores loamy fine sand, 2 % to 9% slopes; Placentia sandy loam, 2 % to 9% slopes; and Placentia sandy loam thick surface, 0% to 2% slopes (Appendix C).

Planning Context
The biological study area is generally located within the planning boundaries of the adopted San Diego Multiple Habitat Conservation Program (MHCP) Plan (Appendix C), and specifically within the Draft San Marcos Subarea Plan area. The City of San Marcos (City) Draft Subarea Plan has not been completed, approved, or adopted (City of San Marcos 2001). Within the MHCP, the project site is identified as “natural habitats outside of Biological Core and Linkage Area (BCLA),” and is recognized as a “Major Amendment Area.” Major amendment lands are privately held properties with sensitive resources that ar e not included in the Subarea plan. Prior to the inclusion of these lands in the Subarea Plan, additional California Environmental Quality Act (CEQA) review is required to determine compatibility with the goals and policies of the Subarea Plan with any proposed development on those lands (Appendix C). The project site is located within the Vernal Pool Major Amendment Area in the City’s Draft Subarea Plan (refer to Figure 4 of Appendix C). While the City’s Draft Subarea Plan has not been approved or adopted and is advisory, the City considers the plan a policy document to guide development in the City.

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-3
The project site is located within critical habitat designated by U.S. Fish and Wildlife Service (USFWS) for the federally listed endangered San Diego fairy shrimp ( Branchinecta sandiegonensis), federally listed threatened spreading navarretia ( Navarretia fossalis ), and federally listed threatened thread -leaved brodiaea ( Brodiaea filifolia). The Project site includes the largest remaining vernal pool complex in the City that supports the San Diego fairy shrimp, San Diego button celery, and spreading navarretia (Navarretia fossalis). The Project site also includes the largest remaining non-conserved native grassland in the City and supports one of the largest known populations of the state endangered thread-leaved brodiaea, as well as the non-listed but still sensitive Orcutt’s brodiaea.

Plants
A total of 73 plant species were observed within the project site during the biological surveys, of which 31 (42%) are non -native species. Please refer to Appendix C (Appendix A, Plant Species Observed) for a list and details regarding the 73 plant species observed within the project site.

Animals
A total of 17 animal species were observed/detected within the project site during the biological surveys, including four invertebrates, one reptile, ten bird species, and two mammal species. Please refer to Appendix C (Appendix B, Animal Species Observed or Detected) for a list and details regarding the 17 animal species observed/detected within the project site.

Special -Status/Regulated Resources
Sensitive Vegetation Communities/Habitats
Sensitive vegetation communities/habitat types are defined as land areas that support unique vegetation communities or the habitats of rare or endangered species or subspecies of animals or plants as defined by Section 15380 of the State CEQA Guidelines. Additionally, sensitive vegetation communities/habitat types are those identified as habitats requiring mitigation by the MHCP.

The rarity of natural communities was also evaluated using the NatureServe’s Heritage Methodology (Appendix C) in which communities are given a G (global) and S (State) rank based on their degree of imperilment (as measured by rarity, trends, and threats). Communities are assigned an overall rank of 1 through 5, with 1 being considered very rare and threatened and 5 being considered demonstrably secure. Communities with a Rarity Ranking of S1 (critically imperiled), S2 (imperiled), or S3 (vulnerable) are considered sensitive by the California Department of Fish and Wildlife (CDFW) (Appendix C).

Three sensitive vegetation communities/habitat types were mapped on the project site: vernal pool, Diegan coastal sage scrub (including disturbed and baccharis-dominated), and grassland (including mixed, native, and non-native grassland). Remaining areas on the project site include disturbed habitat and urban/developed, which are not considered sensitive.

Special -Status Plant Species
Special-status plant species have been afforded special status and/or recognition by USFWS and/or CDFW and may also be included in the California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants. Their status is often based on one or more of three distributional attributes: geographic range, habitat specificity, and/or population size. Sensitive species are those considered unusual or limited in that they a re (1) only found in the region; (2) a local representative of a species or associa tion of species not otherwise found in the region; or (3) severely depleted within their ranges or within the region.

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-4
Special -Status Plant Species Observed
Six special-status plant species were observed on the project site during biological surveys conducted in 2020 , 2021, and 2022 (see Table 3.3-2). Locations of special status plant species on the project site can be viewed on Figure 3.3-1, Special-Status Plant Species, of this EIR.

Table 3.3-2. Special-Status Plant Species Observed on the Project Site Plant
Species Status Distribution Habitat(s)
Presence in
the Project
Area
Thread-
leaved
brodiaea
(Brodiaea
filifolia)
Federally listed
threatened. State
listed endangered.

CNPS Rare Plant
Rank 1B.1.

Proposed as a
Narrow Endemic
under the Multiple
Habitat
Conservation Plan
(MHCP). A critical
population of this
species is identified
on the project site by
the MHCP.

Interior valley
regions of
San Diego,
Riverside, Orange,
and Los Angeles
counties.

This perennial bulbiferous
herb typically blooms
sometime between March and
June and is often associated
with vernal pools. It prefers
clay soils and is known from
habitats including valley
grassland, foothill woodland,
coastal sage scrub, and
chaparral.

Approximately
177,723
individuals
(occupying
approximately

8.53 acres plus
isolated/distant
clusters of
individuals) were
cumulatively
mapped
throughout the
project site
during plant
surveys
conducted in
2020, 2021,
and 2022.

Orcutt’s
brodiaea
(Brodiaea
orcuttii)
CNPS Rare Plant
Rank 1B.1.A.

A critical population
of this species is
identified on the
project site by the
MHCP.

Riverside and
San Bernardino
counties south to
Baja California,
Mexico.

This perennial bulbiferous
herb typically blooms
sometime between May and
July and occurs within closed-
cone coniferous forest,
chaparral, cismontane
woodland, meadows and
seeps, valley and foothill
grassland, and vernal pools.

This species prefers mesic or
clay soils.

Approximately
127,517
individuals
(occupying
approximately

6.10 acres plus
isolated/distant
clusters of
individuals) were
cumulatively
mapped
throughout the
project site
during plant
surveys
conducted in
2020, 2021,
and 2022.

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-5
Table 3.3-2. Special-Status Plant Species Observed on the Project Site Plant
Species Status Distribution Habitat(s)
Presence in
the Project
Area
Small-
flowered
morning-glory
(Convolvulus
simulans)
CNPS Rare Plant
Rank 4.2.

Scattered
locations from the
foothills to the
coast in southern
California and
Baja California,
Mexico. Species
rare in southern
California.

This annual herb typically
blooms sometime between
March and July and can be
found on clay and serpentinite
seeps in openings within
chaparral, coastal scrub, and
native grassland.

Three individuals
of this species
were detected
during plant
surveys
conducted in
2020 through
2022 and occur
in the
southwestern
corner of the
project site.

San Diego
button-celery
(Eryngium
aristulatum
var. parishii)
Federally listed
endangered. State
listed endangered.

CNPS Rare Plant
Rank 1B.1.

Proposed as a
Narrow Endemic
under the MHCP. A
critical population of
this species is
identified on the
project site by the
MHCP.

San Diego and
Riverside
counties; Baja
California, Mexico
This perennial herb typically
blooms sometime between
April and August and occurs in
vernal pools or mima mound
areas with vernally moist
conditions, and in mesic areas
on coastal scrub and native
grassland.

Approximately
160 individuals
were
cumulatively
mapped during
plant surveys in
2020, 2021,
and 2022. This
species was
found within four
vernal pools
located in the
northeast, east,
and west
portions of the
project site.
during 2020
surveys.

Chaparral
rein orchid
(Piperia
cooperi)
CNPS Rare Plant
Rank 4.2.

San Diego and
Los Angeles
counties,
Santa Cruz Island,
Santa Catalina
Island; Baja
California, Mexico
This perennial herb typically
grows on dry sites within
grasslands, chaparral, and
cismontane woodland.

One individual of
this species was
found in the
northeastern
portion of the
site during plant
surveys
conducted in
2020 through
2022.

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-6
Table 3.3-2. Special-Status Plant Species Observed on the Project Site Plant
Species Status Distribution Habitat(s)
Presence in
the Project
Area
Graceful
tarplant
(Holocarpha
virgata ssp.
elongata)
CNPS Rare Plant
Rank 4.2
San Diego,
Orange, and
Riverside counties
This annual herb typically
blooms sometime between
May and November and
occurs in grasslands, coastal
scrub, chaparral, and
cismontane woodland.

Approximately
28,780
individuals were
cumulatively
mapped
throughout the
project site
during plant
surveys
conducted in
2020 through
2022.

Source: Appendix C.

Notes: CNPS = California Native Plant Society; MHCP = Multiple Habitat Conservation Program.

Special Status Plant Species with Potential to Occur
A search of CNPS and California Natural Diversity Database records (2-mile radius from the project site), along with Calflora data, was used to develop a matrix of sensitive plant species that may have potential to occur on the project site due to the presence of suitable habitat (e.g., vegetation communities, soils, elevation, and geographic range, life form/blooming period, etc.).

In addition to the six rare plants detected on site during biological surveys, three additional special status plant species have been recorded on the project site by others: San Diego thornmint (Acanthomintha ilicifolia), spreading navarretia (Navarretia fossalis), and small flowered microseris (Microseris douglasii ssp. Platycarpha). San Diego thornmint and spreading navarretia are reported to occur as critical populations on the project site; however, they have not been detected other than historical observations. These three species were not observed within the project site during biological surveys in 2018 , 2020, 2021, or 2022. Because surveys for rare plants conducted for the project were performed during the blooming periods for these plant species, as well as in a year (2020) yielding above average rainfall, these three plant species would have been observed if present on site. Although annual rainfall in 2021 and 2022 was slightly below average according to the Los Angeles Almanac database, these three plant species would have been detected on site, especially in 2020, if present. Further, even though rainfall in 2021 and 2022 was slightly below average, there was an increase in numbers of rare plants detected compared to the above average rainfall year in 2020. Thus, rare plant surveys conducted between 2020 and 2022 are considered an accurate estimate of rare plant distribution and population size on site. Because there are only records of these three other sensitive plants occurring on site, and they have not been reported as occurring since 2009, the potential for these plants to occur on the project site was determined to be low (Appendix C). The remaining 35 special status plant species evaluated are not expected to occur or are presumed to be absent from project site.

Special Status Animal Species
Special status animal species include those that have been afforded special status and/or recognition by USFWS and/or CDFW. In general, the principal reason an individual taxon (species or subspecies) is given such recognition is the documented or perceived decline or limitations of its population size or geograph ical extent and/or distribution, resulting in most cases from habitat loss.

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-7
Special Status Animal Species Observed or Otherwise Detected One special status animal species was detected in the project area during the biological surveys in 2020. This species is discussed below in Table 3.3 -3, and occupied locations are presented on Figure 3.3 -2, Special-Status Wildlife Species. No other special status animals have been detected during surveys for the project.

Table 3.3-3. Special-Status Animal Species Observed on the Project Site Animal Name Status Distribution Habitat(s)
Presence in the
Project Site
San Diego fairy
shrimp
(Branchinecta
sandiegonensis)
Federally listed
endangered.

Proposed as a
Narrow Endemic
under the
MHCP. A critical
population of
this species is
identified on the
project site in
the MHCP.

Southern
California
from coastal
Orange
County to
San Diego
County.

This fairy shrimp is restricted to
vernal pools and other
ephemeral basins. It is found in
seasonally astatic pools that
occur in tectonic swales or earth
slump basins and other areas of
shallow, standing water often in
patches of grassland and
agriculture interspersed in
coastal sage scrub and
chaparral.

This species was
observed on the
project site in
multiple locations
(i.e., vernal pools
and road ruts)
during focused
USFWS protocol
surveys in 2020.

Source: Appendix C.

Special Status Animal Species with Potential to Occur
A search of California Natural Diversity Database and USFWS records within a 2-mile radius from the project site was used to develop a matrix of sensitive animal species that may have potential to occur on site due to the presence of suitable habitat (e.g., vegetation communities, soils, elevation, geographic range, etc.).

In addition to the one sensitive animal detected on site during 2020 focused surveys, one other special status animal species has been historically observed and recorded on the project site by others: burrowing owl ( Athene cunicularia), which is a species of special concern. Although this species was not observed within the project site during biological surveys in 2018 or 2020, including focused surveys, this species is considered to have low potential to occur on the project site based on historic observations and the presence of suitable habitat. Four other special status animal species were not detected during project biological surveys, and were not recorded in prior observations, but are considered to have low potential to occur on the project site based on the presence of suitable habitat: Orange -throated whiptail ( Aspidoscelis hyperythra ), Coronado skink ( Plestiodon skiltonianus interparietalis), Coastal California Gnatcatcher ( Polioptila californica californica ), and Northwestern San Diego pocket mouse (Chaetodipus fallax fallax). Burrowing owl and Northwestern San Diego pocket mouse are species of special concern, orange -throated whiptail and Coronado skink are watch -list Species, and coastal California gnatcatcher is federally listed threatened and species of species concern. No other special status animal species evaluated are expected to occur on the project site due to lack of suitable habitat (Appendix C).

Nesting Birds
Habitats within the project site could provide suitable nesting habitat for bird species, including raptors, known to occur in the region.

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-8
Vegetation Communities
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 (see Table 3.3-4). Vegetation community locations on the project site can be seen on Figure 3.3-3, Vegetation Communities.

Table 3.3-4. Existing Vegetation/Habitat Types1
Vegetation Community/Habitat Type
MHCP Habitat
Group Area (acres)
Off -Site
Improvements
(acres)
Wetland
Vernal Pool (44000) A 0.44 —
Wetland Subtotal — 0.44 —
Upland
Native Grassland (42100) B 13.61 0.01
Diegan Coastal Sage Scrub-disturbed (32500) C 0.71 0.01 Diegan Coastal Sage Scrub-Baccharis-
dominated (32530)
C 0.36 0.01
Grassland – mixed and disturbed (40000) E 13.93 0.35
Non-native Grassland (42200) E 3.52 0.22
Disturbed Habitat (11300) F 0.58 0.06
Developed (12000) F 0.07 1.22
Upland Subtotal — 32.78 1.88
Total — 33.22 1.88
Source: Appendix C.

Note:
1 Acres rounded to the nearest 0.01 acre.

Vernal Pool s (44000)
There are 0.44 acres of vernal pools on the project site. Vernal pools are seasonally flooded depressions that support a highly specialized plant habitat and unique flora and fauna adapted to living in extreme dry and wet conditions. Vernal pools are associated with two important physical conditions: a subsurface hardpan or claypan that inhibits the downward percolation of water and a topography characterized by a series of low hummocks called mima mounds and low depressions (the vernal pools) that prevents above ground water runoff. As the result of these two physical conditions, water collects in these depressions during the rainy season. As the rainy season ends and the dry season begins, the water that has collected in these vernal pools is gradually eva porated. As water evaporates from these pools a gradient of low soil water availability to high soil water availability is created from the periphery of the pool margins to the center of the pool. The chemical composition of the remaining pool water becomes more concentrated as the pool water is evaporated creating a gradient of low ion concentration at the pool periphery to high ion concentration at the pool center. A temporal succession of plant species will occur at the receding pool margins, depending upon the physical and chemical microenvironmental characteristics of the pool.

Vernal pools in a wet year will have a high proportion of native species that are endemic to this habitat. During these years, the exotic, ruderal species, characteristic of the non-native grasslands that occur on the surrounding mima mounds will not invade these pools unable to tolerate the physiological conditions of the ephemeral pool. In

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-9
years of scarce rainfall that is insufficient to saturate the soil and create a surface pool, the native endemic flora will not germinate and pools are often invaded by the exotic species. Vernal pools are typically identified and separated from other wetlands by the presence of “vernal pool indicator species.” Within the project site , vernal pool indicator species were detected at many of the depressions. Typical species found in the project site within areas mapped as vernal pools include San Diego button-celery, dwarf woolly-heads (Psilocarphus brevissimus var. brevissimus), American pillwort (Pilularia americana), flowering-quillwort (Triglochin scilloides), annual hairgrass (Deschampsia danthonioides), pale spike-rush (Eleocharis macrostachya), toad rush (Juncus bufonius), Mexican rush ( Juncus mexicanus), hyssop loosestrife ( Lythrum hyssopifolia), and curly dock (Rumex crispus).

In addition to vernal pools, several other depressional features were identified on site that did not support vernal pool indicator plants and were mapped within grassland vegetation and disturbed habitat; such features were considered “road ruts” or “other depressions.” Road ruts represent features within or alongside dirt paths that display evidence of vehicular tire tracks, and features labeled as other depressions are those not associated/ created by vehicle tracks, are not within roadways, and represent naturally occurring depressional low spots in the site topography. In total, there were 20 vernal pools, 38 road ruts, and 41 other depressions mapped on site during biological surveys conducted for the project (Appendix C).

Diegan Coastal Sage Scrub (Including Disturbed and Baccharis -Dominated; 32500) There are approximately 1.07 acres of Diegan coastal sage scrub on the project site. Diegan coastal sage scrub may be dominated by a variety of species depending upon soil type, slope, and aspect. Typical species found within Diegan coastal sage scrub include California sagebrush ( Artemisia californica), California buckwheat ( Eriogonum fasciculatum), laurel sumac ( Malosma laurina), and black sage ( Salvia mellifera). Disturbed Diegan coastal sage scrub contains many of the same shrub species as undisturbed Diegan coastal sage scrub but has a higher proportion (above 25%) of non-native species. Within the project site, Disturbed Diegan coastal sage scrub contains California buckwheat and California sagebrush, a variety of native herbs, non -native grasses, and herbaceous weeds. Baccharis dominated Diegan coastal sage scrub is dominated by coyote brush ( Baccharis pilularis), with lesser amounts of other typical coastal sage scrub species . This community is also located within the off -site improvement area along La Mirada Drive north of the project (Appendix C).

Grassland (4 0000)
There are approximately 13.93 acres of grassland (mixed and disturbed) on the project site. Grasslands primarily consist of annual grasses and other annual herbaceous species, generally mid-height up to 3 feet tall. Grasslands in southern California occur in a variety of forms such, but not limited to, mixed grassland, valley needlegrass, saltgrass, non -native, and broadleaf or artichoke thistle dominated. Percent plant cover within grasslands is typically high (at least 75%), and the composition of native versus non-native species varies year by year (less than 20% native to greater than 90 % native) depending on site disturbances, annual rainfall, and growing season conditions. Based on surveys in 2019, 2021, and 2022 of the project site (including immediately adjacent off-site improvement areas), three subtypes or forms of grassland were identified and recorded: mixed disturbed grassland, native grassland, and non-native grassland. Areas found on site to be an intermixed mosaic of both native and non- native herbaceous species were mapped as mixed disturbed grassland. The species composition and plant density of mixed grassland mapped varies throughout/across the site, seems to change throughout the growing season, varies from year to year, and ultimately does not clearly reflect a consistent dominance of either native or non - native species. Below are descriptions of the other two grassland types observed on site: native grassland and non- native grassland.

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FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-10
Native Grassland (42100)
There are approximately 13. 61 acres of native grassland on the project site. Native grassland is typically a community dominated by perennial bunchgrasses such as purple needlegrass (Stipa pulchra) or other native grass species. Native and non-native annuals tend to occur between the perennials, often exceeding the bunchgrass in cover. Native grasslands generally occur on fine -textured soils that exclude the growth of annual exotic grass species. The percentage of native species at any one time can be quite low (Appendix C). Areas on site found to be dominated with dense patches of purple needlegrass were mapped as native grassland. Additionally, native grasslands on site reflect areas found during the focused rare plant surveys to be dominated by Orcutt’s brodiaea, thread-leaved brodiaea, or chaparral brodiaea were mapped as native grassland. Further, areas of the site supporting at least 20 percent native plant cover were also mapped as native grassland. Such areas are primarily comprised of common golden stars ( Bloomeria crocea ) and California blue -eyed gras ( Sisyrinchium bellum ); however, these areas also supporte d a high percentage of non -native annual species, including wild oats ( Avena sp.), foxtail chess (Bromus madritensis), soft chess (Bromus hordeaceus), and Bermuda grass (Cynodon dactylon) (Appendix C).

Non-Native Grassland (42200)
There are 3.52 acres of non-native grassland on the project site. Non-native grassland is a dense to sparse cover of annual grasses, often associated with numerous species of showy -flowered native annual forbs (wildflowers).

This grassland typically occurs on gradual slopes with deep, fine-textured, usually clay soils. Characteristic species include wildoats, red brome (Bromus rubens), ripgut (B. diandrus), ryegrass (Festuca sp.), and mustard (Brassica sp.). In accordance with the MHCP definition, this vegetation community was mapped in areas supporting at least 30% non-native plant cover. On -site non-native grassland primarily includes wild oats, foxtail chess, soft chess, Bermuda grass, rattail sixweeks grass ( Festuca myuros ), and purple false brome ( Brachypodium distachyon ) (Appendix C).

Disturbed Habitat (11300)
There are 0.58 acres of disturbed habitat on the project site. Disturbed habitat includes land cleared of vegetation (e.g., dirt roads), land containing a preponderance of non-native plant species such as ornamentals or ruderal exotic species that take advantage of disturbance (previously cleared or abandoned landscaping), or land showing signs of past or present animal usage that removes any capability of providing viable habitat. An unpaved road/trail bisects the site. Additionally, the northeast corner o f the project site is characterized by bare ground and sparse annual non-native weeds. Disturbed habitat is also mapped within the off -site improvement areas northeast and southwest of the site (Appendix C).

Developed Land (12000)
There are 0.07 acres of developed land on the project site. Urban/developed land includes areas that have been constructed upon or otherwise covered with a permanent, unnatural surface and may include, for example, structures, pavement, irrigated landscaping, or hardscape to the extent that no natural land is evident. These areas no longer support native or naturalized vegetation. Urban/developed land in the project site consists of Linda Vista Drive in the southeast corner of the site and utilities in the northeast corner of the site. Additional urban/developed land is immediately adjacent to the project site associated with the off -site improvements within La Mirada Drive, South Las Posas Road, Linda Vista Drive, and South Pacific Street (Appendix C).

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-11
Jurisdictional Aquatic Resources
Potentially jurisdictional resources occur in the project site, consisting of waters of the U.S./State (including wetlands), isolated waters of the State, and streambed with riparian vegetation. These resources are represented by drainages located in the southeast corner of the project site and vernal pools and other seasonally ponded features scattered throughout the site. There are no potentially jurisdictional resources within the off-site improvement area of the project.

A summary, in acreages, of these jurisdictional resources is provided below in Table 3.3-5. Figure 3.3-4, Potentially Jurisdictional Wetlands and Waters, shows the locations of jurisdictional resources.

Table 3.3-5. Potentially Jurisdictional Resources
Potential Jurisdictional
Resources
Potential Resource Agency Jurisdiction
Acres USACE/RWQCB/CDFW USACE/RWQCB RWQCB
Wetlands
Vernal Pools — 0.44 — 0.44
Drainage 1 (Swale) 0.05 — — 0.05
Subtotal 0.05 0.44 — 0.49
Non -Wetland
Drainage 2 (Streambed) <0.01 — — <0.01
Other Seasonally Ponded
Features
— — 0.02 0.02
Subtotal <0.01 0.02 0.02
Total 0.05 0.44 0.02 0.51
Source: Appendix C.

Notes: USACE = U.S. Army Corps of Engineers; RWQCB = Regional Water Quality Control Board; CDFW = California Department of Fish and Wildlife.

Wetland Waters of the U.S./State
Potential wetland waters of the U.S. identified within the project site could be subject to regulation by USACE and include the vernal pools and drainage 1. These wetland waters of the U.S. also represent waters of the State subject to Regional Water Quality Control Board (RWQCB) jurisdiction pursuant to Section 401 of the Clean Water Act (CWA).

Non-Wetland Waters of the U.S./State
The second drainage ( drainage 2) channel in the in the southeast corner of the project site was identified as potential non-wetland waters of the U.S. that could be subject to regulation by the U.S. Army Corps of Engineers (USACE). The waters of the U.S. also represent waters of the State subject to RWQCB jurisdiction pursuant to Section 401 of the CWA.

Waters of the State
The “other ponded features” (i.e., road ruts and other depressions) detected onsite were surveyed for fairy shrimp and rare plants. These features are considered potentially jurisdictional as isolated surface waters of the State subject to RWQCB jurisdicti on, exclusively, pursuant to Porter -Cologne (see Section 3.3. 3, Regulatory Setting).

Potential habitat considered waters of the U.S. that are determined by USACE, through formal application, to be not under their jurisdiction would also be considered isola ted waters of the State subject to RWQCB regulation under Porter-Cologne.

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Streambed and Riparian Habitat
Potential riparian and streambed habitat under the jurisdiction of CDFW within the project site consists of the two drainages in the southeast corner of the project site. These features could be subject to the jurisdiction of CDFW pursuant to Sections 1600-1603 of the California Fish and Game Code (CFGC).

Wildlife Corridors/Core Wildlife Areas
Wildlife corridors connect otherwise isolated pieces of habitat and allow movement or dispersal of plants and animals. Local wildlife corridors allow access to resources such as food, water, and shelter within the framework of their daily routine. Regional corridors provide these functions over a larger scale and link two or more large habitat areas, allowing the dispersal of organisms and the consequent mixing of genes between populations. A corridor is a specific route that is used for the movement and migration of species and may be different from a linkage in that it represents a smaller or narrower avenue for movement. A linkage is an area of land that supports or contributes to the long -term movement of animals and genetic exchange by providing live -in habitat that connects to other habitat areas. Many linkages occur as stepping -stone linkages that are made up of a fragmented archipelago arrangement of habitat over a linear distance.

Important corridors and linkages have been identified on a local and regional scale throughout the Draft North County MHCP (AMEC Earth & Environmental et al. 2003) and adopted City of San Marcos General Plan (City of San Marcos 2012). The planning objectives of most corridors and linkages in western San Diego County include establishing a connection between the northern and southern regional populations of the coastal California gnatcatcher, in addition to facilitating movement and connectivity of habitat for large mammals and riparian bird species.

The project site is not identified as a wildlife corridor in the City of San Marcos General Plan (City of San Marcos 2012). Due to the high number of special status species present within the project site, the Draft North County MHCP incorporates the project site into the MHCP Biological Core and Linkage Area, and the project site is identified as a major amendment area targeted for conservation. The project site is not identified as a preserve, nor are there preserve lands located within 2,000 feet of proj ect site. The project site is not contiguous with any undeveloped land. Given the barrier posed by surrounding development, the site is not expected to serve as a regional wildlife corridor or substantial habitat linkage that would be used by large mammals, riparian birds, or migratory birds. The drainage features on the project site immediately flow subsurface downstream of the project site for approximately 625 feet before re-emerging south of Linda Vista Drive and Grainger Industrial Supply. Thus, the drainage features are unlikely to facilitate wildlife movement outside of the project site.

Thus, given the project site location immediately adjacent to and surrounded by existing roadways and development within an urban setting, the project site is not considered to serve as a wildlife corridor or habitat linkage , either locally or regionally.

3.3.2 Methodology
Literature Review
The biological study area for the project includes the project site and surrounding areas within 50 feet. Prior to conducting the field surveys, HELIX performed a review of relevant maps, databases, and literature pertaining to biological resources known to occur within the project vicinity. HELIX also reviewed a previous biologic al survey information completed for the project site by others. Recent and historical aerial imagery, topographic maps, soils maps, and other maps of the project site and vicinity were reviewed to obtain information on the environmental setting (Appendix C).

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In addition, a query of sensitive species and habitats within a 2-mile radius of the project site was conducted using the USFWS species records, CDFW records, California Natural Diversity Database, Calflora database, SanBIOS, and CNPS Inventory of Rare and Endangered Plants. A search was conducted from the CNPS Electronic Inventory and the USFWS National Wetlands Inventory. Recorded locations of species, habitat types, and other resources were mapped and overlain onto aerial imagery using Geographic Information Systems (Appendix C).

Biological Surveys
General Biological Survey s
HELIX biologist conducted an initial general biological survey of the project site on July 24, 2018. HELIX biologists conducted an additional biological assessment of the project site on April 22, 2020, to verify the 2018 resources mapping remained accurate, and to refine, where appropriate. HELIX biologist mapped vernal pool watersheds directly in the field with a GPS unit in September 2020. Vegetation communities were classified and mapped. Survey mapping utilized a 1 -inch = 50 -foot scale aerial map with an overlay of th e project site and previous resource mapping. A GPS was used during the survey to record the limits of vegetation and other resources on site. Another survey of the project site was conducted by HELIX biologist on March 26, 2021, to review the existing site conditions, evaluate the mapped vernal pools, assess the status of annual plants, and verify accuracy of the biological resources mapped in 20 20. HELIX biologist reviewed the status of brodiaea mapping on March 18, 2021.

Additionally, multiple surveys we re conducted in 2022 by HELIX biologists to assess the vernal pools, verify vegetation and site conditions, assess grasslands, document and count special-status plants on site, and to evaluate potential species and habitat mitigation (translocation, creation, restoration, enhancement, and preservation) areas on site. Specifically, in 2022, site visits were conducted on February 25, March 1, March 29, March 31, April 6, May 9, May 10, May 13, July 19, August 4, and August 5.

Vegetation communities were mapped by HELIX to one-hundredth of an acre (0.01 acres). A list of all plant and animal species observed or detected within the project site was prepared. Plant species were identified in the field or later in the laboratory with the aid of voucher specimens. Animals were identified in the field by direct visual observation with the aid of binoculars or indirectly by detection of calls, tracks, burrows, or scat.

Jurisdictional Delineation
During the general biological survey on July 24, 2018, HELIX biologist preliminarily identified and mapped jurisdictional aquatic resources potentially subject to UUSACE jurisdiction pursuant to Section 404 of the CWA, RWQCB jurisdiction pursuant to Section 401 of the CWA and State Porter-Cologne Water Quality Control Act (Porter- Cologne), and streambed and riparian habitat potentially subject to CDFW jurisdiction pursuant to Section 1600 et seq. of the CFGC. Additionally, HELIX biologists Jason Kurnow and Angelia Bottiani performed a formal wetland delineation of the project site on April 22, 2020. Potential aquatic resources evaluated within the project site included drainage features, swales, depressions, wetland vegetation, and areas where ponding was observed.

Waters of the U.S. (USACE Jurisdiction)
Potential USACE-jurisdictional wetlands and waters of the U.S. were delineated in accordance with the Wetlands Delineation Manual (Appendix C), Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (USACE 2008), and the Navigable Waters Protection Rule: 85 FR 22250 (Appendix C). The delineation was located within representative uplands and wetlands of the project site, and mapping of drainage features was performed in the field based on ordinary high -water mark and surface indications of hydrology. Five soil pits were

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excavated and evaluated by HELIX in 2020. Areas are determined to be potential wetland waters of the U.S. if there is a dominance of hydrophytic vegetation, hydric soils, and wetland hydrology indicators. Areas are determined to be non-wetland waters of the U.S. if there is evidence of regular surface flow (i.e., perennial or intermittent) within an ordinary high-water mark, but the vegetation and/or soils criterion is not met, and the waters are immediately adjacent to wetlands or are hydrologically connected to downstream navigable waters.

No soil pits were dug in the vernal pools because hydrology and aquatic vegetation extents were evident during survey. Due to the soil profiles and conditions that support vernal pools, presence of hydric soils was assumed.

Thus, pools found to support pon ding and vernal pool aquatic indicator plant species were mapped as potential wetland waters of the U.S. In general, areas were determined to be potential wetland waters of the U.S. if there was a dominance of hydrophytic vegetation, hydric soils, and wetl and hydrology indicators. Areas were determined to be non-wetland waters of the U.S. if there was evidence of regular surface flow within an ordinary high-water mark, but the vegetation criterion was not met.

Waters of the State (RWQCB Jurisdiction)
Potential RWQCB-jurisdictional areas were delineated in the same manner as potential waters of the U.S. All waters of the U.S. were considered waters of the State subject to RWQCB jurisdiction pursuant to CWA Section 401.

Additionally, features that suppor t aquatic resources (i.e., hydrophytic vegetation, hydric soils, and wetland hydrology), but are isolated (i.e., lack downstream connectivity to traditional navigable waters of the U.S.) could be subject to regulation pursuant to the State Porter-Cologne Water Quality Control Act (Porter-Cologne) and would be identified as potential RWQCB-jurisdictional waters of the State.

Streambed and Riparian Habitat (CDFW Jurisdiction)
Potential CDFW-jurisdictional streambed and riparian habitat was determined based on the presence of riparian vegetation or regular surface flow within a definable bed and bank. Streambeds within CDFW jurisdiction were delineated based on the definition of streambed as “a body of water that flows at least periodically or intermittently through a bed or channel having banks and supporting fish or other aquatic life. This includes watercourses having a surface or subsurface flow that supports riparian vegetat ion” ( 14 CCR 1.72 ). Potential CDFW -jurisdictional unvegetated streambed encompasses the top-of-bank to top-of-bank width for the features within the project site.

Riparian habitat is not defined in Title 14, but the section refers to vegetation and habitat associated with a stream.

Focused Species Surveys
Rare Plants
Spring surveys for rare plants were conducted across the project site by HELIX on May 11, 13, 15, 16 , and 29, 2020 by HELIX biologists. The surveys consisted of systematically walking meandering transects throughout the entire project site. At each rare plant location, the plant was identified to species based on unique flower characteristics, the number of individuals was estimate d, and the location was recorded with a GPS unit. Due to the relatively large area supporting Graceful tarplant ( Holocarpha virgata ssp. elongata) on site, this species was also mapped and quantified using similar methods as thread-leaved and Orcutt’s brodiaea species. Following the field surveys, GPS data was analyzed, and polygons were created where appropriate to demonstrate overall distribution. Clusters and individuals of rare plants that were isolated/distant from the polygons were left as single point locations. HELIX also searched for rare plants during the jurisdictional delineation discussed above and the focused animal surveys summarized below. Furthermore, to assess the status, locations, and quantities of rare

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plants relative to the 2020 surveys, HELIX biologists surveyed the site for rare plants, using the methods from May 2020, on March 26 and May 18, 2021; as well as on May 9, 10, 13, July 19, and August 4 and 5, 2022. The results of these efforts have been compiled as part of the Biological Technical Report (Appendix C).

Burrowing Owl
Focused surveys for burrowing owl ( Athene cunicularia) were conducted by HELIX in 2020 in accordance with current CDFW burrowing owl survey guidelines. Four site visits were made from March 30 through June 22, 2020, to survey potential burrowing owl habitat where it occurs on the project site and 500 feet beyond. Survey weather conditions, time of year, and time of day were appropriate for detecting burrowing owl (Appendix C).

Coastal California Gnatcatcher
Focused surveys for the coastal California gnatcatcher were conducted in 2020 in accordance with the Coastal California Gnatcatcher (Polioptila californica californica) Presence/Absence Survey Protocol (USFWS 1997) by HELIX. The survey consisted of six site visits made from April 6 through May 11, 2020 , and conducted during appropriate weather conditions and time of day for detecting coastal California gnatcatcher (Appendix C).

Fairy Shrimp
Protocol wet season and dry season focused surveys for San Diego fairy shrimp were conducted in 2020 in accordance with the Survey Guidelines for the Listed Large Branchiopods (USFWS 2017) by HELIX ( Appendix C).

Seven survey visits were conducted for the wet -season survey between March 22 and May 4, 2020, when all features on the project site were observed to be dry. During the survey, HELIX attempted to verify and identify all features previously sampled by other s. It was determined that the surveys were c onducted during appropriate timing to detect suitable fairy shrimp habitat and fairy shrimp on the project site (Appendix C).

Survey Limitations
Noted animal species were identified by direct observation, vocalizations, or the observance of scat, tracks, or other signs. However, the lists of species identified are not necessarily comprehensive accounts of all species that use the project site, as species that are nocturnal, secretive, or seasonally restricted may not have been observed.

Those special-status species that have the potential to occur on the project site based on historic observation and the presence of potentially suitable habitat are addressed herein.

3.3.3 Regulatory Setting
Federal
Federal Endangered Species Act
Administered by USFWS, the federal Endangered Species Act (ESA) of 1973 provides the legal framework for the listing and protection of species (and their habitats) that are identified as being endangered or threatened with extinction. Under the ESA, “take” of listed animal and plant species in areas under federal jurisdiction is prohibited without obtaining a federal permit. Section 9(a) of the ESA defines take as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.” “Harm” and “harass” are further defined in f ederal regulations and case law to include actions that adversely impair or disrupt a listed species’ behavioral patterns. Under ESA, USFWS may issue incidental take statements, which authorize the take of listed wildlife species provided such take does not jeopardize the continued existence of the species.

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Sections 7 and 4(d) of the Federal ESA regulate actions that could jeopardize endangered or threatened species.

Section 7, administered by USFWS, describes a process of Federal interagency consultation for use when Federal actions may adversely affect listed species. A Section 7 Consultation (formal or informal) with USFWS is required when there is a nexus between a listed species’ use of a site and a project is requesting a federal action, including funding.

If the action may affect listed species, a biological assessment is required for any major construction activity. USFWS determines, through the biological assessment or other review, whether the action is likely to adversely affect a listed species and thereby require formal consultation. At the conclusion of formal consultation, USFWS will prepare a Biological Opinion. The Biological Opinion will state whether will state whether the Federal agency has insured that its action is not likely to jeopardize the continued existence of a listed species and/or result in the destruction or adverse modification of critical habitat. If avoidance cannot be achieved, incidental take can be authorized via the Biological Opinion, issued by USFWS, for non-marine related listed species issues. A Section 7 Consultation could be required if impacts to a federally listed species would occur and there is requested federal action.

If a project could directly or indirectly impact federally listed species and/or their critical habitat, and there is no federal action/nexus (e.g., permit, funding, ownership, etc.), the Federal Endangered Species Act requires the project proponent to consult with USFWS under Section 10. A consultation under Section 10 of the ESA requires submittal of an Incidental Take Permit (ITP) application and a Habitat Conservation Plan to USFWS for e valuation of proposed project impacts. If USFWS determines the proj ect would have a “low effect” on listed, proposed, or candidate species and their habitats, and the project would have minor effects on other environmental resources, USFWS would complete the consultation process and issue an ITP. If a project is determined by USFWS to have a “moderate or high effect” on listed, proposed, or candidate species and their habitats, USFWS would require preparation of National Environmental Policy Act (NEPA) analysis prior to issuance of an ITP. The National Environmental Policy Act analysis would include additional evaluation of the project impacts in the form of an Environmental Assessment or an Environmental Impact Statement. A Section 10 Consultation could be required if impacts to a federally listed species would occur.

Identified by USFWS, critical habitat is defined as areas of land that are considered necessary for endangered or threatened species to recover. The ultimate goal is to restore healthy populations of listed species within their native habitat, so they can be removed from the list of threatened or endangered species. Once an area is designated as critical habitat pursuant to the federal ESA, all federal agencies must consult with USFWS to ensure that any action they authorize, fund, or carry out is not likely to result in destruction or adverse modification of the critical habitat.

Clean Water Act
The CWA is intended to restore and maintain the quality and biological integrity of the nation’s waters. Section 402 of the CWA prohibits the discharge of pollutants to “waters of the United States” from any point source unless the discharge is in compliance with a National Pollutant Discharge Elimination System Permit. The CWA, Section 402, requires a National Pollutant Discharge Elimination System Permit for the discharge of stormwater from municipal separate storm sewer systems serving urban areas with a population greater than 100,000, construction sites that disturb 1 acre or more, and industrial facilities. The RWQCB administers these permits with oversight provided by the State Water Resources Control Board and U.S. Environmental Protection Agency Region IX.

Section 404 of the CWA authorizes the Secretary of the Army, acting through USACE, to issue permits regulating the discharge of dredged or fill materials into the “navigable waters at specified disposal sites.” CWA Section 502 further defines “navigable waters” as “waters of the United States, including territorial seas.” Waters of the United States are broadly defined in the Code of Federal Regulations (CFR), Title 33, Section 328.3, Subdivision (a), to

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include navigable waters; perennial and intermittent streams, lakes, rivers, and ponds; and wetlands, marshes, and wet meadows.

The limits of USACE’s CWA Section 404 jurisdiction in non-tidal waters are defined by the ordinary high water mark, unless adjacent wetlands are present. The ordinary high water mark is a line on the shore or edge of a channel established by the fluctuations of water and ind icated by physical characteristics such as a clear, natural line impressed upon the bank, shelving, changes in the character of soil, destruction of vegetation, or presence of debris (33 CFR 328.3). As a result, waters are recognized in the field by the presence of a defined watercourse with appropriate physical and topographic features. If wetlands occur within or adjacent to waters of the United States, the lateral limits of USACE’s jurisdiction extends beyond the ordinary high water mark to the outer edge of the wetland.

Section 401 of the CWA requires that an applicant for a federal license or permit to discharge into navigable waters provide the federal agency with a water quality certification declaring that the discharge would comply with water quality standard require ments of the CWA. USACE is prohibited from issuing a CWA permit until the applicant receives a CWA, Section 401, water quality certification or waiver from the RWQCB.

Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) (16 USC 703 et seq.) is a federal statute that implements treaties with several countries on the conservation and protection of migratory birds. The number of bird species covered by the MBTA is extensive and is listed in 50 CFR 10.13. The regulatory definition of “migra tory bird” is broad and includes any mutation or hybrid of a listed species and includes any part, egg, or nest of such bird (50 CFR

10.12). Migratory birds are not necessarily federally listed endangered or threatened birds under the ESA. The MBTA, which is enforced by USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migratory bird or attempt such actions, except as permitted by regulation. The applic able regulations prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, except under a valid permit or as permitted in the implementing regulations (50 CFR 21.11). In common practice, the MBTA is now used to place restrictions on disturbance of active bird nests during the nesting season (generally January 15 through September 15 ). In addition, USFWS commonly places restrictions on disturbances allowed near active raptor nests.

State
California Environmental Quality Act
Primary environmental legislation in California is found in CEQA and its implementing guidelines (CEQA Guidelines), which require that projects with potential adverse effects (i.e., impacts) on the environment undergo environmental review. Adverse environmental impacts are typically mitigated as a result of the environmental review process in accordance with existing laws and regulations.

California Endangered Species Act
CDFW administers the California ESA (California Fish and Game Code, Section 2050 et seq.), which prohibits the take of plant and animal species designated by the Fish and Game Commission as endangered or threatened in California. Under the California ESA, Section 86, take is defined as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” California ESA, Section 2053, stipulates that state agencies may not approve projects that would “jeopardize the continued existence of any endangered species or threatened species or result in the destruction or adverse modification of habitat essential to the continued existence of those species,

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if there are reasonable and prudent alternatives available consistent with conserving the species or its habitat which would prevent jeopardy.”
California ESA, Sections 2080 through 2085, address the taking of threatened, endangered, or candidate species by stating, “No person shall import into this state, export out of this state, or take, possess, purchase, or sell within this state, any species, or any part or product thereof, that the Commission determines to be an endangered species or a threatened species, or attempt any of those acts, except as otherwise provided in this chapter, the Native Plant Protection Act (California Fish and Game Code , Sections 1900–1913), or the California Desert Native Plants Act (Food and Agricultural Code, Section 80001).”
California Fish and Game Code
The CFGC provides specific protection and listing for several types of biological resources. Section 1600 of the CFGC requires a Streambed Alteration Agreement for any activity that would alter the flow, change, or use any material from the bed, channel, or bank of any perennial, intermittent, or ephemeral river, stream, and/or lake.

Typical activities that require a Streambed Alteration Agreement include excavation or fill placed within a channel, vegetation clearing, structures for diversion of water, installation of culverts and bridge supports, cofferdams for construction dewatering, and bank reinforcement. Notification is required prior to any such activities.

If the project could result in adverse impacts to a state -listed species that is not also federally listed, Section 2081(b) of the CFGC provides a mechanism for CDFW to permit, on a project-specific basis, incidental take of species listed under the California ESA. Preparation and submittal of an ITP application with CDFW by the project proponent is required. The application must include project details, potential project impacts, an analysis of “jeopardy” for the continued existence of the impacted species , and species -specific mitigation and avoidance measures that would fully mitigate for the project impacts.

Pursuant to CFGC Section 3503, it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. Raptors and owls and their active nests are protected by CFGC Section 3503.5, which states that it is unlawful to take, possess, or destroy any birds of prey or to take, possess, or destroy the nest or eggs of any such bird unless authorized by the CDFW.

Section 3513 states that it is unlawful to take or possess any migratory non-game bird as designated in the MBTA.

These regulations could require that construction activities (particularly vegetation removal or construction near nests) be reduced or eliminated during critical phases of the nesting cycle unless su rveys by a qualified biologist demonstrate that nests, eggs, or nesting birds will not be disturbed, subject to approval by CDFW and/or USFWS.

Porter -Cologne Water Quality Control Act
This statute regulates surface waters and wetlands within the State and is governed by RWQCB. Features that support aquatic resources (i.e., hydrophytic vegetation, hydric soils, and wetland hydrology ), but are isolated (i.e., lack downstream connectivity to waters of the U.S.) could be subject to regulation pursuant to the State Porter - Cologne Water Quality Control Act (Porter-Cologne). Impacts to isolated wetlands and/or waters of the State require a Waste Discharge Requirement Permit from the RWQCB.

Natural Communities Conservation Planning Act
The Natural Communities Conservation Planning (NCCP) program is a cooperative effort to protect habitats and species. It began under the state's NCCP Act of 1991, legislation broader in its orientation and objectives than the

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California ESA or federal ESA. These laws are designed to identify and protect individual species that have already declined significantly in number. The NCCP Act of 1991 and the associated Southern California Coastal Sage Scrub NCCP Process Guidelines (1993), Southern California Coastal Sage Scrub NCCP Conservation Guideline s (1993), and NCCP General Process Guidelines (1998) have been superseded by the NCCP Act of 2003.

The primary objective of the NCCP program is to conserve natural communities at the ecosystem level while accommodating compatible land use. The program seeks to anticipate and prevent the controversies and gridlock caused by species' listings by focusing on the long-term stability of wildlife and plant communities and including key interests in the process.

This voluntary program allows the state to enter into planning agreements with landowners, local governments, and other stakeholders to prepare plans that identify the most important areas for a threatened or endangered species, and the areas that may be l ess important. These NCCP plans may become the basis for a state permit to take threatened and endangered species in exchange for conserving their habitat. The CDFW and USFWS worked to combine the NCCP program with the federal Habitat Conservation Plan process to provide take permits for state and federal listed species. Under the NCCP, local governments, such as the County, can take the lead in developing these NCCP plans and become the recipients of state and federal take permits.

Local
City of San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of biological resources (City of San Marcos 2012). The following goals and policies apply to the project:

Goal COS-1: Identify, protect, and enhance significant ecological and biological resources within San Marcos and its adaptive Sphere of Influence.

Policy COS-1.1: Support the protection of biological resources through the establishment, restoration, and conservation of high-quality habitat areas.

Policy COS -1.2: Ensure that new development, including Capital Improvement Projects, maintain the biotic habitat value of riparian areas, oak woodlands, habitat linkages, and other sensitive biological habitats.

Policy COS-1.3: Continue to work with other federal, State, regional, and local agencies to implement, SANDAG’s MHCP.

Goal COS-2: The City is committed to conserving, protecting, and maintaining open space, agricultural, and limited resources for future generations. By working with property owners, local organizations, and state and federal agencies, the City can limit the conversion of resource lands to urban uses.

Policy COS-2.1: Provide and protect open space areas throughout the City for its recreational, agricultural, safety, and environmental value.

Policy COS-2.2: Limit, to the extent feasible, the conversion of open space to urban uses and place a high priority on acquiring and preserving open space lands for recreation, habitat protection and enhancement, flood hazard management, water and agricultural resources protection, and overall community benefit.

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Policy COS-2.6: Preserve healthy mature trees where feasible; where removal is necessary, trees shall be replaced at a ratio of 1:1.

Goal COS-3: Protect natural topography to preserve and enhance the natural beauty of San Marcos.

Policy COS -3.3: Continue to work with new development and redevelopment project applicants in designing land use plans that respect the topography, landforms, view corridors, wildlife corridors, and open space that exists.

Policy COS-3.4: Evaluate potential impacts to visual and aesthetics resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

Goal COS-8: Focus watershed protection, surface and groundwater quality management on sources and practices that the City has the ability to affect.

Policy COS-8.4: Require new development and redevelopment to protect the quality of water bodies and natural drainage systems through site design, source controls, storm water treatment, runoff reduction measures, Best Management Practices (BMPs), low impact development hydromodification strategies consistent with the current San Diego Regional Water Quality Control Board Municipal Stormwater National Pollutant Discharge Elimination System Permit, and all future municipal stormwater permits.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3. 10, Land Use and Planning. As shown in Section 3. 10.4, Project Impact Analysis, the project is consistent with the applicable goals and policies related to biological resources.

Multiple Habitat Conservation Program
The California NCCP Act of 1991 (Section 2835) allows the CDFW to authorize take of species covered by plans in agreement with NCCP guidelines. A NCCP, initiated by the State of California, focuses on conserving coastal sage scrub, and in concert with USFWS and the federal ESA, is intended to avoid the need for future federal and state listing of coastal sage scrub-dependent species.

The MHCP Plan spans across northwestern San Diego County and has goals of providing protection for over 80 special status species and approximately 19,000 acres of proposed conservation land ( AMEC Earth & Environmental et al. 2003 ). The City of San Marcos and six additional city jurisdictions (Carlsbad, Encinitas, Escondido, Oceanside, Solana Beach, and Vista ) make up the M HCP Plan area. It is a comprehensive, long -term habitat conservation plan that addresses the needs of multiple species by identifying key areas for preservation as open space in order to link core biological areas into a regional wildlife preserve. The MHCP is one of several large multiple jurisdictional habitat planning efforts in San Diego County, each of which constitutes a subregional plan under the NCCP Act of 1991. The M HCP includes incorporated cities in northwestern San Diego County that will implement their respective portions of the M HCP through citywide “subarea” plans, which describe the specific implementing mechanisms each city will institute for the MHCP.

The project site is located within the San Marcos Subarea, which has a Draft Subarea Plan, but was never approved or adopted and remains in draft form as of the date of this report. Although not adopted, the MHCP identifies potential preserve areas as “FPAs” (i.e., Focused Planning Areas) that reflect areas targeted for conservation in

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collaboration with the wildlife agencies, developers, property owners, and various environmental groups. In the context of the se draft plans, the project site is identified as a “Major Amendment Area” and currently not incorporated in the MHCP or San Marcos Subarea Plan. Because the City of San Marcos has not approved or adopted their Draft Subarea Plan ; the project is not subject to the requirements of the MHCP, although it is recognized and herein as a guide for project site planning considerations.

3.3.4 Thresholds of Significance
The significance criteria used to evaluate the project impacts to biological resources are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to biological resources would occur if the project would:

Threshold No. 1: Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Threshold No. 2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Threshold No. 3: Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Threshold No. 4: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

Threshold No. 5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Threshold No. 6: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

3.3.5 Project Impact Analysis
As described in Chapter 2 , Project Description, of this EIR, t he project consists of 449 residential units, including 927 parking spaces and 134,985 square feet of common open space area on approximately 15.09 acres within the approximately 33.2-acre project site. The remaining 17.94 acres of the approximately 33.2- acre project site would be preserved and restored open space and habitat area . The proposed project would have a density of approximately 29.8 dwelling units per acre not including the proposed open space and habitat area. With the open space and habitat area included, the density of the proposed project would be approximately 13.5 dwelling units per acre .

The significance of impacts to biological resources present , or with potential to occur on the project site, was determined based upon the sensitivity of the resource and the extent of the anticipated impact. For certain highly sensitive resources (e.g., a federally listed species), any impact would be considered significant. Conversely, other

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resources that are of low sensitivity (e.g., species with a large, locally stable population in the County but declining elsewhere) could sustain some impact with a less than significant effect.

The issues addressed in this section are derived from Appendix G of the State CEQA Guidelines. Mitigation, monitoring, and reporting requirements to eliminate or reduce project impacts to a less than significant level are also provided herein.

Threshold No. 1: Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Special status plant and animal species on the project site could be impacted as a result of project implementation.

Six special-status plants and one special -status animal species would be directly impacted by grading for the proposed project (Impact BIO-1). These species are discussed further below in this section. Direct impacts could also occur during construction if activities inadvertently encroach into areas outside/beyond the authorized limits of work, generate fugitive dust, create excessive noise, or cause erosion or sedimentation into adjacent areas .

Direct impacts to sensitive species would be significant as described below but would be reduced to less than significant levels with the implementation work limits demarcation, pre-construction surveys, biological construction monitoring, and implementation of construction best management practices (BMPs).

Indirect impacts to sensitive species (plants and animals) by the proposed project would not occur. Potential impacts as a result of increase human presence, noise, domestic animals, the spread of non -native species, and artificial lighting are not anticipated as discussed in detail in Appendix C.

Special -Status Plants
Four special-status plant species occurring on site would be directly impacted by the project: San Diego button- celery (federally listed endangered, state -listed endangered, CNPS California Rare Plant Rank [CRPR] 1B.1, proposed Narrow Endemic under the MHCP), thread -leaved brodiaea (federally listed threatened, state -listed endangered, CNPS CRPR 1B.1, proposed Narrow Endemic under the MHCP), Orcutt’s brodiaea (CNPS CRPR 1B.1), and graceful tarplant (CNPS CRPR 4.2) (Figure 3.3-1). Direct impacts to chaparral rein orchid (CNPS CRPR 4.2) and small-flowered morning-glory (CNPS CRPR 4.2) are not expected.

Additionally, direct impacts to these plant species could also occur if project construction inadvertently extends beyond the allowed ground disturbance footprint (limits of work). However, such impacts to special status plants could be avoided through the implementation of standard BMPs during construction, in addition to measures proposed to mitigate potential direct impacts on other sensitive plant species, such as preconstruction surveys, the installation of temporary construction and/or silt fencing at the limits of work, biological construction monitoring where work limits occur adjacent to known sensitive resources, and long -term protection and management of avoided resources.

Graceful Tarplant
Graceful tarplant is a low -sensitivity species (CNPS CRPR 4.2), is not proposed for coverage by the MHCP, and is relatively widespread locally and regionally. Impacts to plant species with a CNPS CRPR 2 or lower are considered potentially significant. Beca use graceful tarplant has a CRPR of 4.2, and this species is also located within the preserved and restored open space areas of the site, and the restoration efforts discussed in the Habitat Mitigation

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Monitoring Plan (HMMP) would include this species in the plant palette, impacts to this species are not expected to jeopardize its sensitivity status or long-term survival in the region. Therefore, project impacts to this species would be less than significant and would not require mitigation.

San Diego Button -Celery, and Thread -leaved Brodiaea
San Diego button-celery and thread-leaved brodiaea are federally listed endangered and threatened, respectively, and are both CNPS CRPR 1B.1 plants. San Diego button -celery and thread-leaved brodiaea are also state listed endangered. These two species are also proposed as Narrow Endemic under the MHCP, which identifies the project site as supporting critical populations of these two species.

Approximately 33,714 individuals (19%) of thread-leaved brodiaea and 47 individuals of San Diego button-celery (29%) are located within the project footprint and would be directly impacted. Direct impacts to these two listed species are considered significant. Impacts to these two species would require consultation with USFWS through the ESA Section 7 or Section 10 processes, as well as authorization from CDFW in accordance with the California ESA Section 2081 or 2080.1 of the CFGC, as applicable.

Implementation of mitigation measures MM-BIO-1 and MM-BIO-3 would be required to ensure direct impacts to these species would be reduced to less than significant levels. Direct impacts/loss of occupied habitat resulting from the proposed project would be mitigated through preparation and the implementation of an HMMP and/or a Preserve Management Plan (PMP) in accordance with mitigation measures MM-BIO-3, MM-BIO-7a, and MM-BIO-7b (as discussed in response to Threshold No. 2, below).

Direct impacts to these two species could also occur if appropriate avoidance and minimization measures are not implemented during construction. Potential direct impacts could be avoided through installation of temporary construction and/or silt fencing at the limits of work ( refer to mitigation measures MM-BIO-5, below), biological construction monitoring where work limits occur adjacent to known sensitive resources (refer to mitigation measure MM-BIO-6, below), and implementation of construction BMPs.

Orcutt’s Brodiaea
Direct impacts to Orcutt’s brodiaea would occur as a result of construction activities within the project impact footprint. Although a non -listed species, Orcutt’s brodiaea is a CNPS CRPR 1B.1 species, which carries a higher rank of sensitivity as these species are rare, are generally considered endemic to California, and their populations and range have been in decline. Additionally, the MHCP identifies the project site as supporting a critical population for this species. Direct impacts to this species, approximately 80,907 of the 127,517 individuals mapped on site (approximately 63.4%), would be considered significant.

Implementation of minimization, conservation, and translocation measures prescribed by mitigation measures, MM-BIO-1, and MM-BIO-3 would be required to ensure impacts to this species would be reduced to less than significant levels. Direct impacts/loss of occupied habitat for this species would be mitigated by the implementation of an HMMP in accordance with mitigation measures MM-BIO-3, MM-BIO-7a and MM-BIO-7b (as discussed in response to Threshold No. 2, below).

Direct impacts to this species could also occur if appropriate avoidance and minimization measures are not implemented during construction, including the installation of temporary construction and/or silt fencing at the limits of work ( refer to MM-BIO-5), biological construction monitoring where work limits occur adjacent to known

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sensitive resources ( refer to MM-BIO-6), and implementation construction BMPs. Perpetual protection and management of occupied habitat for this species would be provided by the implementation of a PMP as set forth in mitigation measure MM-BIO-7b.

Special Status Animal Species
San Diego Fairy Shrimp
San Diego fairy shrimp is a federally listed endangered species. This species is also proposed as Narrow Endemic under the MHCP, which identifies the project site as supporting a critical population of this species. Of the 20 basins (including 18 vernal pools and 2 road ruts) found to support this species on site, direct impacts would occur to 8 basins (approximately 40%) located within the proposed project impact footprint (Figure 3.3-2). These eight basins occupied by San Diego fairy shrimp to be directly impacted by the project consist of seven vernal pools and one road rut, located in the northern, central, and northeastern portions of the site, respectively.

As part of the project design planning and analysis of potential impacts to San Diego fairy shrimp, an evaluation of the vernal pools and their watersheds was reviewed using on ‐site topography data, field mapping with GPS, and the drainage study completed for the project site. Potential drainage direction lines were overlaid onto the vernal pool mapping, along with the proposed project footprint, to evaluate project impacts. Although the project development could potentially intercept drainage flow in the n orthwestern portion of the site, there has been no surface evidence of drainage flow during field surveys conducted between 2019 and 2022, and furthermore, upon review of historical aerial imagery, no photographs were found suggesting such surface flow or ponding connections between vernal pools exist on site (Historical Aerials). Because of the lack of surface flow evidence and flat (less than 10% slopes) topography on site, the surface drainage flow, if present, is suggested to be minimal. Based on field surveys conducted over multiple consecutive years (2019 through 2022) across the site as well as a review of historical aerial imagery, it is expected that the vernal pools, road ruts, other depressional features, on‐site fill with water as a result of direct precipitation rather than flow connection across the site. Therefore, and furthermore, these features likely function independently of each other rather than connected together. Thus, impacts to pools in the northern portion of the site are not expected to adversely affect the remaining pools on site to be avoided by the project and proposed for preservation by the project.

Ultimately, the proposed project considered the vernal pool watersheds. Although the project would impact 8 basins occupied by San Diego fairy shrimp, the remaining 12 basins on‐site occupied by San Diego fairy shrimp (11 vernal pools and 1 road rut) to be avoided by the project development, including avoidance of their corresponding watersheds plus a buffer surrounding the watershed. Further, the project also considered on‐site drainage direction and would be designed in a manner to mimic the potential dra inage/discharge flow point and path on ‐site; thus, project impacts to site drainage would be minor and considered less than significant.

Implementation of avoidance, minimization, conservation, and translocation measures prescribed by mitigation measures MM-BIO-2 and MM-BIO-3 would ensure project impacts to this species would be reduced to less than significant levels. Further, direct impacts to this listed species would require authorization and consultation with USFWS through the ESA Section 7 or Section 10 processes, as applicable, as well as with CDFW in accordance with the CESA Section 2081 or Section 2080.1 of the CFGC (MM-BIO-3). Direct impacts/loss of occupied habitat for this species would be mitigated by the implementation of an HMMP in accordance with mitigation measures MM-BIO-3, MM-BIO-7a and MM-BIO-7b (as discussed in response to Threshold No. 2, below).

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Direct impacts to this species could also occur if appropriate avoidance and minimization measures are not implemented, including measures proposed for potential indirect impacts on other sensitive species, such as: the installation of temporary construction and/or silt fencing at the limits of work ( MM-BIO-5), biological construction monitoring where work limits occur adjacent to known sensitive resources ( MM-BIO-6), and long-term protection and management of avoided resources through the implementation of a PMP (MM-BIO-3, MM-BIO-7ab and MM-BIO-7bc). Impacts to this listed species would be considered potentially significant without mitigation.

Nesting Birds
The project site contains trees, shrubs, and other vegetation that provide suitable nesting habitat for common birds, including raptors, protected under the MBTA and CFGC. Construction of the proposed project includes vegetation clearing, which could result in direct impacts to nesting birds if the removal or trimming of vegetation occurs during the bird nesting season (January 15 through September 15). Such impacts to nesting birds would be in violation of the MBTA and CFGC and would be significant, especially if the activities would impact the nesti ng of candidate, sensitive, or special status species. Additionally, construction activities could result in indirect impacts through disturbance to nesting from noise, dust, and physical presence , such that the disturbance results in nest abandonment or nest failure. These indirect impacts would also be considered significant. Implementation of mitigation measure MM-BIO-4 would require preconstruction surveys prior to impacts and construction fencing and biological monitoring measures MM-BIO-5 and MM-BIO-6 would reduce potentially significant impacts on nesting birds, including raptors, to less-than-significant levels.

USFWS Critical Habitat
Nearly the entire project site overlaps with the designated final critical habitat overlay for three federally listed species, including: San Diego fairy shrimp, thread-leaved brodiaea, and spreading navarretia. As mentioned earlier, spreading navarretia was not detected during surveys for this species in 2020 or 2021. Although the project site is substantially disturbed and lacks connectivity to off-site habitat, the proposed impact area occurs within areas that support primary constituent habitat elements associated with these species. Therefore, development on the project site could result in adverse modification to critical habitat for these species , and impacts would be potentially significant without mitigation.

Direct impacts to USFWS critical habitat by the proposed project are considered significant. These impacts would require authorization and consultation with USFWS through the ESA Section 7 or Section 10 processes, as applicable. Implementation of minimization, conservation, and/or translocation measures would reduce impacts to less than significant. Specifically, mitigation measures MM-BIO-1, MM-BIO-2, MM-BIO-3, MM-BIO-5, and MM-BIO-6 would be required, as well as the implementation of mitigation measures MM-BIO-7a and MM-BIO-7b, which would ensure direct impacts to these species would be reduced to less than significant.

Conclusion
The proposed development of the site has the potential to result in significant impacts to special status plant and animal species, including general nesting birds and raptors (Impact BIO-1). However, implementation of mitigation measures MM-BIO-1 through MM-BIO-6 would ensure that potential impacts to special status species and their habitat are minimized and/or are reduced to below significant. Further, impacts to special status species habitat would be compensated by the implementation of habitat-based mitigation via an HMMP (see mitigation measures MM-BIO-7a and MM-BIO-7b below). Mitigation measures are outlined in detail in Section 3.3.6. With the implementation of proposed mitigation measures, impacts to special status plant and animal species would be less than significant with mitigation incorporated.

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Threshold No. 2: Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
The proposed project would result in a potentially significant impact to sensitive natural communities. The proposed project would result in direct impacts to sensitive vegetation communities on site, including vernal pools, Diegan coastal sage scrub (including baccharis dominated form), native grassland, non -native grassland , and mixed grassland. In addition, potential direct impacts could also occur if construction work inadvertently extends beyond the authorized work limits where impacts to sensitive natural communities are not anticipated. Direct impacts to sensitive vegetation communities by th e project would be considered significant and require mitigation (Impact-BIO-2). No impacts to riparian or other sensitive natural communities are expected to occur. Direct impacts to non-sensitive habitats (disturbed habitat and developed land) would also occur, but are not considered significant and, therefore, do not require mitigation. Potential indirect impacts as a result of increased human presence, noise, domestic animals, the spread of non -native species, and artificial lighting are not anticipated. Therefore, indirect impacts to sensitive natural communities as a result of the proposed project would not occur.

Sensitive natural communities on the project site that could be impacted are summarized below in Table 3.3-6.

Table 3.3-6. Impacts to Sensitive Natural Communities
Vegetation Community and Habitat Group 1 Acres 2
Off -Site
Improvements
(acres) 2
Wetland
Vernal Pool (Group A)3 0.15 —
Wetland Subtotal 0.15 —
Upland
Native Grassland – including disturbed (Group B)4 5.31 0.01 Diegan Coastal Sage Scrub – including disturbed and
Baccharis-dominated (Group C)

1.07 0.02
Mixed Grassland – disturbed (Group E)4 5.17 0.35
Non-native Grassland (Group E)4 3.35 0.22
Upland Subtotal 14.9 0.60
Total 15.05 0.60
Source: Appendix C.

Notes:
1 Groups defined by the MHCP.
2 Acres rounded to the nearest 0.01 acre.
3 Does not include road ruts or other depressions.
4 Includes road ruts and other depressions. Includes 0.03-acre temporary impact along South Pacific Street.

Mitigation for direct impacts to sensitive vegetation communities identified in Table 3.3-6 would be compensated in accordance with the mitigation ratios presented in Tables 4-6 and 4-7 of the MHCP (AMEC Earth & Environmental et al. 2003) and Section 5.2.1 of the City’s Subarea Plan (City of San Marcos 2001). In addition, the implementation of measures to protect sensitive species (MM -BIO-5 and MM -BIO-6) would ensure that sensitive natural vegetation community areas beyond the authorized limits of work are protected during construction through the installation of temporary work/impact limits fencing (orange silt fencing or similar) and biological construction monitoring to verify the

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authorized impact limits are not exceeded. Proposed mitigation measures MM-BIO-7a and MM-BIO-7b provide further specific requirements for how compensatory mitigation to sensitive natural communities would be implemented.

Implementation of the proposed project would result in significant impacts to sensitive natural communities (i.e., Diegan coastal sage scrub, native grassland, non -native grassland, mixed grassland, and vernal pools). Native habitat creation/restoration/preservation of impacted habitats would fully compensate for the loss of habitat and reduce impacts to below a level of significance. With the implementation of mitigation measures MM-BIO-5, MM-BIO-6, MM-BIO-7a and MM-BIO-7b, impacts on sensitive natural communities would be less than significant with mitigation incorporated.

Threshold No. 3: Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Implementation of the proposed project would affect federally protected wetlands and other potential jurisdictional features. This impact would be considered significant (Impact BIO-3). The proposed project would directly impact wetlands and waters under Section 404 of the CWA subject to the jurisdiction of USACE, jurisdictional waters of the State subject to jurisdiction by RWQCB under Section 401 of the CWA and/or under Porter-Cologne, and protected streambed and associated riparian habitat under the jurisdiction of CDFW per S ection 1602 of the CDFW Game Code, as shown in Table 3.3-7. Indirect impacts to potentially jurisdictional resources by the proposed project are not expected.

Table 3.3-7. Impacts to Potentially Jurisdictional Resources Potential Jurisdictional
Resources
Potential Resource Agency Jurisdiction
Acres USACE/RWQCB/CDFW USACE/ RWQCB RWQCB
Wetlands
Vernal Pools — 0.15 — 0.15
Drainage 1 (Swale) — — — —
Subtotal — 0.15 — 0.15
Non -Wetland
Drainage 2 (Streambed) <0.0001 — — <0.0001
Other Seasonally Ponded
Features
— — 0.01 0.01
Subtotal <0.0001 — 0.01 0.01
TOTAL 0.0001 0.15 0.01 0.16
Source: Appendix C.

Notes: USACE = U.S. Army Corps of Engineers; RWQCB = Regional Water Quality Control Board; CDFW = California Department of Fish and Wildlife.

As a regulatory requirement, the proposed project must notify and obtain necessary permits from the resource agencies responsible, including USACE, RWQCB, and/or CDFW, as applicable. Implementation of measures MM-BIO-8a and MM-BIO-8b would ensure that the appropriate permits are obtained and that the impact is compensated in accordance with USACE, RWQCB, and/or CDFW requirements, as applicable. Implementation of required construction BMPs, in combination with mitigation measures MM-BIO-5 and MM-BIO-6 to protect sensitive species, would ensure that construction activities are regularly monitored, are contained within the proposed work limits, and that no additional impacts (including indirect impacts) to adjacent jurisdictional resources occur.

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In conclusion, i mplementing the proposed project would result in significant impacts to protected jurisdictional resources under potential regulation by USACE, RWQCB, and or CDFW. 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 USACE, 401 Certification from the RWQCB, and a 1602 agreement from CDFW would be needed.

If the wetlands or waters on site are ruled non -jurisdictional by USACE, it is anticipated that a Waste Discharge Requirement Permit from RWQCB and a 1602 agreement from CDFW would be required. Mitigation 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 a level of less than significant with mitigation incorporated.

Threshold No. 4: Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Development on the project site would not interfere with wildlife movement or nursery functions. The project site does not support fish habitat, is entirely bounded by existing development, is not contiguous with native habitats, and is outside of areas where wildlife movement opportunities do occur (along undeveloped open space habitat corridors). Areas may be used by smaller urban-adapted mammal species and bird species, but such areas are not considered refuge as a wildlife corridor or habitat linkage.

The project site is identified by the MHCP to support a critical population of one animal species, San Diego fairy shrimp, which was found during biological studies to occur in several vernal pools located across the project site.

However, San Diego fairy shrimp is strictly found in ephemeral pools or other seasonally ponded habitats and is essentially non-mobile. Further, the project site is located in an urban and developed area that does not support wildlife movement or nursery functions. Based on the an alysis above, development on the project site would not interfere or impede with wildlife movement, corridors, or nursery sites. No impacts would occur.

Threshold No. 5: Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Section 14.12.200 of the City’s Municipal Code provides that where a permit is required for excavation, fill, or obstruction for installation or repair of utilities under any public street, sidewalk, trail, or public place , such construction should be located away from trees. As described in Chapter 2 the proposed project would likely require utility work within public streets including sewer and water improvements, storm drainage facilities, and roadway network improvements. However, as a requirement under the City’s Municipal Code to obtain an excavation permit, such construction will be located away from trees and not otherwise require the removal of trees within the public right-of-way. In the case that construction away from trees is unavoidable, the applicant will confer with the Director of Development Services, or their designee, to determine how best to avoid conflicts with mature trees and their root systems. The project would be required to demonstrate compliance with this requirement to the satisfaction of the Director to obtain an excavation permit.

Per General Plan Policy COS-2.6, healthy mature trees are to be preserved , where feasible, and where removal is necessary, trees shall be replaced at a ratio of 1:1. The project as proposed would not require the removal of any healthy mature trees. The proposed project would incorporate a conceptual landscape plan that would detail tree planting plans and would be drafted to be aligned with all relevant General Plan policies , including this tree preservation policy.

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Further, as discussed in Section 3.10, the project would be consistent with the City’s General Plan Conservation and Open Space Element. The proposed project would conserve existing biological resources and incorporate open space area into the project design plans, which would be subject to City review. Therefore, it is determined that the project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, and no impact would occur.

Threshold No. 6: Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? The project site is recognized for future incorporation in the MHCP and corresponding Draft San Marcos Subarea Plan.

Because the project site is not incorporated, the draft policies and guidelines of the Draft San Marcos Subarea Plan are currently not applicable to the proposed project. Further, the Draft San Marcos Subarea Plan has not been adopted and remains in draft form since 2001; therefore, the project would not be in conflict with an adopted habitat conservation plan. Nonetheless, the implementation of the proposed project would not preclude or prevent finalizing and adoption of the Draft San Marcos Subarea Plan because the conservation estimates/requirements exclude the project site, and its adoption is not reliant on incorporating the project site as open space or protected habitat.

The proposed project would also not conflict with the provisions of the MHCP. The project site is located within a “Major Amendment Area” by the MHCP, is targeted in the MHCP as a high priority for conservation and is identified to be a critical location to the conservation of vernal pools and other associated MHCP narrow endemic species.

Critical populations of MHCP species (including narrow endemic species) are identified occurring on the project site and within the proposed project impact footprint. According to the MHCP, even though the project site is surrounded by development and is a relatively small “postage -stamp” size, the narrow endemic species onsite would be presumed to persist with proper conservation mechanisms and management. However, the MHCP specifically excluded the project site from the MHCP conservation areas, estimates, and requirements, and assumes land acquisition and conservation planning for the project site would occur at a later date in cooperation with willing landowners, such as during approvals and development of the proposed project.

According to the MHCP Narrow Endemic Species and Critical Population Policies (MHCP Volume II Appendix D), known locations of narrow endemic species, including their critical populations, should be substantially conserved, and impacts should be avoided to the maximum extent practicable. This is generally interpreted as requiring avoidance of impacts to the degree practicable, without precluding reasonable use of a property. Avoidance and minimization measures should factor in various biological requirements, such as buffer widths and other species considerations. The MHCP also distinguishes avoidance and minimization measures for impacts to narrow endemic species located inside of Focused Planning Areas versus impacts in areas outside of Focused Planning Areas. Per Figures 2-4 and 3-1 of the MHCP, the project site is located outside of the Biological Core and Linkage Area and is a Major Amendment Area.

Narrow endemic populations identified in the MHCP as “Critical” must be either totally avoided or avoided to the maximum extent practicable without precluding economic or productive use of the property. If the project Applicant is able to demonstrate to the satisfaction of the City that species avoidance would hinder economic or productive use of a property, impacts would likely be restricted to a maximum of five percent gross cumulative loss of the critical population or occupied habitat acreage as most appropriate for the species (MHCP Volume II Appendix D).

In some rare cases, no take of individuals, populations, or habitat of high-priority critical endemic species would be allowed until a certain regional conservation threshold has been achieved in support of species recovery.

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The project site is designated as a Major Amendment Area in the MHCP and the policies therein are not required; however, such policies were considered to guide the proposed project development and conservation area on the project site. The proposed project would impact three MHCP narrow endemic species on site, including San Diego fairy shrimp, San Diego button celery, and thread-leaved brodiaea. Details on impacts to narrow endemic species, including critical populations, are provided in Section 5.2.1 of Appendix C. Although the project site is a Major Amendment Area in the MHCP and biological resources on site are excluded from the MHCP conservation estimates/requirements, the MHCP is used as a guide for species conservation on site. The proposed development was designed to minimize impacts to MHCP narrow endemic species and critical populations of such species on the project site to the extent practicable, which would be subject to review and approval by the City, USFWS, and/or CDFW, as applicable.

The proposed project would also comply with minimum standards and mitigation ratios required by the MHCP, as set forth in mitigation measures MM-BIO-1 through MM-BIO-8b. Compliance with mitigation measures MM-BIO-1 through MM-BIO-8b outlined below in Section 3.3.6 would ensure that the proposed project would reduce impacts, including impacts to Narrow Endemic Species, to less than significant. Overall, compliance with existing regulations, in addition to the implementation of mitigation measures MM-BIO-1 through MM-BIO-8b, would ensure the proposed project would not preclude or prevent finalizing and/or a doption of the City’s draft Subarea Plan under the MHCP. Therefore, impacts would be less than significant with mitigation incorporated.

3.3.6 Mitigation Measures
Mitigation measures MM-BIO-1 through MM-BIO-8b outlined below would ensure consistency with the MHCP and draft San Marcos Subarea Plan , reduce potential impacts related to special status plants and animals , would reduce potential impacts on sensitive natural communities , and would ensure that the appropriate permits are obtained and that impact s are compensated in accordance with USACE, RWQCB, and CDFW requirements. With implementation of mitigation measures MM-BIO-1 through MM-BIO-8b, impacts to biological resources as a result of project implementation would be reduced a level of less than significant.

MM-BIO-1 Rare Plant Transplant Plan. Prior to issuance of land disturbance, clearing, grubbing, or grading permits for the project site, the project Applicant shall submit a rare plant transplant plan to the City and resource agencies (USFWS and CDFW) regarding transplanting and monitoring of special- status plants: San Diego button -celery, Orcutt’s brodiaea, and thread leaved brodiaea. The transplant plan shall include, at minimum, methods for plant salvage, seed/bulb/corm collection, transplantation, relocation, performance standards, and maintenance and monitoring (5 years) to provide for no loss of these plant species and to achieve establishment success. Overall, San Diego button-celery, Orcutt’s brodiaea, and threa d-leaved brodiaea shall be translocated and/or replanted through propagation into existing suitable habitat in the on -site open space preserve near existing populations of these species and according to the conceptual mitigation plan for the project (refer to Figure 15, Conceptual Mitigation Plan, in the Biological Resources Technical Report prepared for the project). The planting of these species shall also be incorporated , as applicable, into the revegetation palettes discussed in the Vernal Pools Mitigat ion Plan (MM -BIO-2). The transplant plan shall be approved by the City and resource agencies, and will meet currently accepted standards for sensitive species translocation. Contingency measures , in case performance standards are not met after 5 years, shall be included in the plan to ensure success (i.e., no loss of these plant species) is achieved. Resource Agency verification that transplant plan success criteria has been met is required for the completion of this measure. In addition to the

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transplant plan, a cost estimate to implement the plan shall be provided to the City and resource agencies for approval and the project Applicant shall post/secure a bond in the amount of 120% of the approved cost estimate for financial assurance of the pl an prior to any clearing, grubbing, grading or other land disturbance related to the project.Prior to the issuance of land disturbance, clearing, grubbing, or grading permits for the project site, the project Applicant or Developer shall submit a rare plant transplant plan to the City and resource agencies (USFWS and CDFW) regarding transplanting and monitoring of special -status plants to be impacted by the project: San Diego button-celery, Orcutt’s brodiaea, and thread leaved brodiaea. The transplant plan shall be approved by the City and resource agencies prior to implementation and prior to issuance of clearing, grubbing, other land disturbance, or grading permits related to the project. The transplant plan shall meet currently accepted standards for sens itive plant species translocation and include, at minimum, methods for plant salvage, seed/bulb/corm collection, transplantation, relocation, performance standards, and maintenance and monitoring to achieve establishment success. San Diego button -celery, O rcutt’s brodiaea, and thread -leaved brodiaea to be impacted shall be translocated and/or replanted through propagation on-site as specified in the approved rare plant transplant plan. Resource Agencies may require the rare plant transplant plan also include off-site translocation or replanting at one of several candidate sites in the City having appropriate soils and habitat for these species. Contingency or remedial measures shall also be included in the approved transplant plan to ensure performance stand ards are achieved. Such measures may include supplemental seeding or transplantation of nursery grown plants, replacing dead plants, improving weed control, or other adaptive management techniques required by the resource agencies.

Resource agency verification that transplant plan performance standards have been met is required for the completion of this measure. In addition to the transplant plan, a cost estimate to implement the plan shall be provided to and approved by the City and resource agencies. Prior to implementation, transplantation and monitoring in accordance with the rare plant transplant plan shall be fully funded by the Applicant or Developer via an endowment or other funding mechanism, as approved by the City and pertinent permit-issuing resource agencies.

MM-BIO-2 Vernal Pools Mitigation Plan. Prior to any land disturbance, clearing, grubbing, or grading permits for the project site, the project Applicant shall submit a Vernal Pool Mitigation Plan (VPMP) to the City and resource agencies, describing the creation, re-establishment, and/or restoration, as well as maintenance and monitoring (5 years) of vernal pools in the mitigation plan. Vernal pool mitigation shall occur on-site within appropriate suitable habitat in the on-site open space preserve, according to the conceptual mitigation plan for the project. The VPMP shall include, at minimum, restoration methods, performance standards, and contingency measures if performance standards are not met. Vernal pool mitigation areas shall require agency sign -off after successful completion. If impacts to vernal pools occupied by listed San Diego fairy shrimp cannot be fully avoided, a consultation shall occur with USFWS to obtain take authorization pursuant to the federal ESA and as described in mitigation measure BIO-3. Measures required by USFWS as a result of consultation shall be implemented, which may include preparation and implementation of a resource salvage plan and translocation of cysts by inoculation into existing suitable habitat within approved preserve a reas or into created or restored habitat on-site. Suitable habitat is located within existing depressions (found not occupied) near existing vernal pools to be preserved on-site, which is located within the Vernal Pool Major Amendment Area in the City’s Dr aft Subarea Plan.

Ultimately, the VPMP shall be approved by the City and resource agencies. In addition to the VPMP, a cost estimate to implement the plan shall be provided to the City and resource agencies for

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-32
approval and the project Applicant shall post/secure a bond in the amount of 120% of the approved cost estimate for financial assurance of the plan prior to any clearing, grubbing, grading or other land disturbance related to the project.Prior to issuance of land disturbance, clearing, grubbing, or grading permits for the project site, the project Applicant or Developer shall submit a Vernal Pool Mitigation Plan (VPMP) to the City and applicable permit -issuing resource agency (i.e. USFWS, USACE, RWQCB, and/or CDFW) describing vernal pool creation, expansion, and/or restoration, as well as maintenance and monitoring of such vernal pools. The VPMP shall be approved by the City and permit -issuing resource agency prior to implementation and prior to issuance of clearing, grubbing, other land disturbance, or grading permits related to the project. The proposed distribution of the vernal pool mitigation herein shall be on-site as specified in the approved VPMP.

The VPMP shall include, at minimum, creation and resto ration methods, performance standards, maintenance and monitoring, and contingency measures if performance standards are not met.

Agency sign-off, as applicable per the regulatory permit(s) issued for the project, shall be required for verification that VPMP criteria has been met and for completion of this measure. If impacts to vernal pools occupied by listed San Diego fairy shrimp cannot be fully avoided, prior to impacts, a consultation shall be completed with USFWS to obtain take authorization pursuant to the federal ESA and as described in mitigation measure BIO -3. Measures required by USFWS as a result of consultation shall be implemented, which may include preparation and implementation of a resource salvage plan and translocation of cysts by inoculat ion into suitable habitat within approved preserve areas or into created or restored habitat. Suitable habitat is located on -site within existing depressions (found not occupied) near existing vernal pools to be preserved on-site, all of which is located w ithin the Vernal Pool Major Amendment Area in the City’s Draft Subarea Plan. In addition to the VPMP, a cost estimate to implement the plan shall be provided to and approved by the City and pertinent resource agencies. Implementation and monitoring per VPM P plan shall be fully funded by the Applicant or Developer via an endowment or other funding mechanism, as approved by the City and pertinent resource agencies.

MM-BIO-3 Listed Species Conservation Measures. Prior to issuance of any land disturbance, clearing, grubbing, or grading permits for the project site, the project Applicant or Developer shall demonstrate to the City that consultation with USFWS for adverse effects to San Diego Fairy shrimp, thread leaved brodiaea, and San Diego button celery has occurred in accordance with Section 7 or Section 10 of the federal ESA, as applicable. Impacts to San Diego button celery and thread leaved brodiaea shall also requ ire either a Section 2080.1 Consistency Determination or a Section 2081(b) Incidental Take Permit from CDFW, according to the federal action, or demonstrate to the City that none was required by CDFW. Impacts to habitat occupied by these listed species shall be compensated by the implementation of habitat -based mitigation via an HMMP and long -term conservation and management via a PMP (see mitigation measures MM-BIO-7a and MM-BIO-7b).

MM-BIO-4 Avoidance of Nesting Birds and Raptors. To prevent direct impacts to nesting birds, including raptors, protected under the federal MBTA and the CFGC, any project construction activities requiring the removal and/or trimming of vegetation suitable for nesting birds (including clearing, grubbing, trenching, grading, or any land disturbances) shall occur outside of the breeding season for general birds, including raptors (January 15 to September 15). The City may waive this condition, provided that the following additional avoidance measures are taken. If the construction activities cannot avoid the bird breeding season, a qualified biologist shall be retained to conduct a pre - construction nesting bird survey within 7 days prior to the activities to confirm the presence or

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-33
absence of active bird nests. If no active bird nests are found by the qualified biologist, then the activities shall proceed with the reassurance that no violation to the MBTA and CFGC would occur.

If an active bird nest is found by the qualified biologist, then vegetation removal and/or trimming activities at the nest location and within 300 feet for passerine birds and 500 feet for raptors shall not be allowed to occur until the qualified biologist has determined that the nest is no longer active.

Buffers may be reduced only at the discretion of the qualified biologist, depending on the bird species and construction/vegetation removal activities required in the vicinity of the active nest.

MM-BIO-5 Construction Work Limits Fencing. Prior to any the issuance of land dis turbance, clearing, grubbing, or issuance of grading permits for the project site, it the Applicant or Developer shall be demonstrated to the City that the approved grading boundaries and limits of work are presented on the Final Construction Drawings, including the limits of work fencing. To help ensure inadvertent/unauthorized impacts to environmentally sensitive areas outside of the a pproved limits of work footprint are avoided, temporary construction fencing (orange fencing or similar), including silt fencing as appropriate, shall be installed at the edges of the approved impact limits.

This fencing shall be installed prior to construction and maintained for the duration of construction activity. Fencing shall be installed in a manner that does not impact sensitive species or habitats to be avoided. Prior to installation, a qualified biologist shall survey the fencing location to inspect that the fencing alignment is consistent with the Final Construction Drawings and to verify no special-status plant species occur within the fencing installation location. If special -status plants are detected, the fencing alignment shall be adjusted to avoid those plant individuals , or such plants shall be relocated into the project preserve areas to avoid their impact as a result of fence installation. Once the fencing is installed, the City and project biologist (see MM BIO-6) shall determine the need for additional inspections and monitoring activities throughout the duration of construction. If work occurs beyond the fenced or demarcated limits of impact, work in the affected areas shall cease until the problem has been remedied and mitigation identified satisfactory to the City and qualified biologist. All temporary construction fencing shall be removed upon completion of construction.

MM-BIO-6 Biological Construction Monitoring. Prior to any clearing, grubbing, or issuance of grading permits for the project site grading, the project Applicant or Developer shall demonstrate to the City that a qualified biologist has been retained to monitor construction activities, including monitoring of the temporary work/impact limits fencing installation (see MM-BIO-5), which clearly delineates the edge of the approved work limits and the edges of environmentally sensitive areas that occur beyond the approved limits. The qualified biologist shall conduc t a preconstruction environmental training session for construction personnel to inform them of the sensitive biological resources in the local area and the avoidance measures in place to remain in compliance. The monitoring, at minimum, shall include insp ection of construction work areas, including staging and storage areas, to confirm that activities are kept within the approved limits and that Best Management Practices are in place. The biologist shall regularly monitor construction activities throughout construction. If items of non -compliance are identified, the biologist shall notify the on -site construction superintendent immediately to discuss and implement corrective actions. Issues of non -compliance that result in additional impacts to sensitive bi ological resources shall be documented and provided to the City within 72 hours of identification. Mitigation for unauthorized impacts shall adhere to the applicable measures in the Biological Resources Technical Report prepared for the project .

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-34
MM-BIO-7a Compensatory Mitigation for Impacts to Sensitive Natural Communities. The proposed project shall compensate for impacts to sensitive natural communities (i.e., Diegan coastal sage scrub, native grassland, non-native grassland, mixed grassland, and vernal pools) according to the ratios provided in Table 3.3-8 below. Mitigation shall not occur at levels below the ratios described in Table 3.3-7 unless otherwise conditioned in permits and/or discretionary approvals issued by USFWS, USACE, RWQCB, and/ or CDFW, as applicable. Impacts to sensitive natural communities (e.g., Diegan coastal sage scrub, native grassland, non -native grassland, mixed grassland, and vernal pools) as a result of project implementation shall be mitigated per the following ratios. A 3:1 mitigation ratio shall be provided for impacts to vernal pools (minimum 1:1 creation/expansion), a 2:1 ratio for impacts to native grassland (including disturbed), a 1:1 ratio for Diegan coastal sage scrub (including disturbed and Baccharis dominated), a 0.5:1 ratio for impacts to mixed grassland (including disturbed), and a 0.5:1 ratio for impacts to non -native grassland. Mitigation shall not occur at levels below these ratios unless otherwise conditioned in permits or discretionary approvals issued by the City and/or applicable permit -issuing resource agency (USFWS, USACE, RWQCB, and/or CDFW). The mitigation to sensitive natural communities shall be implemented per MM-BIO-7b.

Table 3.3-8. Mitigation for Impacts to Sensitive Natural Communities Vegetation Community and Habitat Group 1 Impacts 2
Mitigation
Ratio 3
Required
Mitigation 2
Wetland
Vernal Pool (Group A) 0.15 3:1 0.45
Wetland Subtotal 0.15 — 0.45
Upland
Native Grassland – including disturbed (Group B) 5.32 2:1 10.64 Diegan Coastal Sage Scrub – including disturbed
and Baccharis-dominated (Group C)

1.09 1:1 1.09
Mixed Grassland – disturbed (Group E) 5.52 0.5:1 2.76
Non-Native Grassland (Group E) 3.57 0.5:1 1.796
Subtotal 14.84 — 16.28
Total 14.99 — 16.73
Notes:
1 Groups defined by the MHCP.
2 Acres rounded to the nearest 0.01 acre. Includes project development on-site and off-site improvements. 3 Mitigation Ratios are consistent with those listed in Tables 4 -6 and 4-7 of the MHCP ( AMEC Earth & Environmental et al. 2003 ) and Section 5.2.1 of the City Subarea Plan (City of San Marcos 2001) for lands located outside Focused Planning Areas.

MM-BIO-7b Compensatory Mitigation for Permanent Impacts to Sensitive Natural Communities. Prior to the issuance of land disturbance, clearing, grubbing, or grading permits for the project site, the Applicant or Developer shall demonstrate to the satisfaction of the City, and applicable permit - issuing agency (i.e. USFWS, USACE, RWQCB, and/or CDFW) that compensatory mitigation for direct permanent impacts to sensitive natural communities (e.g., Diegan coastal sage scrub, native grassland, non-native grassland, mixed grassland, and vernal pools) has been adequately provided

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-35
in accordance with the ratios described in mitigation measure MM -BIO-7a and secured through one or a combination of the following mechanisms:
• Implementation of on-site and/or off-site habitat preservation, creation/expansion, restoration, and/or enhancement; or.
• Purchase of off-site conservation credits from a conservation bank in the region (such as Brook Forest Mitigation Bank, Cleveland Corridor Conservation Bank, Heights of Pala Mesa Conservation Bank, Manchester Avenue Conservation Bank, Ramona Grasslands Conservation Bank, Red Mountain Conservation Bank, or another location deemed acceptable by the City).

Prior to issuance of any land disturbance, clearing, grubbing, or issuance of grading permits for the site, compensatory mitigation areas proposed on - and/or off -site through habitat creation/expansion, enhancement, and/or restoration shall be required to prepare and implement a Habitat Mitigation Monitoring Plan (HMMP) and a Preserve Management Plan (PMP), which shall be subject to City and applicable permit -issuing resource agency (i.e., USFWS, USACE, RWQCB, and/or CDFW) review and approval prior to the issuance of any permits for the proposed project.

Because the rare plant transplant plan and vernal pool mitigation plan ( see MM-BIO-1 and MM - BIO-2 above) ultimately prescribes actions resulting in grasslands and vernal pools establishment, re-establishment, and/or restoration, such plans shall suffice as the HMMP provided the pertinent information prescribed below is incorporated.

The HMMP shall prescribe the on-/off-site mitigation actions of creation/establishment/expansion, re-establishment, restoration, enhancement, and/or preservation. The HMMP shall include the location of any creation/establishment, re -establishment, restorat ion, enhancement and/or preservation site(s); requirements for site preparation, soil amendments, temporary irrigation, native plant palettes, installation methods, maintenance, and performance monitoring, as appropriate. The HMMP shall include graceful tarplant into the native habitat planting seed palette, where appropriate. The HMMP shall also include information pertaining to any specific rare plant translocation plans (see MM -BIO-1) or vernal pool resources mitigation plans (see MM -BIO-2) as required by MM -BIO-1 and MM -BIO-2. The HMMP shall require that all mitigation (except for preservation areas not restored) be subject to monitoring with specific performance standards to ensure that the impacted functions and services are restored. All the mitigati on areas shall be subject to long-term management as outlined by the approved PMP for the project.

The PMP for the proposed project shall prescribe the on -/off-site actions of stewardship and perpetual management of the preserve areas and include at a minimum: (a) the location and description of the mitigation area(s); final plans for the mitigation are a(s); (b) the responsible entities for the mitigation area(s); (c) the management funding amount and mechanism, based on a Property Analysis Record (PAR) or similar cost estimation method approved by the City and applicable permit-issuing resource agency (i.e., USFWS, USACE, RWQCB, and/or CDFW); (d) specific habitat and monitoring management directives, including: vegetation monitoring, sensitive species monitoring, water pollution, and control and treatment of non-native invasive/exotic plant species; (e) specific success criteria (f) public awareness programs/initiatives; (g) preserve barriers, fencing management, and signage to prevent human intrusion and control illegal dumping; (h) monitoring and reporting schedules; and (i) adaptive management recommen dations for the preserve area.

Implementation of long-term management shall be provided by a qualified entity approved by the

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-36
City and applicable permit -issuing resource agency (i.e., USFWS, USACE, RWQCB, and/or CDFW) with experience in managing preserve lands.

Prior to the issuance of land disturbance, clearing, grubbing, or grading permits for the project, a protective instrument, such as a conservation easement or restrictive covenant, shall be recorded over the mitigation areas where such a protective instrument does not already exist (including all on-/off-site conservation areas), and in -perpetuity management shall be provided by a qualified manager in accordance with the PMP, which would be funded by an endowment or other acceptable funding mechanism.

The draft HMMP and PMP, including the endowment estimate and documentation, shall be provided to the City and applicable permit -issuing resource agency (i.e., USFWS, USACE, RWQCB, and/or CDFW) at least 60- days prior to project impacts. The HMMP and PMP shall be approved by the City and applicable permit -issuing resource agency (i.e., USFWS, USACE, RWQCB, and/or CDFW) prior to the issuance of land disturbance, clearing, grubbing, or grading permits for the project. for Implementation of the HMMP and PMP sh all be fully funded by the Applicant or Developer via an endowment or other funding mechanism, as approved by the City and pertinent permit-issuing resource agency prior to any land disturbance for the project.

Prior to issuance of and land disturbance, clearing, grubbing, or grading permits for the proposed project, the Applicant shall demonstrate to the City that compensatory mitigation for direct permanent impacts to sensitive natural communities (i.e., Diegan coastal sage scrub, native grassland, non -native grassland, mixed grassland, and vernal pools) has been adequately proposed in accordance with the ratios described in mitigation measure MM-BIO-7a and secured through one or a combination of the following mechanisms:

Implementation of on-site and/or off -site habitat preservation, creation, restoration, and/ or enhancement
Purchase of off -site conservation credits from a conservation bank in the region (such as Brook Forest Mitigation Bank, Cleveland Corridor Conservation Bank, Heights of Pala Mesa Conservation Bank, Manchester Avenue Conservation Bank, Ramona Grasslands Conservation Bank, Red Mountain Conservation Bank, or another location deemed acceptable by the City).

Compensatory mitigation proposed on - and/or off -site through habitat establishment, re - establishment, and/or restoration areas shall be required to prepare and implement a Habitat Mitigation Monitoring Plan (HMMP) and a Preserve Management Plan (PMP), which shall be subject to City review and approval prior to issuance of any permits for the proposed project. Because the rare plant transplant plan and vernal pools mitigation plan (see Bio-1 and Bio-2 above) ultimately prescribes acti ons resulting in grassl ands and vernal pools establishment, re -establishment, and/or restoration, such plans shall suffice as the HMMP provided the pertinent information prescribed below is incorporated.

The HMMP shall prescribe the on -/off-site mitigation actions of creation/establishment, re - establishment, restoration, and/or preservation. The HMMP shall include discussion on the location of any creation/establishment, re-establishment, restoration, and/or preservation site(s); requirements for site preparation, soil amendments, temporary irrigation, native plant palettes,

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-37
installation methods, maintenance, and performance monitoring, as appropriate. The HMMP shall include graceful tarplant into the native habitat planting seed palette, where appropriate. The HMMP shall also include information pertaining to any specific rare plant translocation plans (see MM-BIO-1) or vernal pool resources mitigation plans (see MM-BIO-2) as applicable. The HMMP shall require that all mitigation (except for preservation areas not restored) be subject to a minimum 5-year performance monitoring period with specific success criteria to ensure that the impacted functions and services are restored. A protective instrument, such as a conservation easement or restrictive covenant, shall be recorded over the mitigation areas where such a protective instrument does not already exist. All the mitigation areas shall be subject to long -term management as outlined by the PMP prepared for the proposed project.

The PMP for the proposed project site shall prescribe the on-/off-site actions of stewardship and perpetual management of the preserve areas and include at minimum: (a) the location and description of the mitigation area; final plans for the mitigation area; (b) the responsible entities for the mitigation area; (c) the management funding amount and mec hanism, based on a Property Analysis Record (PAR) or similar cost estimation method; (d) specific habitat and monitoring management directives such as: vegetation monitoring, sensitive species monitoring, control and treatment of non -native invasive/exotic plant species; (e) specific success criteria (f) public awareness; (g) preserve barriers or fencing management; (h) monitoring and reporting schedules; and (i) adaptive management recommendations for the preserve area. Implementation of long - term management shall be provided by a qualified entity approved by the City with experience in managing preserve lands (i.e., CDFW list of qualified entities).

Because the project proposes impacts and mitigation that involve resources regulated by USFWS, USACE, RWQCB, and/or CDFW, the City shall also coordinate concurrence approval of the HMMP and PMP by these agencies, as appropriate.

MM-BIO-8a Regulatory Permitting. Prior to impacts to potentially jurisdictional resources, the Applicant shall provide the City copies of all applicable regulatory permits issued by USACE, RWQCB, and/or CDFW.

Prior to issuance of land disturbance, clearing, grubbing, or grading permits for the project, the Applicant or Developer shall provide the City copies of all applicable regulatory permits required by the USACE, RWQCB, and/or CDFW for project impacts to jurisdictional aquatic resources.

MM-BIO-8b Compensatory Mitigation for Impacts to Jurisdictional Resources. Impacts to jurisdictional aquatic resources under the regulation of USACE, RWQCB, and/or CDFW that result from the proposed project shall be mitigated at a 3:1 ratio consisting of a minimum 1:1 creation/ expansion/establishment/re-establishment, subject to regulatory permitting requirements of USACE, RWQCB, and /or CDFW, as applicable (MM-BIO-8a). Mitigation shall be provided through one or a combination of the following mechanisms below:
▪ Purchase of preservation, creation/establishment, re-establishment, rehabilitation, and/or enhancement credits from a mitigation bank (such as the Brook Forest Mitigation Bank, Ramona Grasslands Conservation Bank, San Luis Rey Mitigation Bank, or another bank) approved by USACE, RWQCB, and CDFW as applicable.
▪ Implementation of permittee -responsible preservation, creation/expansion/establishment, re-establishment, restoration, rehabilitation and/or enhancement at an on - and/or off -site

3.3 - BIOLOGICAL RESOURCES
FINAL EIR FOR CITY OF SAN MARCOS PACIFIC SPECIFIC PLAN PROJECT 13170 MAY 2024 3.3-38
location approved by the applicable permit -issuing resource agency (i.e., USACE, RWQCB, and/or CDFW) as applicable. Permittee-responsible mitigation proposed on - and/or off -site shall be required to prepare and implement a Habitat Mitigation Monitoring Plan (HMMP) and a Preserve Management Plan (PMP) (see MM-BIO-7b), which shall be subject to the applicable permit-issuing resource agency (i.e., USACE, RWQCB, and/or CDFW) review and approval prior to implementation. The HMMP shall prescribe the on-/off-site mitigation actions proposed, and the PMP shall provide the parameters for stewardship and perpetual management.

3.3.7 Conclusion
As described throughout Section 3.3.5, Project Impact Analysis, implementation of the proposed project would result in potential ly significant impacts to biological resources (Impact BIO-1, Impact BIO-2, and Impact BIO-3).

However, compliance with existing regulations and implementation of proposed mitigation measures MM-BIO-1 through MM-BIO-8b outlined in Section 3.3.6 above, would ensure that the proposed project would not conflict with the MHCP or draft San Marcos Subarea Plan, or other applicable regulations related to biological resources.

Implementation of proposed mitigation, and City review of proposed project plans for the site would ensure impacts to biological resources would be reduced to a level of less than significant.

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3.4 - CULTURAL RESOURCES
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3.4 Cultural Resources
This section describes the existing 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. Potential impacts to Tribal Cultural Resources are analyzed in Section 3.16 of this environmental impact report (EIR).

The analysis in this section relies on the Cultural Resource Inventory Report for the Pacific Project (Cultural Resources Report) prepared by Dudek in December, 2022. The cultural resources report included a record search, literature review, correspondence with Native American contacts, and a field survey. 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 (City) General Plan. The Cultural Resources Report is included as Appendix D to this EIR.

Table 3.4-1 summarizes the project- and cumulative-level cultural resources impacts, by threshold.

Table 3.4-1. Cultural Resources Summary of Impacts
Threshold of Significance
Project -Level
Impact
Cumulative -Level
Impact
Significance
Determination
#1 – Cause a substantial adverse change in the
significance of a historical resource pursuant to
Section 15064.5.

No Impact No Impact No Impact
#2 – Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to Section 15064.5.

Potentially
Significant
Less than
Significant
Less Than
Significant with
MM-TCR-1 through
MM-TCR-4
#3 – Disturb any human remains, including those
interred outside of dedicated cemeteries.

Potentially
Significant
Less than
Significant
Less Than
Significant with
MM-TCR-1 through
MM-TCR-4

3.4.1 Existing Conditions
This section provides information on the cultural setting of the project site, as well as information on the research methodology used to prepare the Cultural Resources Report for the proposed project. Additional detail can be found in Appendix D of this EIR.

The project area of potential effect ( APE), as analyzed in the Cultural Resources Report, includes the entire

33.2-acre project site , which is located in the City of San Marcos, County of San Diego , and is comprised of Assessor’s Parcel Numbers 219-222-01, 219-222-02, 219-222-03, and 219-222-04. The project APE is located at the northwest corner of South Las Posas Road and Linda Vista Drive and is surrounded by light industrial uses. The property is mapped on Section 16 of Township 12 South, Range 3 West on the United States Geological Survey 7.5’ San Marcos Quadrangle.

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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 for a 1-mile radius around the project APE 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.

Archival Research
In addition to the SCIC records search, Dudek conducted an online review of historic aerial photographs of the project APE and general vicinity, to help determine the possible development and land use of the project APE in the past. The historic aerial photographs available from the website HistoricAerials.com by Nationwide Environmental Title Research, LLC, demonstrates that development of the area surrounding the project APE started after 1967 (Appendix D). By 1978, dirt roads traverse the project APE. The 1982 aerial photograph shows some clearing and leveling in the northeast corner of the project APE. The 1989 aerial photograph shows that the eastern border of the project APE was leveled and cleared. The review of the historic aerial images demonstrates that, besides unofficial dirt roads and some limited clearing, there has been no development of the project APE.

Native American Heritage Commission and Native American Outreach Letters Dudek requested a Native American Heritage Commission ( NAHC) search of the Sacred Lands File ( SLF) on March 12, 2021, for the project APE and a 1-mile buffer. The SLF consists of a database of known Native American resources. These resources may not be included in Southern California Indian Center database. The NAHC replied on March 24, 2021, and reported that the SLF 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 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

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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.

In compliance with Assembly (AB) Bill 52 and Senate Bill (SB) 18, the City, as lead agency, is responsible for conducting government to government consultation with pertinent tribal entities. At the time of circulation for public review of this EIR , consultation is ongoing. This EIR will be revised to include information obtained through consultation as it becomes available.

Intensive Pedestrian Survey
Dudek archaeologist David Faith conducted a pedestrian survey of the project APE on March 23, 2021. The project APE was undeveloped but surrounded by numerous industrial buildings. Portions of the project APE have been previously disturbed, as evidenced by the presence of several dirt roads with deep ruts and numerous well -worn foot paths. There are also several dirt mound disturbances in the northern section of the project APE, adjacent to La Mirada Drive. There are many small, undulating knolls throughout the project APE but the terrain largely slopes downhill to the southeast. There is a pocket of dense vegetation in the northeastern corner of the project APE, with numerous bushes greater than 6 feet high and thick coastal scrub. The survey transects thro ugh the thickest vegetation were conducted in a non-linear manner. There is also a seasonal north-south trending drainage ditch in the southern portion of the project APE, adjacent South Las Posas Road. Outside of the thick vegetation and drainage, ground visibility throughout the project APE is optimal. Modern debris from illegal dumping is visible throughout the project APE with the bulk of the debris located closer to the surrounding roads. The pedestrian survey was conducted utilizing formal transects at 15-meter intervals, except as mentioned above. Deviations from transects also occurred to inspect exposed sediments and animal burrows throughout the project APE. The pedestrian survey did not identify any cultural resources within the project APE.

3.4.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to cultural resources, including federal, state, and local guidelines.

Federal
National Historic Preservation Act
The National Historic Preservation Act established the National Register of Historic Places (NRHP) program under the Secretary of the Interior. The National Historic Preservation Act authorized funding for state programs with provision for pass-through funding and participation by local governments, created an Advisory Council on Historic Preservation, and established the Section 106 review process for protecting historic resources. Th e goal of the Section 106 review process is to offer protection to sites that are determined eligible for listing in the NRHP. The National Historic Preservation Act provides the legal framework for most state and local preservation laws.

Traditional Cultural Properties (Native American Heritage Values) Federal and state laws mandate that consideration be given to the concerns of contemporary Native Americans with regard to potentially ancestral human remains, associated funerary objects, and items of cultural patrimony.

Consequently, an important element in assessing the significance of the study site has been to evaluate the likelihood that these classes of items are present in areas that would be affected by the proposed project. Also,

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potentially relevant to prehistoric archaeological sites is the category termed Traditional Cultural Properties in discussions of cultural resource management performed under federal auspices. According to Patricia L. Parker and Thomas F. King (1998), “Traditional” in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. The traditional cultural significance of a historic property, then, is significance derived from the role the property plays in a community’s historically rooted beliefs, customs, and practices.

State
California Register of Historic Resources (Public Resources Code Section 5020 et seq.) In California, the term “historical resource” includes, but is not limited to, “any object, building, structure, site, area, place, record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (California Public Resources Code [PRC] Section 5020.1[j]). In 1992, the California legislature established the California Register of His toric Resources (CRHR) “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change” (PRC Section 5024.1[a]). A resource is eligible for listing in the CRHR if the State Historical Resources Commission determines that it is a significant resource and that it meets any of the following NRHP criteria (PRC Section 5024.1[c]):

Associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.

Associated with the lives of persons important in our past.

Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values.

Has yielded, or may be likely to yield, information important in prehistory or history.

Resources less than 50 years old are not considered for listing in the CRHR unless it can be demonstrated that sufficient time has passed to understand the historical importance of the resource (14 CCR, Section 4852[d][2]).

The CRHR protects cultural resources by requiring evaluations of the significance of prehistoric and historic resources. The criteria for the CRHR are nearly identical to those for the NRHP, and properties listed or formally designated as eligible for listing on the NRHP are automatically listed on the CRHR, as are the state landmarks and points of interest. The CRHR also includes properties designated under local ordinances or identified through local historical resource surveys. The State Historic Preservation Officer maintains the CRHR.

California Points of Historic Interest
California Points of Historical Interest are buildings, structures, site or features of local (city and county) significance and have anthropological, cultural, military, political, architectural, economic, scientific/technical, religious, experimental, or other value. Points of Historical Interest designated after December 1997 are recommended by the State Historical Resources Commission are also listed in the CRHR. The criteria for designation of Points of Historical Interest are the same as those that govern the California Historic Landmarks program.

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Native American Historic Cultural Sites ( PRC 5097 et seq.) State law addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are 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 makes it a misdemeanor punishable by up to 1 year in jail to d eface or destroy Native American historic or cultural site that is listed or may be eligible for listing in the CRHR.

California Environmental Quality Act
Under CEQA, a project may have a significant effect on the environment if it may cause “a substantial adverse change in the significance of an historical resource” (PRC Section 21084.1; CEQA Guidelines Section 15064.5[b]).

If a site is either listed or eligible for listing in the CRHR, or if it is included in a local register of historic resource s, or identified as significant in a historical resources survey (meeting the requirements of PRC Section 5024.1[q]), it is a “historical resource” and is presumed to be historically or culturally significant for purposes of CEQA ( PRC Section 21084.1; CEQA Guidelines Section 15064.5[a]). The lead agency is not precluded from determining that a resource is a historical resource even if it does not fall within this presumption ( PRC Section 21084.1; CEQA Guidelines Section 15064.5[a]).

A “substantial adverse change in the significance of an historical resource” reflecting a significant effect under CEQA means “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (CEQA Guidelines Section 15064.5[b][1]; PRC Section 5020.1[q]).

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. 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 shall occur until the County coroner has examined the remains (Section 7050.5b). If the coroner determines or has reason to believe the remains are those of a Native American, the coroner must contact the NAHC within 24 hours ( Section 7050.5c). The NAHC will notify the Most Likely Descendant. 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 Likely Descen dant 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.

Health and Safety Code Section 8010 -8011
This code is intended to provide consistent state policy to ensure that all California Indian human remains and cultural material are treated with dignity and respect. The code extends policy coverage to non-federally recognized tribes and federally recognized groups.

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AB 2461
The section provides procedures for private landowners to follow upon discovering Native American human remains. Landowners are encouraged to consider culturally appropriate measures if they discover Native American human remains as set forth in PRC 5097.98.

SB 18
SB 18, approved in 2004, amends the California Civil Code and the California Government Code, requiring cities and counties to contact and consult with California Native American tribes prior to adopting or amending any general plan or specific plan, or designating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within the city’s or county’s jurisdiction. SB 18 also requires cities and counties to hold in strict confidenc e any information about the specific identity, location, character or use of these resources. In 2005, the Governor’s Office of Planning and Research published Tribal Consultation Guidelines to guide cities and counties on the process of engaging in consultation in accordance with SB 18. The NAHC maintains a list of California Native American Tribes with whom cities and counties must consult pursuant to SB 18.

AB 52
AB 52 was approved in 2014 and adds new requirements regarding consultation with California Native American Tribes and consideration of tribal cultural resources. The law went into effect on July 1, 2015, and after that date, if requested by a California Native American Tribe, lead agencies must consult prior to the release of a Negative Declaration, Mitigated Negative Declaration or Draft EIR. City of San Marcos consultation efforts in accordance with SB 18 and AB 52 are discussed in the Section 3.16, Tribal Cultural Resources, of this EIR 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 SB 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.

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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 reconstruction off-site, and/or photo-preservation.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10 of this EIR.

As detailed in Section 3.10.4, the project is consistent with the applicable General Plan goals and policies pertaining to cultural resources.

3.4.3 Thresholds of Significance
The determination of significance for cultural resources is based on CEQA Guidelines Appendix G . Impacts to cultural resources would be significant if the proposed project would:

Threshold No. 1: Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5;
Threshold No. 2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5;
Threshold No. 3: Disturb any human remains, including those interred outside of dedicated cemeteries.

3.4.4 Project Impact Analysis
Impacts to 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 historical resource pursuant to CEQA Guidelines Section 15064.5?
Section 15064.5 of the CEQA Guidelines defines a historical resource as one that meets one or more of the following criteria:

Is listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the CRHR; or
Is included in a local register of historical resources or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code; or Is determined to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California.

As identified in Section 3.4.1, no historic resources exist at the project site , in the off-site improvement areas, or immediate surroundings. Therefore, it is determined that, no impact related to historical resources would occur as a result of project implementation.

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Threshold No. 2: Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5?
As identified in Section 3.4.1, no cultural resources were found at the project site during the field survey or the SCIC records search. As described in the Cultural Resources Report (Appendix D), the NAHC SLF Search and intensive pedestrian survey, suggest that no known cultural resources would be impacted by the proposed project. However, construction activities associated with the project could result in potentially significant impacts to undocumented archaeological resources. In the unlikely event that archaeological resources are identified during earth moving activities associated with the project, mitigation is proposed that would require work be temporarily halted in the vicinity of the discovery (MM-TCR-1 through MM-TCR-3). The project developer would then be required to notify a qualified archaeologist , who would review the unanticipated find and evaluate the resource for CRHR listing.

Accordingly, although unlikely, ground -disturbing activities on the project site associated with the project could result in a potentially significant impact (Impact CR-1), and mitigation would be required (see Section 3.4.5).

As described above, t o date, two responses have been received from the Native American outreach . 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 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.

Consultation between the City and tribes is ongoing.

Threshold No. 3: Would the project disturb any human remains, including those interred outside of dedicated cemeteries? The cultural resources field survey conducted for the proposed project did not identify any human remains or find any indications that they would be expected to be found on the project site. However, although unlikely, there is the possibility of human remains being discovered during ground disturbing activities on the project site. If remains are discovered during project construction activities, mitigation is proposed that would require work in the vicinity of the discovery be halted and procedures set forth in the PRC (Section 5097.98) and State Health and Safety Code (Section 7050.5) be followed (MM-TCR-1 through MM -TCR-4). Therefore, potential discovery of undocumented human remains on the project site could result in a potentially significant impact (Impact CR-2), and mitigation would be required (see Section 3.4.5 below).

3.4.5 Mitigation Measures
Implementation of mitigation measures MM-TCR-1 through MM-TCR-3 would mitigate potentially significant impacts to unknown archaeological resources (Impact CR-1) identified above in response to Threshold #2. Implementation of mitigation measures MM -TCR-1 through MM -TCR-4 would mitigate potentially significant impacts to human remains (Impact CR-2) identified above in response to Threshold #3.

MM-TCR-1 Pre-Excavation Agreement: Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall enter into a Tribal Cultural Resources Treatment and Repatriation Agreement (Pre -Excavation Agreement) with a Traditionally and Culturally Affiliated Native American Tribe (TCA Tribe), identified in consultation with the City. The purpose of the Pre - Excavation Agreement shall be to formalize protocols and procedures between the

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Applicant/Owner and the TCA Tribe for the protection, treatment, and repatriation of Native American human remains, funerary objects, cultural and/or religious landscapes, ceremonial items, traditional gathering areas, and other tribal cultural resources. Such resources may be located within and/or discovered during ground disturbing and/or construction activities for the proposed project, including any additional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities. Any project -specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the TCA Tribe requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation.

The landowner shall relinquish ownership of all non-burial related tribal cultural resources collected during construction monitoring and from any previous archaeological studies or excavations on the project site to the TCA Tribe for proper treatment and disposition per the Pre-Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The requirement and timing of such release of ownership, and the recipient thereof, shall be reflected in the Pre -Excavation Agreement. If the TCA Tribe does not accept the return of the cultural resources, then the cultural resources will be subject to curation.

MM-TCR-2 Construction Monitoring: Prior to the issuance of a Grading Permit or ground disturbing activities, the Applicant/Owner or Grading Contractor shall provide written documentation (either as signed letters, contracts, or emails) to the City ’s Planning Division stating that a Qualified Archaeologist and Traditionally and Culturally Affiliated Native American monitor (TCA Native American monitor) have been retained at the Applicant/Owner or Grading Contractor ’s expense to implement the construction monitoring program, as described in the Pre-Excavation Agreement.

The Qualified Archaeologist and TCA Native American monitor shall be invited to attend all applicable pre -construction meetings with the General Contractor and/or associated subcontractors to present the construction monitoring program. The Qualified Archa eologist and TCA Native American monitor shall be present on site during grubbing, grading, trenching, and/or other ground-disturbing activities that occur in areas of native soil or other permeable natural surfaces that have the potential to unearth any evidence of potential archaeological resources or tribal cultural resources. In areas of artificial paving, the Qualified Archaeologist and TCA Native American monitor shall be present on site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb more than six inches below the original pre- project ground surface to identify any evidence of potential archaeological or tribal cultural resources. No monitoring of fill material, existing or imported, wi ll be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) ar e from private or other non -commercial sources that have been determined to be absent of tribal cultural resources by the Qualified Archaeologist and TCA Native American monitor.

The Qualified Archaeologist and TCA Native American monitor shall maintain ongoing collaborative coordination with one another during all ground disturbing activities. The requirement for the construction monitoring program shall be noted on all applicable construction documents, including demolition plans, grading plans, etc. The Applicant/Owner or Grading Contractor shall provide written

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notice to the Planning Division and the TCA Tribe, preferably through e-mail, of the start and end of all ground disturbing activities.

Prior to the release of any grading bonds, or prior to the issuance of any project Certificate of Occupancy, an archaeological monitoring report, which describes the results, analysis, and conclusions of the construction monitoring shall be submitted by the Qualified Archaeologist, along with any TCA Native American monitor’s notes and comments received by the Qualified Archaeologist, to the Planning Division Manager for approval. Once approved, a final copy of the archaeological monitoring report shall be retained in a confidential City project file and may be released, as a formal condition of Assembly Bill (AB) 52 consultation, to Rincon Band of Luiseño Indians, San Pasqual Band of Mission Indians, or any parties involved in the project specific monitoring or consultation process.

A final copy of the report, with all confidential site records and appendices, will also be submitted to the South Coastal Information Center after approval by the City.

MM-TCR-3 Unanticipated Discovery Procedures: Both the Qualified Archaeologist and the TCA Native American monitor may temporarily halt or divert ground disturbing activities if potential archaeological resources or tribal cultural resources are discovered during construction activities.

Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource ’s potential significance.

Isolates and clearly non -significant archaeological resources (as determined by the Qualified Archaeologist, in consultation with the TCA Native American monitor) will be minimally documented in the field. All unearthed archaeological resources or tribal cultural resources will be collecte d, temporarily stored in a secure location (or as otherwise agreed upon by the Qualified Archaeologist and the TCA Tribe), and repatriated according to the terms of the Pre-Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

If a determination is made that the archaeological resources or tribal cultural resources are considered potentially significant by the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor, then the City and the TCA Tribe shall determine, in consultation with the Applicant/Owner and the Qualified Archaeologist, the culturally appropriate treatment of those resources.

If the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor cannot agree on the significance or mitigation for such resources, these issues will be presented to the Planning Division Manager for decision. The Planning Division Manage r shall make a determination based upon the provisions of CEQA and California Public Resources Code Section 21083.2(b) with respect to archaeological resources and California Public Resources Section 21704 and 21084.3 with respect to tribal cultural resources, and shall take into account the religious beliefs, cultural beliefs, customs, and practices of the TCA Tribe.

All sacred sites, significant tribal cultural resources, and/or unique archaeological resources encountered within the project area shall be avoided and preserved as the preferred mitigation. If avoidance of the resource is determined to be infeasible by the City as the Lead Agency, then the City shall require additional culturally appropriate mitigation to address the negative impact to the resource, such as, but not limited to, the funding of an ethnographic study and/or a data recovery plan, as determined by the City in consultation with the Qualified Archaeologist and the TCA Tribe.

The TCA Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation and the drafting and finalization of any ethnographic study and/or

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data recovery plan, and/or other culturally appropriate mitigation. Any archaeological isolates or other cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site (or as otherwise agreed upon by the Qualified Archaeologist and TCA Tribe), and repatriated according to the terms of the Pre -Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The removal of any artifacts from the project site will be inventoried with oversight by the TCA Native American monitor.

If a data recovery plan is authorized as indicated above and the TCA Tribe does not object, then an adequate artifact sample to address research avenues previously identified for sites in the area will be collected using professional archaeological collect ion methods. If the Qualified Archaeologist collects such resources, the TCA Native American monitor must be present during any testing or cataloging of those resources. Moreover, if the Qualified Archaeologist does not collect the cultural resources that are unearthed during the ground disturbing activities, the TCA Native American monitor may, at their discretion, collect said resources for later reburial or storage at a local curation facility, as described in the Pre-Excavation Agreement.

In the event that curation of archaeological resources or tribal cultural resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by Califo rnia State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project construction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the TCA Tribe or the curation facility, whichever is most applicable, that the repatriation and/or curation have been completed.

MM-TCR-4 Human Remains: As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to o verlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.

If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two working days of being notified if the remains are subject to his or her authority.

If the Medical Examiner recognizes the remains to be Native American, and not under his or her jurisdiction, then he or she shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

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If suspected Native American remains are discovered, the remains shall be kept in situ (in place) until after the Medical Examiner makes its determination and notifications, and until after the Most Likely Descendent is identified, at which time the archaeological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public. According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a location free from future disturbance (see Public Resources Code Section 5097.98[e] and 5097.94[k]).

3.4.6 Conclusion
Implementation of the proposed project would not impact any identified archaeological resources, historical resources, or any known human remains interred outside a formal cemetery. However, based upon the analysis presented in Section 3.4.4, the potential exists for impacts to unknown cultura l resources resulting from implementation of the proposed project.

These potentially significant impacts to archaeological resources and human remains would be mitigated to below a level of significance through implementation of mitigation measures MM-TCR-1 through MM-TCR-4. Specifically, implementation of mitigation measures MM-TCR-1 through MM-TCR-3 provide for the presence of archaeological and Native American monitors during ground disturbing activities that would be able to identify any previously unidentified cultural resources and to prevent inadvertent disturbance of any intact cultural deposits that may be present. Should any resources be identified, implementation of mitigation measure MM-TCR-4 would ensure proper handling and treatment of such resources by providing for a proper evaluation to deter mine whether additional archaeological work is necessary.

Potential impacts to human remains would be mitigated through implementation of mitigation measures MM-TCR-1 through MM-TCR-4, which include the requirement that any remains uncovered during ground disturbing activities shall not be further disturbed until the San Diego County Coroner has determined origins of the remains and final treatment has been agreed to with input of Native American Tribes as necessary. With incorporation of these mitigation measures, potential impacts to cultural resources associated with the proposed project would be reduced to a level of less than significant.

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3.5 Energy
This section describes the existing setting of the project site with respect to energy use and conservation, identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the proposed Pacific Specific Plan Project (proposed project).

Appendix G and Appendix F of the California Environmental Quality Act Guidelines require that an environmental impact report (EIR) discuss the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy , to ensure that energy implications are considered in project-related decision-making processes. As such, this section analyzes the energy impacts of the proposed project. Specifically, this section summarizes th e existing conditions in the project area, discusses the regulatory framework, and discloses estimated energy use during the construction and operational phases of the proposed project. This analysis considers the electricity, natural gas, and transportation fuel (petroleum) demand of the proposed project.

Information in this section is based on the proposed project’s Air Quality and Greenhouse Gas (GHG) Emissions Technical Report (February 2023), prepared by Dudek, which is included as Appendix B of this EIR.

Table 3.5-1 summarizes the project- and cumulative-level energy impacts, by threshold.

Table 3.5-1. Energy Summary of Impacts
Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1 – Result in potentially significant
environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2 – Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Less than
Significant
Less than
Significant
Less than
Significant

3.5.1 Existing Conditions
The environmental setting for the proposed project related to electricity, natural gas, and petroleum, including associated service providers, supply sources, and estimated consumption, is discussed below. In summary, in 2019 (the latest calendar year for which data is uniformly available for all three types of energy sources), California’s estimated annual energy use included the following:
▪ Approximately 250,379 gigawatt -hours of electricity (EIA 2020a) ▪ Approximately 21.5 billion therms of natural gas (EIA 2021) ▪ Approximately 28.7 billion gallons of petroleum (EIA 2020b) Electricity
According to the U.S. Energy Information Administration, California used approximately 250,379 gigawatt-hours of electricity in 2019 (EIA 2020a). Electricity usage in California for different land uses varies substantially by the types of uses in a building, type of construction materials used in a building, and the efficiency of all electricity-consuming

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devices within a building. By sector in 2017, commercial uses utilized 46% of the state’s electricity, followed by 35% for residential uses, and 19% for industrial uses (EIA 2019). Due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s electricity use per capita in the residential sector is lower than any other state except Hawaii (EIA 2020b).

San Diego Gas & Electric (SDG&E) provides electric services to 3.6 million customers through 1.4 million electric meters located in a 4,100-square-mile service area that includes San Diego County (County) and southern Orange County (SDG&E 2022). SDG&E is a subsidiary of Sempra Energy and would provide electricity to the proposed project. According to the California Public Utilities Commission (CPUC), SDG&E customers consumed approximately 19,169 million kilowatt-hours (kWh) of electricity in 2015 (CPUC 2016).

SDG&E receives electric power from a variety of sources. According to the California Energy Commission ( CEC) Biennial Renewable Portfolio Standard Program Update, about 40 % of SDG&E’s power came from eligible renewable energy sources in 2020, including biomass/waste, geothermal, small hydroelectric, solar, and wind sources (CPUC 2022).

Based on recent energy supply and demand projections in California, statewide annual peak electricity demand is projected to grow an average of 3,333 gigawatt-hours per year through 2030, or 1. 2% annually. In San Diego County, the CEC reported an annual electrical consumption of approximately 19.0 billion kWh in 2019, with

12.4 billion kWh for non-residential use and 6.7 billion kWh for residential use (CEC 2018).

Natural Gas
CPUC regulates natural gas utility service for approximately 10.8 million customers who receive natural gas from Pacific Gas & Electric, Southern California Gas (SoCalGas), SDG&E, Southwest Gas, and several smaller natural gas utilities. CPUC also regulate s independent storage operators Lodi Gas Storage, Wild Goose Storage, Central Valley Storage, and Gill Ranch Storage (CPUC 2022). SDG&E provides natural gas service to the counties of San Diego and Orange and would provide natural gas to the proposed proje ct. SDG&E is a wholesale customer of SoCalGas and currently receives all of its natural gas from the SoCalGas system (CPUC 2022).

CPUC regulates California natural gas rates and natural gas services, including in -state transportation over transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used in California comes from out-of-state natural gas basins. California gas utilities may soon also begin receiving biogas into their pipeline systems (CPUC 2022).

In 2017, California customers received 38% of their natural gas supply from basins located in the Southwest, 27% from Canada, 27% from the Rocky Mountains, and 8% from basins located within California (CPUC 2022). Natural gas from out -of-state production basins is delivered into California through the interstate natural gas pipeline system. The major interstate pipelines that deliver out -of-state natural gas to California are the Gas Transmission Northwest Pipeline, Kern River Pipeline, Transwestern Pipelin e, El Paso Pipeline, Ruby Pipeline, Southern Trails, and Mojave Pipeline. The North Baja–Baja Norte Pipeline takes gas off the El Paso Pipeline at the California/Arizona border and delivers it through California into Mexico. The Federal Energy Regulatory C ommission regulates the transportation of natural gas on interstate pipelines, and CPUC often participates in Federal Energy Regulatory Commission regulatory proceedings to represent the interests of California natural gas consumers (CPUC 2022).

Most of the natural gas transported through interstate pipelines, as well as some California-produced natural gas, is delivered through the Pacific Gas & Electric and SoCalGas intrastate natural gas transmission pipeline systems

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(commonly referred to as California’s “backbone” natural gas pipeline system). Natural gas on the backbone pipeline system typically is then delivered into local transmission and distribution pipeline systems or to natural gas storage fields. CPUC has regulatory jurisdiction over 100,000 miles of utility ‐owned natural gas pipelines, which transported 82% of the natural gas delivered to California’s gas consumers in 2017 (CPUC 2022).

Petroleum
According to the U.S. Energy Information Administration , California used approximately 681 million barrels of petroleum in 2018, with the majority (584 million barrels) used for the transportation sector (EIA 2020b). This total annual consumption equates to a daily use of approximately 1.9 million barrels of petroleum. There are 42 U.S. gallons in a barrel, so California consumes approximately 78.4 million gallons of petroleum per day, adding up to an annual consumption of 28.7 billion gallons of petroleum. By sector, transportation sources utilize approximately

85.5% of the state’s petroleum, followed by 11.1% from industrial, 2.5% from commercial, 0.9% from residential, and 0.01% from electric power uses (EIA 2018a). Petroleum usage in California includes petroleum products such as motor gasoline, distillate fuel, liquefied petroleum gases, and jet fuel. California has implemented policies to improve vehicle efficiency and to support use of alternative transportatio n, which are described in Section 3. 5.2, below. As such, the CEC anticipates an overall decrease of gasoline demand in the state over the next decade.

Existing Infrastructure
As discussed in Section 2.2.2, Project Characteristics, electricity and natural gas to the project site would be provided by SDG&E. Electrical facilities throughout the City of San Marcos (City) include a combination of above - ground and below -ground electrical distribution lines and utilities structures. 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.

There are existing electrical lines and natural gas pipeline adjacent to the project site within Meyers Avenue .

Additionally, there is an existing overhead pole line on La Mirada Drive between South Pacific Street and South Las Posas Road. Existing along La Mirada Drive are seven SDG&E utility poles and four AT&T poles. In addition, Cox Communications is attached to five of the SDG&E poles with their cables.

For the existing SDG&E poles, there are approximately 1,500 feet of 636 aluminum cables between South Pacific Street and South Las Posas Road. On the existing joint AT&T and SDG&E poles, there are approximately 1,500 feet of overhead cables between Pacific Street and South Las Posas Road. On the existing joint SDG&E and Cox Communications poles, there are approximately 600 feet of overhead cables on South Las Posas Road, and underground services to numerous properties on the north side of La Mirada Drive.

3.5.2 Regulatory Setting
Federal, state, and local agencies regulate energy use and consumption through various means and programs. On the federal level, the U.S. Department of Transportation, the U.S. Department of Energy, and the U.S. Environmental Protection Agency (EPA) are three federal agencies with substantial influence over energy policies and programs.

On the state level, CPUC and CEC are two agencies with authority over different aspects of energy. Relevant federal, state, and local energy -related regulations are su mmarized below. This information helps to place the impact analysis within its proper regulatory context.

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Federal
Infrastructure Investment and Jobs Act
On November 6, 2021, Congress passed the Bipartisan Infrastructure Deal (Infrastructure Investment and Jobs Act), a once-in-a-generation investment in our nation’s infrastructure and competitiveness. This Bipartisan Infrastructure Deal will rebuild America’s roads, bridges, and rails, expand access to clean drinking water, ensure every American has access to high-speed internet, tackle the climate crisis, advance environmental justice, and invest in communities that have too often been left behind. The legislation will help ease inflationary pressures and strengthen supply chains by making long overdue improvements for our nation’s ports, airports, rail, and roads. It will drive the creation of good- paying union jobs and grow the economy sustainably and equitably so that everyone gets ahead for decades to come.

Combined with the President’s Build Back Framework, it will add on average 1.5 million jobs per year for the next 10 years. It will improve transportation options for millions of Americans to reduce energy use and GHG emissions. It will increase investment in electric vehicle chargers and renewable energy production.

Federal Energy Policy and Conservation Act
In 1975, Congress enacted the Federal Energy Policy and Conservation Act, which established the first fuel economy standards for on-road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 FR 62624 –63200).

The National Highway Traffic Safety Administration is proposing to amend the Corporate Average Fuel Economy standards set in 2020 for passenger cars and light trucks manufactured in model years 2024 –2026, so that standards would increase in stringency at a rate of 8% per year rather than the 1.5% year set previously (49 CFR Part 531). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.

Intermodal Surface Transportation Efficiency Act of 1991 The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) promoted the development of intermodal transportation systems to maximize mobility and address national and local interests in air quality and energy.

ISTEA contained factors that metropo litan planning organizations were to address in developing transportation plans and programs, including some energy ‐related factors. To meet the new ISTEA requirements, metropolitan planning organizations adopted policies defining the social, economic, ene rgy, and environmental values guiding transportation decisions.

Transportation Equity Act for the 21st Century
The Transportation Equity Act for the 21st Century was signed into law in 1998 and builds on the initiatives established in the ISTEA legislation, discussed above. The act authorizes highway, highway safety, transit, and other efficient surface transportation programs. The act continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of tr ansportation decisions. The act also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of intelligent transportation systems to help improve operations and mana gement of transportation systems and vehicle safety.