San Marcos City Council
June 24, 2025

Energy Independence and Security Act
The Energy Independence and Security Act of 2007, among other key measures, included the following goals, which would aid in the reduction of national GHG emissions:

1. Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022.

2. Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct National Highway Traffic Safety Administration to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.

3. Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.

State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, mobile sources, renewable energy procurement, water, solid waste, and water.

State Climate Change Targets
Executive Order (EO) S-3-05 (2005) established the following statewide goals: GHG emissions should be reduced to 2000 levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be reduced to 80% below 1990 levels by 2050.

Assembly Bill (AB) 32: California Global Warming Solutions Act (2006) provided initial direction on creating a comprehensive multiyear program to limit California’s GHG emissions to 1990 levels by 2020 and initiate the transformations required to achieve the state’s long-range climate objectives.

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California Air Resources Board’s Climate Change Scoping Plan. Under AB 32, the California Air Resources Board (CARB) is responsible for and is recognized as having the expertise to carry out and develop the programs and regulations necessary to achieve the GHG emissions reduction mandate of AB 32. Therefore, in furtherance of AB 32, CARB adopted regulations requiring the reporting and verification of GHG emissions from specified sources, such as industrial facilities, fuel suppliers and electricity importers (see Health & Safety Code Section 35830; Cal. Code Regs., tit. 17, §§95100 et seq.). CARB is also required to adopt rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. AB 32 authorized CARB to adopt market-based compliance mechanisms to meet the specified requirements. Finally, CARB is ultimately responsible for monitoring compliance and enforcing any rule, regulation, order, emission limitation, emission reduction measure, or market-based compliance mechanism adopted.

In 2007, CARB approved a limit on the statewide GHG emissions level for year 2020 consistent with the determined 1990 baseline (427 million metric tons [MMT] CO2e). CARB’s adoption of this limit is in accordance with Health and Safety Code Section 38550.

Further, in 2008, CARB adopted the Climate Change Scoping Plan: A Framework for Change (2008 Scoping Plan) in accordance with Health and Safety Code Section 38561. The 2008 Scoping Plan established an overall framework for the measures to be implemented to reduce California’s GHG emissions for various emission sources/sectors to 1990 levels by 2020. The 2008 Scoping Plan evaluated opportunities for sector-specific reductions, integrated all CARB and Climate Action Team13 early actions and additional GHG reduction features by both entities, identified additional measures to be pursued as regulations, and outlined the role of a cap-and-trade program.

In the 2008 Scoping Plan, CARB determined that achieving the 1990 emissions level in 2020 would require a reduction in GHG emissions of approximately 28.5% from the otherwise projected 2020 emissions level, i.e., those emissions that would occur in 2020, a bsent GHG -reducing laws and regulations (referred to as “Business -As-Usual” [BAU]). For purposes of calculating this percent reduction, CARB assumed that all new electricity generation would be supplied by natural gas plants, no further regulatory action would impact vehicle fuel efficiency, and building energy efficiency codes would be held at 2005 standards.

In the 2011 Final Supplement to the 2008 Scoping Plan’s Functional Equivalent Document, CARB revised its estimates of the projected 2020 emissions level in light of the economic recession and the availability of updated information about GHG reduction regulations. Based on the new economic data, CARB determined that achieving the 1990 emissions level by 2020 would require a reduction in GHG emissions of 21.7% (down from 28.5%) from the BAU conditions. When the 2020 emissions level projection was updated to account for newly implemented regulatory measures, including Pavley I (model years 2009–2016) and the Renewables Portfolio Standard (12% to 20%), CARB determined that achieving the 1990 emissions level in 2020 would require a reduction in GHG emissions of 16% (down from 28.5%) from the BAU conditions.

In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update) defined the state’s GHG emission reduction priorities for the next 5 years and laid the groundwork to start the transition to the post -2020 goals set forth in EO S-3-05 and EO B-16-2012. The First Update found that California was on track to meet

13 The Climate Action Team is comprised of state agency secretaries and heads of state agencies, boards, and departments; these members work to coordinate statewide efforts to implement GHG emissions reduction programs and adaptation programs.

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the 2020 emissions reduction mandate established by AB 32, noted that California could reduce emissions further by 2030 to levels squarely in line with those needed to stay on track to reduce emissions to 80% below 1990 levels by 2050 if the state realizes the expected benefits of existing policy goals.

In November 2017, CARB released California’s 2017 Climate Change Scoping Plan for public review and comment. This update includes CARB’s strategy for achieving the state’s 2030 GHG target as established in SB 32. (discussed below). The strategy includes continuing the Cap-and-Trade Program through 2030,
14 inclusive policies and broad support for clean technologies, enhanced industrial efficiency and competitiveness, prioritization of transportation sustainability, continued leadership on clean energy, putting waste resources to beneficial use, supporting r esilient agricultural and rural economics and natural and working lands, securing California’s water supplies, and cleaning the air and public health. When discussing project-level GHG emissions reduction actions and thresholds, the 2017 Scoping Plan states “[a]chieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.” However, the 2017 Scoping Plan also recognizes that such an achievement “may not be feasible or appropriate for every project … and the inability of a project to mitigate its GHG emissions to net zero does not imply the project results in a substantial contribution to the cumulatively significant environmental impact of climate change under CEQA.” CARB’s Governing Board adopted the 2017 Scoping Plan in December 2017.

The 2022 Scoping Plan is the most recently adopted plan and lays out a path to achieve targets for carbon neutrality and reduce anthropogenic greenhouse gas emissions by 85% below 1990 levels no later than 2045, as directed by AB 1279. The actions and outcomes in the plan will achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon. The plan calls for a need to take an unprecedented transformation and aggressively seek reductions to reduce the need of fossil fuels by moving to zero emission transportation, electrifying the cars, buses, trucks, and trains. The plan relays on external controls and requires partnership and collaboration with the federal government, other U.S. states, and other jurisdictions around the world for California to succeed in achieving its climate targets.

EO B-30-15 (2015) identified an interim GHG reduction target in support of targets previously identified under EO S -3-05 and AB 32. EO B -30-15 set an interim target goal of reducing statewide GHG emissions to 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long -term goal of reducing statewide GHG emissions to 80% below 1990 levels by 2050, as set forth in EO S-3-05. To facilitate achievement of this goal, EO B-30-15 calls for an update to CARB’s Scoping Plan to express the 2030 target in terms of MMT CO2e. The EO also calls for state agencies to continue to develop and implement GHG emission reduction programs in support of the reduction targets. Sector -specific agencies in transportation, energy, water, and forestry were required to prepare GHG reduction plans by September 2015, followed by a report on action taken in relation to these plans in June 2016.

Senate Bill (SB) 32: California Global Warming Solutions Act and AB 197: State Air Resources Board (2016) are companion bills that set a new statewide GHG reduction target; make changes to CARB’s membership and increase legislative oversight of CARB’s climate change-based activities; and expand

14 In July 2017, AB 398 was enacted into law, thereby extending the legislatively authorized lifetime of the Cap-and-Trade Program to December 31, 2030.

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dissemination of GHG and other air quality -related emissions data to enhance transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are red uced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly, in order to provide ongoing oversight over implementation of the state’s climate policies. AB 197 also added two members of the Legislature to CARB as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the scoping plan.

AB 1279: California Climate Crisis Act (2022) requires the state to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative greenhouse gas emissions thereafter. The bill also requires California to reduce statewide GHG emissions by 85% compared to 1990 levels and directs CARB to work with relevant state agencies to achieve these goals.

SB 1020: 100% Clean Electric Grid (2022) creates clean electricity targets of 90% by 2035 and 95% by 2040 with the intent of advancing the state’s trajectory to the existing 100% clean electricity retail sales by 2045 goal.

Energy Efficiency Standards
California Title 24 Building Energy Efficiency Standards serve to reduce wasteful, uneconomical, and unnecessary uses of energy for the state. While not initially promulgated to reduce GHG emissions, Building Energy Efficiency Standards are designed to ensure new buildings and alterations or additions to existin g buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. They include requirements in the Energy Code (Title 24, Part 6) and voluntary energy efficie ncy provisions in the California Building Standards (Title 24, Part 11). The California Energy Commission (CEC) is responsible for adopting, implementing, and updating these standards every three years.
• Energy Code (Title 24, Part 6) Standards were established in 1978 and serve to enhance and regulate California’s building standards. Because homes and businesses use nearly 70 percent of California’s electricity and are responsible for a quarter of GHG emissions, the CEC was mandated to periodically update and adopt building standards to increase energy efficiency of buildings and reduce GHGs. Part 6 of Title 24 implemented this mandate so that every three years the CEC updates the Energy Code for new const ruction and renovations to existing residential and non -residential buildings. As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.

The 2022 Building Energy Efficiency Standards (Energy Code) improves upon the 2019 Energy Code for new construction of, and additions and alterations to, residential and nonresidential buildings. The 2022 building code went into effect January 1, 2023, and focuses on four key areas in new construction: encouraging electric heat pump technology and use, establishing electric-ready requirements when natural gas is installed, expanding solar photovoltaic system and battery storage standards, and strengthening ventilation standards to improve indoor air quality. The 2022 standards have mandatory requirements to reduce building envelope air leakage, improve roofing through Solar Reflectance and Thermal Emittance, improve on insulation, improve on space conditioning, water heating and plumbing, improve on lighting efficiency requirements, and others.

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• California Green Building Standards Code (Title 24, Part 11) was adopted by the California Building Standards Commission in 2008 . The California Green Building Standards Code (CALGreen Part 11 of Title 24) is commonly referred to as CALGreen and establishes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low- rise residential and state -owned buildings and schools and hospitals. The CALGreen 2016 standards require d mandatory reduction in indoor and outdoor water use, diversion of demolition waste, mandatory inspections of energy systems, inclusion of electric vehicle charging stations for designated parking spaces and use of low-pollutant-emitting exterior and interior finish materials.

The current CALGreen standards were last updated in 2022 and went into effect January 1, 2023. The standards focus on battery storage system controls, demand management, heat pump space and water heating, and building electrification . The 2022 CALGreen standards update eliminates the two -tiered menu of compliance prerequisites and enforces a single tiered menu of provisionary options. Mandatory requirements include many updated electric vehicle (EV) charging requirements for multi and single-family developments.

California Title 20 : Appliance Efficiency Regulations require manufacturers of appliances to meet state and federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to demonstrate compliance with standards. New appliances regulated under Title 20 include: refriger ators, refrigerator -freezers and freezers; room air conditioners and room air - conditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low voltage dry-type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing for each type of appliance covered under the regulations and appliances must meet the standards for energy performance, energy des ign, water performance and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regulated appliances, state standards for federally regulated appliances, and state standards for non -federally re gulated appliances.

Mobile Sources
AB 1493: California’s Greenhouse Gas Vehicle Emission Standards (2002) required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by CARB to be vehicles that are primarily used for noncommercial personal transportation in the state. The bill required that CARB set GHG e mission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. When fully phased in, the near-term (2009–2012) standards were intended to result in a reduction of about 22 percent in GHG emissions compared to the emissions from the 2002 fleet, while the mid -term (2013– 2016) standards would result in a reduction of about 30 percent.

EO S-1-07: Low Carbon Fuel Standard (2007) set a declining Low Carbon Fuel Standard (LCFS) for GHG emissions measured in CO2e grams per unit of fuel energy sold in California. The carbon intensity measures the amount of GHG emissions in the lifecycle of a fuel, including extraction/feedstock

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production, processing, transportation, and final consumption, per unit of energy delivered. CARB adopted the implementing regulation in April 2009 and began implementation in 2011. The LCFS is designed to encourage the use of cleaner low-carbon transportation fuels in California, encourage the production of those fuels, and therefore, reduce GHG emissions and decrease petroleum dependence in the transportation sector. In 2018, CARB approved amendments which included strengthening and smoothing the carbon intensity benchmarks through 2030 in-line with California's 2030 GHG emission reduction target enacted through SB 32.

SB 375: The Sustainable Communities and Climate Protection Act (2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035. Regional metropolitan planning organizations are then responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a forecasted development pattern for the region that, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.

Pursuant to California Government Code Section 65080(b)(2)(K), a sustainable communities strategy does not (1) regulate the use of land; (2) supersede the land use authority of cities and counties; or (3) require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the state-mandated housing element process.

In 2010, CARB adopted the original SB 375 targets for the regional metropolitan planning organizations. The targets adopted for the San Diego Association of Governments (SANDAG) in 2010 were a 7% reduction in per capita passenger vehicle GHG emissions by 2020 and a 13% reduction by 2035, measured relative to 2005 GHG emissions. In 2018, CARB adopted the second round of SB 375 reduction targets, and increased SANDAG’s 2020 target to a 15% reduction in per capita passenger vehicle GHG emissions and the 2035 target to a 19% reduction, using the same 2005 baseline.

In December 2021, SANDAG adopted its 2021 Regional Plan, which contains the region’s current SCS (Appendix D of the Regional Plan). The SANDAG’s GHG emissions quantification analysis determined that the San Diego region reduced per capita CO
2 emissions by 17.9% in 2020 compared to 2005
baseline, which exceeds the 2020 target set for SANDAG of 15% reduction. It was noted that measurement data was significantly impacted by COVID -19 due to intermittent stay -home orders, changes in employment, employee work location, telework, tourism travel, package and food delivery, cross-border travel restrictions, declines in public transit ridership, and price of gasoline, among many other impacts. SANDAG estimated that implementation of the SCS would result in a 20% CO 2 emissions reduction for cars and light-duty trucks by 2035. The GHG reductions for the 2021 Regional Plan were calculated using the CARB model EMFAC 2014 and adjustment factors provided by CARB to account for differences in emissions rates between EMFAC 2007 (used to set the original targets in 2010) and EMFAC 2014.

The 2021 Regional Plan provides a big picture vision for how the San Diego region will grow through 2050 and beyond with an implementation program to help make the plan a reality. Within the Regional Plan, SANDAG introduced a transformative vision for tran sportation in San Diego County that

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completely reimagines how people and goods could move throughout the region in the 21st century.

The plan outlines the “5 Big Moves” which are: Complete Corridors, Transit Leap, Mobility Hubs, Flexible Fleets, and the Next Operating System. This plan is the region’s long- term plan which will be implemented incrementally through the Regional Transportation Improvement Program (RTIP) .

In September 2022, the SANDAG Board directed staff to prepare an amendment to the 2021 Regional Plan without the regional road usage charge. In developing the amendment, SANDAG will refine the financial strategies used in the 2021 Regional Plan to achieve the region's greenhouse gas emissions target set by CARB, without the road usage charge. SANDAG will also assess the region's continued ability to meet air quality standards. An Amendment to the 2021 Regional Plan removing the regional road user charge was adopted by SANDAG in October 2023. The 2025 Regional Plan is currently in development and also will not include a regional road user charge.

EO B-16-12: Zero Emission Purchasing Mandate (2012) directs state entities under the Governor’s direction and control to support and facilitate development and distribution of zero emission vehicles (ZEVs). This EO also sets a long-term target of reaching 1.5 million ZEVs on California’s roadways by 2025. On a statewide basis, EO B-16-12 also establishes a GHG emissions reduction target from the transportation sector equaling 80 percent less than 1990 levels by 2050.

Advanced Clean Cars Program (2012) was a new emissions -control program for model years 2015 through 2025 that combined standards for smog producing pollutants and greenhouse gases into one program. The package includes elements to reduce smog -forming pollution, reduce GHG emissions, promote cle an cars, and provide the fuels for clean cars. To improve air quality, CARB also has implemented new emission standards to reduce smog-forming emissions beginning with 2015 model year vehicles. To reduce GHG emissions , CARB, in conjunction with the USEPA and the National Highway Traffic Safety Administration, also adopted new GHG standards for model year 2017 to 2025 vehicles; the new standards are estimated to reduce GHG emissions by 34% in 2025.

Advanced Clean Cars II Program (2022). CARB’s latest rule is known as Advanced Clean Cars II which continues the concept of increasing stringency for fuel-efficiency standards and increasing the number of ZEVs in the vehicle fleet starting with model year 2026 until model year 2035 when all new vehicles sold in the state must be ZEVs. The regulations are two-pronged. First, it amends the ZEV Regulation to require an increasing number of ZEVs, and relies on currently available advanced vehicle technologies, including battery-electric, hydrogen fuel cell electric and plug-in hybrid electric-vehicles, to meet air quality and climate change emissions standards. These amendments support Governor Newsom’s 2020 EO N-79-20 that requires all new passenger vehicles sold in California to be zero emissions by 2035. Second, the Low -Emission Vehicle Regulations were amended to include increasingly stringent standards for gasoline cars and heavier passenger trucks to continue to reduce smog-forming emissions.

In October 2023, staff launched a new effort to consider potential amendments to the Advanced Clean Cars II regulations, including updates to the tailpipe GHG standard and limited revisions to the Low - Emission Vehicle and ZEV regulations.

EO N-79-20: Zero Emission by 2035 (2020) calls for elimination of new internal combustion passenger vehicles by 2035. By setting a course to end sales of internal combustion passenger vehicles by 2035, the Governor’s EO establishes a target for the transportation sector that helps put the state on a path to carbon neutrality by 2045. It is important to note that the EO focuses on new vehicle sales for automakers, and therefore does not require Californians to give up the existing cars and trucks they

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already own. The primary mechanism for achieving the ZEV target for passenger cars and light trucks is the Advanced Clean Cars II Program.

As part of the EO, the Governor’s Office of Business and Economic Development (GO-Biz) was tasked with preparing a ZEV Market Development Strategy along with the accompanying California State agency ZEV Action Plans.

The Clean Miles Standard Program (2022) is a regulation developed by CARB and implemented by the California Public Utility Commission that seeks to reduce GHG emissions from passenger -ride-hailing services operated by transportation networks companies (such as Uber and Lyft). This program w ill have aggressive requirements for electric miles that will transition ride-hailing fleets to zero-emission operations starting in 2023 and ramping up through 2030.

SB 350: Clean Energy and Pollution Reduction Act (2015) –establishes (among other things) a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is required for achievement of the state’s 2030 and 2050 reduction targets.

Renewable Energy Procurement
SB 1078: The Renewable Portfolio Standard (2002) established the Renewables Portfolio Standard (RPS) program, which requires an annual increase in renewable generation by the utilities equivalent to at least 1% of sales, with an aggregate goal of 20% by 2017. This goal was subsequently accelerated, requiring utilities to obtain 20% of their power from renewable sources by 2010.

SB X1 2: California Renewable Energy Resources Act (2011) expanded the RPS by establishing that 20% of the total electricity sold to retail customers in California per year by December 31, 2013, and 33% by December 31, 2020, and in subsequent years be secured from qualifying renewable energy sources. Under the b ill, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation of 30 megawatts or less, digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location. In addition to the retail sellers previously covered by the RPS , SB X1 2 added local, publicly owned electric utilities to the RPS.

SB 350: Clean Energy and Pollution Reduction Act (2015) further expanded the RPS by establishing that 50% of the total electricity sold to retail customers in California per year by December 31, 2030 be secured from qualifying renewable energy sources. In addition, SB 350 includes the goal to double the energy efficiency savings in electricity and natural gas final end uses (such as heating, cooling, lighting, or class of energy uses on which an energy-efficiency program is focused) of retail customers through energy conservation and efficiency.

SB 100: 100% Clean Energy Act (2018) has further accelerated and expanded the RPS, requiring achievement of a 50% RPS by December 31, 2026, and a 60% RPS by December 31, 2030. SB 100 also established a new statewide policy goal that calls for eligible renewable energy resources and zero-carbon resources to supply 100% of electricity retail sales within the State of California by December 31, 2045.

Water
EO B-29-15: Statewide 25% Reduction in Potable Urban Water (2015) set a goal of achieving a statewide reduction in potable urban water usage of 25% relative to water use in 2013. The term of

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the EO extended through February 28, 2016, although many of the directives have since become permanent water-efficiency standards and requirements. The EO includes specific directives that set strict limits on water usage in the state. In response , the California Department of Water Resources has modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increases the requirements for landscape water use efficiency and broadens its applicability to include new development projects with smaller landscape areas.

Solid Waste
AB 939: Integrated Waste Management Act (1989) redefined solid waste management in terms of both objectives and planning responsibilities for local jurisdictions and the state. The Act was adopted to reduce the volume and toxicity of solid waste that is landfilled and incinerated by requiring local governments to prepare and implement plans to improve the management of waste resources. AB 939 required each of the cities and unincorporated portions of the counties to divert a minimum of 25% of the solid waste sent to landfills by 1995, and 50% by the year 2000 through source reduction, recycling and composting, and environmentally safe landfill disposal and transformation. This law established the California Integrated Waste Management Board, later the Califo rnia Department of Resources Recycling and Recovery (CalRecycle).

AB 1327: California Solid Waste Reuse and Recycling Act (1991) required adequate areas for collecting and loading recyclable materials within a project site.

SB 1016: Solid Waste Disposal Measurement Act (2008) introduced a new diversion measurement system, which was based on a City's population and disposal tons to calculate a per capita disposal rate expressed in pounds per person per day. SB 1016 builds on AB 939 compliance requirements by implementing a simp lified measure of the City's recycling performance. Under this measurement system, a city needs to annually dispose of an amount equal to or less than its "50 percent equivalent per capita disposal target" calculated by CalRecycle.

AB 341 : Mandatory Commercial Recycling (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter. This law requires California commercial or public entities that generate four or more cubic yards of solid waste per week, and multifamily dwellings of five or more units, to arrange for recycling services.

AB 1826: Mandatory Commercial Organics Recycling (2014) requires local governments to establish organic waste recycling programs. In addition, it requires businesses and multifamily residences of at least five units that generate four cubic yards or more of solid waste per week to arrange for organic waste recycling services.

SB 1383: Short-Lived Climate Pollutants: Organic (2016) is a statewide effort to reduce emissions of short-lived climate pollutants (SLCP). Specifically, the law sets the following targets: 1) Reduce statewide disposal of organic waste by 50% by January 1, 2020 and by 75% by January 1, 2025 (based on 2014 levels), and 2) rescue at least 20% of currently disposed of edible food for human consumption by 2025.

Increasing the amount of solid waste that is recycled, reused, or composted will reduce GHG emissions primarily by 1) reducing the energy requirements associated with the extraction, harvest, and processing of raw materials and 2) using recyclable material s that require less energy than raw materials to manufacture finished products. Increased diversion of organic materials (green and food

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waste) will also reduce GHG emissions (CO 2 and CH4) resulting from decomposition in landfills by redirecting this material to processes that use the solid waste material to produce vehicle fuels, heat, electricity, or compost.

Local
City of San Marcos Climate Action Plan
Consistent with AB 32, the City adopted a CAP in September 2013 as a long-range plan to reduce GHG emissions and mitigate climate change impacts associated with City government operations and with implementation of the City’s General Plan. An updated CAP was adopted on December 8, 2020.

The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets. The CAP is a plan for the reduction of GHG emissions in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183.5. Pursuant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b), a project’s incremental contribution to a cumulative GHG emissions effect may be determined not to be cumulatively considerable if it complies with the requirements of the CAP (City of San Marcos 2020).

The CAP set the following citywide targets:
• 4% below 2012 levels (575,000 MT CO2e) by 2020.
• 42% below 2012 levels (347,000 MT CO2e) by 2030.

The City has also developed a Climate Action Plan Consistency Review Checklist (CAP Checklist), in conjunction with the CAP, to provide a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA.

The CAP Consistency Guidance Memo dated July 15, 2020 summarizes the methodology and application of a GHG screening threshold which is set at 500 metric tons of carbon dioxide equivalent [MT CO
2e] per year as outlined in the CAP.

City of San Marcos General Plan
Land Use and Community Design Element
• Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU -2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards. o Policy LU-2.7: Promote the installation of trees to reduce the urban heat-island effect and green infrastructure to reduce storm water runoff.

Conservation and Open Space Element
The Conservation and Open Space Element of the City of San Marcos General Plan identifies one goal and two policies regarding GHGs that are applicable to the proposed project:

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• Goal COS-4: Improve regional air quality and reduce GHG emissions that contribute to climate change.
o Policy COS-4.3: Participate in regional efforts to reduce GHG emissions. o Policy COS-4.4: Quantify community-wide and municipal GHG emissions, set a reduction goal, identify and implement measures to reduce GHG emissions as required by governing legislation.
o Policy COS-4.5: Encourage energy conservation and the use of alternative energy sources within the community.
o Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.

Mobility Element
Additionally, the Mobility Element of the City of San Marcos General Plan identifies one goal and associated policy that addresses GHG emission reductions through minimized vehicle miles traveled and reduced fuel consumption:
• Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and GHG emissions; and reinforces the role of the street as a public space that unites the City.

Environmental Justice Element
The following goal and policies in the City of San Marcos General Plan, Environmental Justice Element are applicable to greenhouse gas emissions:
• Goal EJ -1: Reduce greenhouse gas emissions, enhance air quality, and reduce impacts associated with climate change.
o Policy EJ-.1.5: Promote the installation of trees to reduce the urban heat-island effect and green infrastructure to reduce stormwater runoff (See Policy LU-2.7). o Policy EJ -1.6: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the City. (See Policy M-1.3) o Policy EJ 1 -8: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City. (See Policy M-3.1)
o Policy EJ-1.11: Participate in regional efforts to reduce greenhouse gas emissions. (See Policy COS-4.3)
o Policy EJ-1.12: Quantify community-wide and municipal greenhouse gas (GHG) emissions, set a reduction goal, identify and implement measures to reduce greenhouse gas emissions as required by governing legislation. (See Policy COS-4.4)

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o Policy EJ-1.13: Encourage energy conservation and the use of alternative energy sources within the community. (See Policy COS-4.5)
o EJ-1.14: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment. (See Policy COS-4.6)
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As deta iled in Table 3.7 -7 in Section 3.7, the project is consistent with the applicable goals and policies pertaining to greenhouse gas emissions.

3.6.3 Thresholds of Significance
Appendix G of the State CEQA Guidelines identifies two evaluation criteria to determine the significance of GHG emissions. A significant impact would be identified if the project would:
• Threshold #1: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Threshold #2: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing greenhouse gases.

The City ’s CAP Checklist, in conjunction with the CAP, provide s a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA.

The CAP Consistency Guidance Memo summarizes the methodology and application of a GHG screening threshold which is set at 500 MT CO
2e per year. Projects that are projected to emit fewer
than 500 MT CO2e annually would not make a considerable contribution to the cumulative impact of climate change and would not need to provide additional analysis to demonstrate consistency with the CAP. This screening threshold is for new development projects consistent with the City’s General Plan.

When such a project exceeds the screening threshold, the project would be required to demonstrate consistency with the CAP through the CAP Checklist.

In most cases, compliance with the CAP Checklist would provide a streamlined CEQA review path to allow project specific environmental documents, if eligible, to tier from and/or incorporate by reference the CAP’s programmatic review of GHG impacts. Projects that are consistent with the General Plan and implement CAP GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects.

If a project is consistent with the existing General Plan land use designation(s), it can be determined to be consistent with the CAP projections and can move forward to Step 2 of the CAP Checklist, which is to evaluate a project’s consistency with the applicable strategies and measures of the CAP.

For projects seeking a General Plan Amendment, such as the proposed project, the CAP Checklist requires a comparative analysis to determine if the amendment results in an equivalent or less GHG- intensive project when compared to the existing designations. In addition to providing evidence to support the conclusion that the project would generate fewer emissions than existing designations, these projects would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist.

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If a land use designation amendment results in a more GHG-intensive project, the project is required to prepare a quantitative GHG analysis based on applicable sections of the CEQA Guidelines.

3.6.4 Project Impact Analysis
The project site currently has a General Plan land use designation of Public Institutional (P -I). The project seeks a General Plan Amendment (GPA) and rezone to change the property from P-I to Specific Plan Area (SPA) for the proposed mixed-use development. Consistent with the requirements of the CAP Checklist, the GHG analysis focuses on a relative comparison between the proposed project and a likely scenario that could be constructed under the current General Plan land use designation. The P- I land use ty pically allows for any public type of use, including schools, hospitals, civic centers, telecommunication data centers, etc. The allowable use onsite per the zoning could have a floor area ratio (FAR) of 3.0. Based on this, any facility which could be constructed onsite would be limited to approximately 318,000 square feet (s.f.). Vehicular trip generations of public institutions like schools or hospitals would result in significantly more traffic than the 1,214 trips that would be generated by the proposed project and would therefore generate larger quantities of operational GHG emissions.

Based on SANDAG’s trip generation guide, a hospital can generate as many as 25 trips per 1,000 s.f. or over 7,000 trips for a project of this size (LDN 2024). One other approved use for the project site, and perhaps a more likely scenario given the project site’s location adjacent to an existing data center, would be to install a 160,000 s.f. data center or larger if multiple stories are constructed. Therefore, the GHG analysis first focuses on a relative comparison between the proposed project and the General Plan Buildout (Data Center) scenario. Secondly, per the CAP Checklist, the analysis reviews whether the project would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist.

GHGs related to construction and annual operation were calculated using the California Emissions Estimator Model (CalEEMod) 2022.1 GHG model. The construction module in CalEEMod was used to calculate the emissions associated with the construction of the project. The CalEEMod input/output model is shown in Attachments A and B of the GHG report in Appendix E of this document.

Threshold #1: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
The following analysis presents the anticipated emissions for the proposed project and the General Plan Buildout (Data Center) scenario. It was assumed that construction of the General Plan Buildout (Data Center) scenario would be very similar in terms of equipment and schedule to the proposed project. Therefore, a comparative analysis is not provided for construction emissions.

Proposed Project
Construction Emissions
The project would start grading some time in 2026 with construction to start shortly thereafter. Grading would consist of approximately 6,950 cubic yards (CY) of cut material and 4,400 CY of fill material requiring an export of approximately 2,250 CY of fill material when materials shrinkage is considered.

The export material was manually added to CalEEMod.

Construction-related GHG emissions include emissions from site preparation, grading, building construction, paving and architectural coating, including truck traffic, soils export activities, and worker trips. During grading , blasting and rock crushing may be required and was manually added to CalEEMod. The rock crusher assumed to be used during blasting would be similar to the Terex 4242SR

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310 HP unit and is further specified in Attachment C of the GHG report in Appendix E of this document.

Emissions generated by earthwork activities associated with grading were analyzed within CalEEMod using a “Grading Equipment Passes” methodology which has been approved by the South Coast Air Quality Management District (SCAQMD) in consultation with building estimator references (LDN 2024).

The contractor would use Tier IV rated diesel construction equipment to minimize diesel particulates from construction, which was manually updated in CalEEMod.

Table 3.6 -2 presents the anticipated construction emissions for the proposed project. As shown, anticipated construction related GHG emissions for the proposed project are estimated at 494 MTCO2e over the construction life of the project. Given the fact that the total emissions would ultimately contribute to cumulative levels, construction emissions of GHGs were annualized to allow for inclusion in operational emissions estimates, consistent with the SCAQMD recommendations for construction GHG emissions. Construction e missions were annualized over a 30-year period, per SCAQMD recommendations, to account for emissions generated over the assumed project lifetime. (LDN 2024). As shown in Table 3.6-2, project construction would contribute 16.46 MT CO 2e per year.

Table 3.6-2. Proposed Project Expected Annual Construction Emissions Summary (MT/Year) Year Total CO2 CH4 N2O CO2e (MT/Year)
2026 487 0.02 0.02 494
Yearly Average Construction Emissions (Metric Tons/year over 30 years) 16.46 Source: LDN 2024.

Notes: Expected Construction emissions are based upon CalEEMod modeling assumptions for equipment and durations listed in Table 4.1 of the GHG Report (LDN 2024, Appendix E of the EIR).

Operational Emissions
Once construction is completed , the proposed project would generate GHG emissions from daily operations, including sources such as area, energy, mobile, solid waste, and water uses, which are calculated within CalEEMod. Area sources include consumer products, landscaping, and architectural coatings as part of regular maintenance. Energy sources would be from electricity and natural gas use.

Mobile sources are from vehicular traffic. Solid waste generated in the form of trash is also considered as decomposition of organic material breaks down to form GHGs. Water sources include standard residential and commercial uses including landscaping activities. GHGs from water are also indirectly generated through the conveyance of the resource via pumping throughout the state and as necessary for wastewater treatment. Also, no hearth (fireplace) options were included in the modeling. A design feature has been included in the project description to indicate exclusion of fireplaces from the project.

Finally, the project traffic engineer estimated that the project would generate 1,214 daily trips (LLG 2024). These traffic numbers were utilized within the CalEEMod analysis. The project would be required to implement all CAP measures for this project type which w ould further reduce GHG emissions. Since the intent of this analysis is to compare the proposed project with the likely General Plan Buildout (Data Center) scenario , not all CAP measures were calculated for the comparison.

However, CAP Measure T -2, which requires the project to install 13 Level 2 EV Chargers would be expected to reduce emissions by 21.45 MT CO
2e was included in the operational emissions summary
(LDN 2024). Table 3.6-3 presents the proposed project’s operational emissions summary. As shown, project operations after construction and calculated CAP measures would generate 1,300.61 MT CO2e per year.

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Table 3.6-3. Proposed Project Operational Emissions Summary (MT/Year) Source Total CO2 CH4 N2O CO2e (MT/Year)
Mobile 1,149.00 0.06 0.05 1,166.00
Area 3.23 < 0.005 < 0.005 3.24
Energy 81.80 0.02 < 0.005 82.80
Water 2.84 0.20 < 0.005 9.36
Waste 12.6 1.26 0 44.20
Operations Total 1,305.60
Construction Emissions (See Table 3.6-2) 16.46
Construction and Operations 1,322.06
CAP Measure T-2: EV Charger Reduction -21.45
Project GHG Emissions 1,300.61
Source: LDN 2024.

Note: The data is presented in decimal format and may have rounding errors.

General Plan Buildout (Data Center) Emissions
Construction Emissions
The General Plan Buildout (Data Center) scenario is assumed to have a similar duration and intensity and would essentially generate the same or less GHG emissions during construction. For this reason, GHG emissions for construction were not estimated in this analysis. Instead, they are assumed to be

16.46 MT CO2e annually over a 30-year duration, which is the same as the proposed project.

Project Operational Emissions
As discussed above, the General Plan Buildout (Data Center) scenario assumes construction and operation of a 160,000 s.f. telecommunications data center. Data centers are recognized as very high consumers of electrical energy, despite being minimally staffed. For example, a 413,000 s.f. data center in Santa Clara was found to consume 665,750 megawatt hours (M Wh) or 1.61 MWh of electricity per square foot per year. Based on this, a 160,000 square foot (s.f.) building would require at least 257,600 MWh. (LDN 2024).

Based on the City’s CAP, the total cumulative Photovoltaic (PV) system in San Marcos was 10.3 megawatts direct current (MWdc), which generated 17,585 MWh or 1,707.28 MWh per MWdc installed. Based on the CAP, a building of 16 0,000 s.f. would be required to install 0.322 MWdc (2 watts dc per s.f. * 160,000 s.f. / (1 million watts per megawatt) of solar which would generate 553 MWh of electricity per year. The data center would consume 257,600 MWh annually so the solar would provide less than one percent of the total energy required. Based on CalEEMod, the data center would generate 5,505 MT CO
2e just from electrical consumption alone (See Attachment B of the GHG report, which is Appendix E of this EIR). Therefore, the required solar would not reduce emissions sufficiently to reduce this alternative scenario to less than what would be expected by the proposed project.

In addition to emissions from energy use, a 16 0,000 s.f. data center would also generate emissions from vehicular trips, area sources such as landscaping, and waste management. As such, the 5,505

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MT CO2e estimate for operational emissions is conservative for comparison to the project, since it is emissions from energy use alone.

Comparison of the Proposed Project and the General Plan Buildout (Data Center) Scenario When the proposed project’s GHG emissions (1,300.61 MT CO2e) are compared to the GHG emissions estimated under the General Plan Buildout (Data Center) scenario (5,505 MT CO2e), the project would have an estimated 76 percent less intense carbon footprint than would otherwise be assumed in the City’s General Plan based on an allowable 160,000 s.f. data center. As explained above, this is driven almost entirely by the reduced energy consumption of the project compared to a data center.

CAP Measure Consistency
Since the proposed project seeks a GPA , the proposed project’s analysis is based on a comparison between estimated emissions from the proposed use(s) and what would otherwise be approved under the existing General Plan. If a project’s proposed amendment to the General Plan would result in consistent or lower GHG emissions than development under the General Plan, the project would be required to implement the applicable CAP measures identified in Step 2 of the CAP Checklist (Appendix F of this EIR)
. Table 3.6-4 describes the CAP measures that are applicable to a multi-family residential and commercial project and how the proposed project would comply.

Table 3.6-4. Project Consistency with Applicable CAP Checklist Measures CAP Consistency Checklist Measures Project Compliance
Electric Vehicle Charging Stations (Measure T-2)
Will the project install electric vehicle charging
stations (Level 2 or better) in at least five percent of the total parking space provided on-site?
The project proposes a total of 254 on-site parking
spaces including 13 Level 2 EV spaces, 62 EV ready
spaces, and 25 EV capable spaces. The project has
been designed to meet the requirements of Measure
T-2.

Transportation Demand Management (Measure T-9)
Will the project develop and implement a TDM plan
that includes, at minimum, all of the TDM strategies
listed below?
• Provide discounted monthly transit pass or
provide at least 25 percent transit fare
subsidy to residents/employees.
• Provide designated car-share, carpool,
vanpool, and/or park-and-ride parking
spaces.
• Provide pedestrian connections between all
internal uses and to all existing or planned
external streets around the project site(s).
• Provide secure bicycle parking spaces or
bicycle racks, showers, and clothes lockers.
• Encourage telecommuting for employees
(allow one telecommute day per week or
compressed work weeks) or provide a
telecommute work center with common
office space and equipment available to
residents.

Transit Discount: The property manager will make
transit passes available to residents and business of
the building.

Designated Parking: The project will provide
designated carpool, vanpool, and/or park-and-ride
spaces on site.

Pedestrian Connections: The project provides a
pedestrian connection from the building to Armorlite
Drive.

Bicycle Spaces: The project will provide bicycle racks
for visitors. The project also includes 34 bicycle
parking spaces. Residents will have shower facilities
within apartments.

Telecommuting: The project will have space available
in the community room for residents to telecommute.

The project has been designed to meet the
requirements of Measure T-9.

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CAP Consistency Checklist Measures Project Compliance
Reduce Parking Near Transit (Measures T-12)
For Multi-Family Residential, if the project is located within a half-mile of a major transit stop, would the
project provide at least 27 percent fewer parking
spaces than required for the same use based on the
City’s municipal code parking requirements?
Per the San Marcos Municipal Code Section 20.340
(Off-Street Parking and Loading) 339 spaces would
be required for the residential use and 23 spaces
would be required for the commercial use (362 total).

However, per Measures T-12, the project is required
to reduce its total required parking by 27% or 98
spaces (264 total) since the site is within one half
mile of a major transit station. To meet the
requirements of the CAP, the project would provide
247 spaces for residential use (69 garage standard
spaces, 102 garage tandem spaces, 18 tuck under
spaces and 58 open spaces) and 17 spaces for the
commercial uses. Commercial parking requirements
would be met by providing 7 open parking spaces,
and 10 of the residential open spaces would be
available for commercial use from 9:00 AM to 5:00
PM to meet the required 17 spaces. The project has
been designed to meet Measure T-12.

Water Heaters (Measure E-1)
Will the project install one of, or a combination of, the following water heater types in place of natural gas
heaters?
The project will install electric heat pump water
heaters within all residential units. Natural gas water heaters will not be used. The project has been
designed to meet Measure E-1.

Photovoltaic Installation (Measure E-2)
Will the project install photovoltaic systems with a
minimum capacity of two watts per square foot of
gross floor area?
The project will install a photovoltaic rooftop system
with a minimum capacity of two watts per square foot
of gross floor area. The project has been designed to
meet Measure E-2.

Landscaping Water Use (Measure W-1)
Will the project comply with the City’s Water Efficient Landscape Ordinance?
The project will comply with the City’s Water Efficient Landscape Ordinance. The project has been designed
to meet Measure W-1.

Urban Tree Canopy (Measure C-2)
For multi-family residential, if the project is providing more than 10 parking spaces, will the project plant at
least one tree per five parking spaces provided?
The project includes a total of 66 outdoor uncovered
sparking spaces. Therefore, the project is required to
provide a total of 13 trees to meet the requirements
of Measure C-2. Per the landscape concept plan, the
project will plant 49 trees. The project exceeds the
requirements of Measure C-2.

Summary
Based on the comparison analysis of the proposed project and the General Plan Buildout (Data Center) Scenario, the project would have an estimated 76 percent less intense carbon footprint. As shown in Table 3.6-4, the project would comply with applicable CAP measures. Projects that propose a GPA but have GHG emissions that are less than would be anticipated for a project allowable under the General Plan, and that would implement all applicable CAP GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects. The CAP Checklist provides a streamlined review process for the GHG emissions analysis of proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA. As such, the proposed project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Impacts would be less than significant.

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Threshold #2: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHGs
The City’s CAP is the applicable plan for reducing GHG emissions. As discussed under GHG Threshold #1, above, the proposed project’s GHG emissions would be approximately 76% lower compared to the GHG emissions under the General Plan Buildout (Data Center) scenario (CAP Consistency Step 1). The project would also implement all applicable CAP GHG reduction measures (CAP Consistency Step 2), as demonstrated in Table 3.6 -4. The City’s CAP and the General Plan includes goals and policies related to GHG emissions , as detailed in Section 3.6.2. The City’s CAP was prepared in 2013 and updated in 2020 to be consistent with state and regional goals and will continue to evolve as updates to those state and regional goals are made. Since the updated CAP was adopted, AB 1279 was adopted and requires the state to achieve net zero GHG emissions no later than 2045 and to reduce statewide GHG emissions by 85% compared to 1990 levels. Approving the project’s land use change to a less intensive use moves the City in the right d irection toward achieving the newly adopted AB 1279 goals.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As detailed in Table 3.7-7 in Secti on 3.7, the project is consistent with the applicable goals and policies pertaining to greenhouse gas emissions.

In summary, the project would not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing GHGs and impacts would be less than significant.

3.6.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future projects producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect.

The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets. The CAP is a plan for the reduction of GHG emissions in accordance with CEQA Guidelines Section 15183.5. Pursu ant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b), a project’s incremental contribution to a cumulative GHG emissions effect may be determined not to be cumulatively considerable if it complies with the requirements of the CAP (City of Sa n Marcos 2020). As presented in Section 3.6.4, the project complies with the City’s CAP. Therefore, the project’s incremental contribution to a cumulative GHG emissions effect is determined not to be cumulatively considerable and impacts would be less than
significant.

3.6.6 Mitigation Measures
Based upon the analysis presented in Sections 3.6.4 and 3.6.5, project and cumulative greenhouse gas impacts would be less than significant. Therefore, no mitigation measures are necessary.

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3.6.7 Conclusion
The analysis above considered the GHG emissions of the proposed project in comparison to the emission that would be anticipated from a project that was consistent with the existing General Plan (General Plan Buildout Data Center scenario). When the proposed project’s GHG emissions (1,300.61 MT CO2e) are compared to the GHG emissions estimated under the General Plan Buildout (Data Center) scenario (5,505 MT CO2e), the project would have an estimated 7 6 percent less intense carbon footprint than would otherwise be assumed in the City’s General Plan based on an allowable 160,000 s.f. data center. This is driven almost entirely by the reduced energy consumption of the project compared to the data center. The project would also implement all the CAP Checklist measures that are applicable to multi -family housing. The proposed project would be consistent with the City’s CAP.

In addition to the City’s CAP, the General Plan includes goals and policies related to GHG emission, as detailed in Section 3.6.2. The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As detailed in Table 3.7-7 in Section 3.7, Land Use and Planning, the project is consistent with the applicable goals and policies pertaining to greenhouse gas emissions.

In summary, the project would not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing GHGs and impacts would be less than significant.

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3.7 Land Use and Planning
Introduction
This section analyzes the potential for the proposed project to have impacts related to land use and planning. This section considers consistency with applicable land use plans and habitat conservation plans. The transportation portion of the analysis is based on the following report, which is included as Appendix O of the Environmental Impact Report (EIR)15:
• Local Transportation Analysis (LTA) Armorlite Lofts , prepared by Linscott, Law & Greenspan (LLG) (November 2024a).

Although not required under the California Environmental Quality Act (CEQA), the Local Transportation Analysis focuses on automobile delay/Level of Service (LOS), consistent with the City’s Transportation Impact Analysis Guidelines ( TIAG) (San Marcos 2020). The LOS analysis was conducted to identify roadway deficiencies in the project study area and to recommend project improvements to address such deficiencies. The Local Transportation Analysis is incorporated and addressed in this section as it relates to consistency with the City’s Mobility Element policies in the General Plan. A vehicle miles traveled (VMT) analysis, which is required under CEQA, is in cluded as Appendix R of t he EIR and summarized in Section 3.11, Transportation.

In the Initial Study prepared for the proposed p roject (Appendix B.1), it wa s determined that there would be no potential for the project to have an adverse impact related to physical division of an established community. Therefore, this issue is not discussed further in this EIR section. Section 5.7, Environmental Effects Found not to be Significant - Land Use, provides additional information on this topic.

Table 3.7-1 summarizes the project- and cumulative-level land use impact analysis for the proposed project.

Table 3.7-1. Land Use Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
Threshold #1: Cause a significant
environmental impact due to a conflict
with any land use plan, policy, or
regulation adopted for the purpose of
avoiding or mitigating an environmental
effect?
Less than Significant Less than Significant Less than Significant Without Mitigation

3.7.1 Existing Conditions
This section describes the existing planning context for the project site, including the General Plan and Zoning designations that currently apply to the site.

15 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.

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Project Site
The project site is currently undeveloped, vacant land enclosed by chain-link fencing along the north, south and western property boundary and open cable railing situated atop a small retaining wall along the eastern property boundary. A gated driveway ont o the site is located on Armorlite Drive, and a second gated driveway in the northwestern portion of the property provides vehicular access via the adjacent AT&T facility to the west. Well-used foot paths and a hole in the chain-link fencing along the northern property limits indicate informal walk-through access across the property. The site is generally flat with two small, paved drive aisles and slopes downward along its edges. The project site is generally flat. Elevations range from 575 (above mean sea level (amsl) in the central knoll on the site to approximately 562 feet amsl along Armorlite Drive.

Existing General Plan Designation
The project site has an existing General Plan Land Use designation of Public/Institutional (PI) which has a maximum floor area ratio (FAR) of 3.0. According to Table 2 -3 of the Land Use Element of the City’s General Plan, this designation is for “facilities built and maintained for public use such as academic facilities, institutional uses, community service facilities, water and sewer facilities, detention and drainage facilities, cemeteries, police and fire stations, and other government buildings and properties. This designation may include privately owned facilities built and maintained for public use.” (City of San Marcos 2012).

Existing Zoning Designation
The project site has a zoning designation of P-I (Public/Institutional). According to Section 20.240.020 of the City’s Zoning Ordinance, this zone is intended to “ To provide a district for the orderly and harmonious development of public facilities to adequately meet the needs of the San Marcos community. Appropriate P -I Zone uses may include maintenance, public buildings, recreation facilities, schools, and utility installations. The P -I Zone is intended to implement and be consistent with the Public/Institutional (PI) land use designation of the General Plan.” (City of San Marcos 2021).

Surrounding Land Uses
The project site is in a developed portion of the City. The project vicinity includes a mix of multi-family residential and commercial uses. The site is bounded by North County Transit District (NCTD) right of way to the north, the Palomar Station mixed -use development to the east and south, and George Burgers and AT&T to the west. The Palomar College SPRINTER station is located approximately 0.1 - miles from the project site, approximately 1,000 feet east of the intersection of Las Posas Road and W. Mission Road. SR-78 is approximately 0.25 mile south of the project site.

Roadway Circulation System
The study area includes ten intersections and four roadway segments based on guidance provided in the TIAG (City of San Marcos 2020). Per the City’s TIAG, the study area was defined using the following criteria:
• Signalized and unsignalized intersection along and adjacent to the project site; • Site access driveways; and

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• Any classified (non-residential) roadway segments that are linked to the intersections that are being studied
Figure 3.7-1 shows the project study area roadway segments and intersections.

Study Intersections
• #1 - Mission Road/Rancho Santa Fe Road
• #2 - Mission Road/Pacific Street
• #3 - Mission Road/Las Posas Road
• #4 - Mission Road/Knoll Road
• #5 - Armorlite Drive/Las Posas Road
• #6 - Armorlite Drive/Project Driveway
• #7 - Las Posas Road/Descanso Avenue
• #8 - Las Posas Road/SR-78 Westbound Ramp
• #9 - Las Posas Road/Grand Avenue
• #10 - Grand Avenue/SR-78 Eastbound Ramp
Study Roadway Segments
• Mission Road, between Rancho Santa Fe Road and Las Posas Road • Mission Road, between Las Posas Road and Knoll Road
• Las Posas Road, between Mission Road and SR-78 Westbound Ramp • Las Posas Road, between SR-78 Westbound Ramp and Grand Avenue Existing Level of Service for Intersections and Roadway Segments Table 3.7-2 summarizes the LOS criteria for signalized intersections and Table 3.7-3 summarizes the LOS criteria for stop-controlled unsignalized intersections. Table 3.7-4 summarizes roadway segments daily capacity and LOS standards. Section 3.7.4 below provides additional information regarding the LOS analysis and methodology.

Table 3.7-2. Signalized Intersection LOS Operational Analysis Method LOS
Average Stopped
Delay Per Vehicle
(Seconds)
Description
A <10
Operations with very low delay. This occurs when the progression is extremely favorable and most vehicles do not stop. Short cycle lengths may also contribute to low delay.

B >10 and <20
Operations with generally good progression and/or short cycle lengths. More vehicles stop than for LOS A, causing higher levels of average delay.

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LOS
Average Stopped
Delay Per Vehicle
(Seconds)
Description
C >20 and <35
Operations with higher delays, which may result from fair progression and/or longer cycle lengths. Individual cycle failures may begin to appear at this level. The number of vehicles stopping is significant at this level, although many still pass through the intersection without stopping.

D >35 and <55
Operations with high delay, resulting in some combination of unfavorable progression, long cycle lengths, or high volumes. The influence of congestion, and individual cycle features is noticeable.

E >55 and <80 The limit of acceptable delay. Individual cycle failures are frequent occurrences.

F >80
Excessively high delays considered unacceptable to most drivers.

Poor progression and long cycle lengths may also be major contributing factors to such delays.

Source: Highway Capacity Manual, 7th edition.

Table 3.7-3. LOS Criteria for Stop-Controlled Unsignalized Intersections Average Stopped Delay Per Vehicle (Seconds) LOS
<10 A
>10 and <20 B
>20 and <35 C
>35 and <55 D
>55 and <80 E
>80 F
Source: Highway Capacity Manual, 6thth edition.

Table 3.7-4. Roadway Segment Daily Capacity and LOS Standards Street Classification
LOS/ADT Threshold

A B C D E
Expressway (6-lane) < 30,000 < 42,000 < 60,000 < 70,000 < 80,000 Prime Arterial (6-lane) < 25,000 < 35,000 < 50,000 < 55,000 < 60,000 Major Arterial (6-lane, divided) < 20,000 < 28,000 < 40,000 < 45,000 < 50,000 Major Arterial (4-lane, divided) < 15,000 < 21,000 < 30,000 < 35,000 < 40,000 Major Arterial (3-lane, one-way) < 12,500 < 16,500 < 22,500 < 25,000 < 27,500 Major Arterial (2-lane, one-way) < 10,000 < 13,000 < 17,500 < 20,000 < 22,500 Secondary Arterial / Collector (4 -lane w/
center lane) < 10,000 < 14,000 < 20,000 < 15,000 < 30,000 Collector (4-lane w/o center lane) < 5,000 < 7,000 < 10,000 <13,000 < 15,000

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Street Classification
LOS/ADT Threshold

A B C D E
Collector (2 -lane w/ continuous left -turn
lane) < 5,000 < 7,000 < 10,000 < 13,000 < 15,000
Collector (2-lane no fronting property) < 4,000 < 5,500 < 7,500 < 9,000 < 10,000 Collector (2-lane w/ commercial fronting) < 2,500 < 3,500 < 5,000 < 6,500 < 8,000 Collector (2-lane w/ multi-family) < 2,500 < 3,500 < 5,000 < 6,500 < 8,000 Collector (3-lane, one-way) < 11,000 < 14,000 < 19,000 < 22,500 < 26,000 Collector (2-lane, one-way) < 7,500 < 9,500 < 12,500 < 15,000 < 17,500 Collector (1-lane, one-way) < 2,500 < 3,500 < 5,000 < 6,500 < 7,500 Sub-Collector (2-lane single family) - - < 2,200 - -
Source: City of San Marcos Transportation Impact Guidelines (San Marcos 2020).

Note: Bold number indicates the ADT threshold for acceptable LOS.

Traffic Counts
The study area intersections and roadway traffic counts were conducted on either September 14, 2023 or October 2, 2023 when schools in the area were in session. Traffic count worksheets are provided in Appendix A of the LTA which is included as Appendix O of this EIR.

Intersections
Table 3.7 -5 displays intersection LOS and average vehicle delay results for the key study area intersections under existing conditions. As shown in Table 3.7- 5, all intersections are calculated to currently operate at LOS D or better during both the AM and PM peak hours with the exception of the following intersections:
• Las Posas Road/Descanso Avenue – LOS F (AM Peak Hour) and LOS E (PM Peak Hour) • Las Posas Road/Grand Avenue – LOS E (AM and PM Peak Hours) Roadway Segments
Table 3.7-6 shows the classification of each project area roadway and the current operating conditions for the study area roadway segment. As shown in Table 3.7 -6, the study area segments are all operating at LOS C or better.

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Table 3.7-5. Peak Hour Intersection LOS – Existing Conditions # Intersection Control
Type Peak Hour
Existing
Avg. Delay
(seconds) LOS
1 Mission Road/Rancho Santa Fe Road Signal
AM 29.3 C
PM 30.3 C
2 Mission Road/Pacific Street Signal
AM 28.2 C
PM 46.0 D
3 Mission Road/Las Posas Road Signal
AM 46.6 D
PM 50.0 D
4 Mission Road/Knoll Road Signal
AM 49.6 D
PM 38.8 D
5 Armorlite Drive/Las Posas Road Signal
AM 28.0 C
PM 24.3 C
6 Armorlite Drive/Project Driveway DNE(1)

AM -- --

PM -- --
7 Las Posas Road/Descanso Avenue Signal
AM 97.6 F
PM 80.0 E
8 Las Posas Road/SR-78 Westbound Ramp Signal
AM 28.5 C
PM 20.0 B
9 Las Posas Road/Grand Avenue Signal
AM 68.4 E
PM 72.1 E
10 Grand Avenue/SR-78 Eastbound Ramp Signal
AM 39.5 D
PM 41.5 D
Source: LLG 2024a.

Notes: (1) DNE - Does not exist.

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Table 3.7-6. Roadway Segment LOS Results – Existing Conditions Roadway Segment Classification Daily
Volume
LOS
Threshold
(LOS E)
V/C(1) LOS(1
Mission Road
Rancho Santa Fe Road
to Las Posas Road
4-Lane Major Arterial
with Enhanced Class II
Bike Lanes
14,200 40,000 0.355 A
Las Posas Road to
Knoll Road
4-Lane Major Arterial
with Enhanced Class II
Bike Lanes
19,960 40,000 0.499 B
Las Posas Road
Mission Road to SR-78
Westbound Ramps 6-Lane Prime Arterial 29,710 60,000 0.495 B Mission Road to Grand
Avenue 6-Lane Prime Arterial 38,610 60,000 0.644 C
Source: LLG 2024a.

Notes: (1) VC = Volume/Capacity
(2) LOS = Level of Service
(3) CLTL = Continuous Left-Turn Lane

3.7.2 Regulatory Setting
This section provides an overview of the regulatory setting related to planning and land use that apply to the project, including state, regional, and local regulation and planning documents.

State
California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is provided in the California Planning and Zoning Law, Government Code Sections 65000 et seq. Under state planning law, each city and county is required to adopt a General Plan “for the physical development of the county or city, and any land outside its boundaries which bears relation to its planning” (Section 65300). The California Supreme Court has called the General Plan the “constitution for futur e development.” The General Plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private. A General Plan consists of several elements, including land use, circulation, housing, conservation, open space, noise, and safety; other elements may be included at the discretion of the jurisdiction that relate to the physical development of the county or city.

Senate Bill 743
California Senate Bill (SB) 743 mandated specific types of CEQA analysis of transportation projects effective July 1, 2020. Prior to implementation of SB 743, CEQA transportation analyses of individual projects typically determined impacts on the circulation system in terms of LOS roadway delay and/or capacity usage at specific locations, such as street intersections or roadway segments. SB 743, signed into law in September 2013, required changes to the guidelines for CEQA transportation analysis. The changes include the elimination of auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts. The purpose of SB 743 is to

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promote the reduction of greenhouse gas (GHG) emissions, the development of multimodal transportation networks, and a diversity of land uses.

Under SB 743, a project’s effect on automobile delay shall not constitute a significant environmental impact. Therefore, LOS and other similar vehicle delay or capacity metrics may no longer serve as transportation impact metrics for CEQA analysis. The California Office of Planning and Research (OPR) has updated the CEQA Guidelines and provided a final technical advisory in December 2018, which recommends VMT as the most appropriate measure of transportation impacts under CEQA. The California Natural Resour ces Agency certified and adopted the CEQA Guidelines including the Guidelines section implementing SB 743. The changes have been approved by the Office of Administrative Law and are now in effect. Section 3.15, Transportation, of this EIR analyzes potential VMT impacts related to the proposed project.

While VMT is the preferred quantitative metric for assessing potentially significant transportation impacts under CEQA, it should be noted that SB 743 does not prevent a city or county from using metrics such as LOS as part of the application of local gene ral plan policies, municipal and zoning codes, conditions of approval, or any other planning requirements through a city’s planning approval process. Cities can still ensure adequate operation of the transportation system in terms of transportation congestion measures related to vehicular delay and roadway capacity. As such, the City can continue to require congestion -related transportation analysis and mitigation projects through planning approval processes outside of CEQA.

To comply with the requirements of SB 743, the City of San Marcos has prepared its TIAG to provide guidance on conducting transportation impact analyses in the city as follows:
• CEQA Analysis Requirements: Requirements for conducting CEQA analysis, which consists of SB 743-consistent VMT analysis as well as assessing impacts to pedestrians, bicyclists, transit, hazards, emergency access, and other impacts (See Section 3.15 Transportation). • Local Transportation Analysis Requirements: Requirements for conducting LOS analysis, site access assessments, and other local transportation analyses for non-CEQA purposes (Section

3.7 Land Use and Planning).

Regional/Local
SANDAG San Diego Forward: The Regional Plan
The Regional Plan, adopted in 2021 by the San Diego Association of Governments (SANDAG), provides a long-term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal access to jobs, educat ion, healthcare, and other community resources. The plan is the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies.

The Regional Plan combines the Regional Comprehensive Plan and the Regional Transportation Plan/ Sustainable Communities Strategy (RTP/SCS). By integrating land use and transportation plans, the Regional Plan is intended to achieve greenhouse gas emission reduction targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act.

The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from

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the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments (GPAs) initiated by the jurisdiction or landowner applicants. The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications.

Accordingly, SANDA G’s RTP/SCS latest forecasts of future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.

The Regional Plan also supports other regional transportation planning and programming efforts, including overseeing which projects are funded under the Regional Transportation Improvement Program and the TransNet program. SANDAG is applying data -driven strategies, innovative technologies, and stakeholder input to create a future system that is faster, fairer, and cleaner. Part of this data-driven approach includes the implementation of five key transportation strategies referred to as the 5 Big Moves. Thes e strategies provide the framework for the Regional Plan and consider policies and programs, changes in land use and infrastructure, take advantage of the existing transportation highway and transit networks, and leverage trends in technology to optimize use of the transportation system. Together, these initiatives will create a fully integrated, world -class transportation system that offers efficient and equitable transportation choices, meets state climate targets, and supports local jurisdictions’ achievements of Climate Action Plan (CAP) goals.

In September 2022, the SANDAG Board directed staff to prepare an amendment to the 2021 Regional Plan without the regional road usage charge. The amendment to the Regional Plan was approved by the SANDAG Board in late 2023.

SANDAG Smart Growth Opportunity Areas
The project site is located within the SM -3 Mixed Use Transit Corridor as identified in the SANDAG Smart Growth Concept Map for North County. The “Smart Growth Concept Map” identifies locations in the region that can support smart growth, transit, walking, and biking. The map serves as the foundation for prioritizing transportation investments and determining eligibility for local smart growth incentive funds. The Smart Growth Concept Area data includes just over 200 existing, planned, or potential smart growth locations. Planning professionals from the region’s jurisdictions — each of the 18 cities and the county — provided the recommendations for these specific locations. In addition to input from the cities and county, feedback from the public also was important in creating the data for inclusion in the Smart Growth Concept Map. The SANDAG Board of Directors accep ted the initial Concept Map in 2006. The Board accepted the most recent technical update in 2016 (SANDAG 2016).

Multiple Habitat Conservation Program
The Multiple Habitat Conservation Program (MHCP) is a comprehensive conservation planning process that addresses the needs of multiple plant and animal species in northwestern San Diego County. The MHCP encompasses the cities of Carlsbad, Encinitas, Escond ido, Oceanside, San Marcos, Solana Beach, and Vista. Its goal is to conserve approximately 19,000 acres of habitat, of which roughly 8,800 acres (46%) are already in public ownership and contribute toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.

The City of San Marcos began preparing a draft of the City Subarea Plan of the MHCP in December 1999 and although the Subarea Plan has not yet been approved by the U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) , the plan is a component of the

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adopted MHCP and is currently being used as a guide for open space design and preservation within the city. The intent of the City’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizin g fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as Focused Planning Areas (FPA), have been designated with parcel -level preserve goals which would contribute to achie ving local and regional conservation goals while minimizing adverse effects on property rights and property values. The project site is not located within an FPA.

San Diego County Regional Airport Authority/Airport Land Use Commission The nearest public airport is the McClellan-Palomar Airport, which is located approximately five miles southwest of the project site. The McClellan -Palomar Airport Land Use Compatibility Plan (ALUCP) contains policies to promote land use compatibility betw een the McClellan-Palomar Airport and adjacent and proximate land uses, to the extent these areas are not already developed with existing uses, and to protect the public health, safety, and welfare. Using airport -related forecasts and background data appro ved by the California Department of Transportation, Division of Aeronautics, the plan reflects anticipated growth of the airport over a 20 -year horizon. The plan includes land use compatibility criteria and identifies policies applicable to the airport and surrounding land uses.

According to the McClellan-Palomar ALUCP, the project site partially lies within Review Area 2 of the airport influence area. The influence area is regulated by the Airport Land Use Commission (ALUC), which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over-flight factors through review of development proposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain. Residential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights.

City of San Marcos General Plan
The San Marcos General Plan consists of the following elements:
• Land Use and Community Design Element - Describes the desired future physical composition of the planning area in terms of location, type, and intensity of new development and open space to ensure balanced development that maximizes the long -term livability of the San Marcos community.
• Mobility Element - Describes the mobility strategy for the City, which identifies a network of options including streets, sidewalks, trails, and transit, that connects people with the City. • Conservation and Open Space Element – Recognizes the habitat and scenic value of natural and cultural open spaces within the City and lists goals and policies that ensure long -term stewardship of these resources. This element also addresses climate change, water conservation, energy conservation, air quality, watersheds, and water quality. • Parks, Recreation and Community Health Element – Identifies the recreational amenities and community service programs offered within the City and outlines goals for increased access to parks, trails, recreational facilities, and community service programs for all community members.
• Safety Element - Establishes policies and programs to protect public health, safety, and welfare of all residents and property. This element identifies and describes plans for response to natural and human-caused safety issues, including geologic, seismic, flood, and fire hazards.

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• Noise Element - Identifies problematic noise sources within the City and outlines strategies to reduce overall ambient noise levels. This element also includes measures to strategically distribute land uses throughout the City.
• Housing Element - Describes the strategy for developing a variety of housing opportunities to accommodate all residents and preserve the quality of existing housing in order to promote safe, decent, and affordable housing within the 2021-2029 planning period. • Environmental Justice - Addresses priorities related to a more equitable, safe, and healthy lifestyle for all City residents.

The City’s Land Use and Community Design Element identifies five goals and associated policies to guide well-balanced land use planning in the city. The following goals and policies from the City of San Marcos General Plan, Land Use Element pertain to planning:
• Goal LU -1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community. o Policy LU-1.1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices.
o Policy LU-1.3: Diversify land uses by providing mixed use land uses in strategic locations within the City that place housing adjacent to employment. o Policy LU -1.4: Maintain the natural integrity of open space preserves by ensuring development projects are sensitively integrated along the edges of preserved or protected areas.
• Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU-2.2: Encourage new development to be sited to respond to climatic conditions, such as solar orientation, wind, and shading patterns.
o Policy LU -2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards. o Policy LU-2.5: Promote landscaping (e.g., native, drought -tolerant plants) that minimizes demands on water supply.
o Policy LU-2.7: Promote the installation of trees to reduce the urban heat island effect and green infrastructure to reduce storm water runoff.
• Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
o Policy LU-3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.
o Policy LU -3.5: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways.

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o Goal LU -5: Promote community design that produces a distinctive, high -quality built environment with forms and character that create memorable places and enrich community life.
o Policy LU-5.4: Require building and site design that respects the natural topography and iconic ridgelines that serve as the visual backdrop for San Marcos. o Policy LU -5.6: Require a specific plan for strategic areas/properties that require high - quality design, orientation, and development due to their location or visibility within the community.
o Policy LU-5.7: Architecture shall be enhanced with high-end building materials, varied roof lines, and decorative details.
• Goal LU-7: Direct and sustain growth and expansion in areas of San Marcos that can support a concentration of a variety of uses and are particularly suitable for multimodal transportation and infrastructure expansion and improvements.
o Policy LU-7.2: Coordinate pedestrian, transit and infrastructure upgrades with infill and redevelopment opportunities.

The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to the land use for the proposed project are identified below. Policies associated with Goals M-2 and M-3 are analyzed in Table 3.7-7, located at the end of this section, and discussed in Section

3.15, Transportation.
• Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods. o Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map o Policy M -1.2: Require new development to finance and construct internal adjacent roadway circulation and City-wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian, and bicycle facilities. o Policy M -1.3: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the City.
o Policy M-1.4: Utilize multi-modal LOS techniques to evaluate transportation facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
 LOS D or better for Vehicles as a prioritized mode
⸋ Generally, provides facilities that have minimum vehicle congestion during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
 The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).

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o Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network. o Policy M-1.7: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor. • Goal M-2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.
o Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods, while maintaining the City’s desire to provide connectivity on the roadway network. o Policy M-2.3: Consider roundabouts, as appropriate, as an intersection control device with demonstrated air quality, traffic efficiency, and safety benefits. • Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City.
o Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance, and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate. o Policy M-3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.
o Policy M-3.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians.
o Policy M -3.9: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian-scale lighting, way finding signage, transit shelters, and other approp riate amenities.

The General Plan includes goals and policies applicable to other areas, such as mobility, safety, noise, conservation, and environmental justice. The project’s consistency with applicable General Plan goals and policies is presented in
Table 3.7-7, at the end of this section.

San Marcos Municipal Code and Zoning Ordinance, Title 20 The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.

The Zoning Ordinance is based on the official Zoning Map of the City of San Marcos. The purpose of this Zoning Ordinance is to protect and promote the publ ic health, safety, comfort, convenience, and general welfare of the San Marcos community; to implement the policies of the General Plan; and to

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provide the physical, environmental, economic, and social advantages that result from the orderly planned use of land resources.

The project site has a zoning designation of Public Institutional (P-I). According to Section 20.240.020 of the City’s Zoning Ordinance, this zone is intended to “To provide a district for the orderly and harmonious development of public facilities to adeq uately meet the needs of the San Marcos community. Appropriate P-I Zone uses may include maintenance, public buildings, recreation facilities, schools, and utility installations. The P -I Zone is intend ed to implement and be consistent with the Public/Institutional (PI) land use designation of the General Plan.” (City of San Marcos 2021). The project proposes a zoning change to Specific Plan Area for the Armorlite Lofts Specific Plan.

3.7.3 Thresholds of Significance
According to Appendix G of the State CEQA Guidelines, the proposed project would have a significant impact related to land use if it would:
• Threshold #1: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect.

As identified above, impacts related to physical division of an established community are not discussed in this section. Section 5.0, Environmental Effects Found not to be Significant, provides additional information on this topic.

3.7.4 Project Impact Analysis
The project proposes 165 residential apartments on 2.44 acres for a proposed density of 67 dwelling units/acre. As proposed, 15% of units calculated from the base density would be affordable units at the very-low income level. Very -low income is defined by the U.S Department of Housing and Urban development as 50% of the Area Median Income or AMI) 16. The proposed project is requesting approval of a Specific Plan, General Plan Amendment, Rezone, Site Development Plan, and Conditional Use Permit. Each of these actions is described in more detail below. The project plans are included as Appendix A.2.
• Specific Plan (SP23 -0001) - The Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan. The Specific Plan would be required to be reviewed and approved concurrently with the Multi-Family Site Development Plan application.
• General Plan Amendment (GPA23 -0002) - A General Plan Amendment would be required to change the existing PI (Public Institutional) designation to Specific Plan Area (SPA). • Rezone (R22-0001) - A rezone would be required to change the existing Public-Institutional (P- I) zoning to Specific Plan Area (SPA).
• Site Development Plan (SDP23-0003) - The Site Development Plan approval would be required to construct 165 apartment units and 5,600 s.f. of commercial and address the details of the

16 Area Median Income (AMI) is the midpoint of a region’s income distribution- half of the families in a region earn more than the median and half earn less than the median. This can also be looked at as the median household income.

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architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Conditional Use Permit (CUP23-0002) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

Threshold #1: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect.

Plans and policies considered in this analysis include the San Marcos General Plan, the City of San Marcos zoning ordinance and the MHCP.

San Marcos General Plan
As identified above, the project site has an existing General Plan Land Use designation of Public/Institutional (PI) which has a maximum floor area ratio (FAR) of 3.0. According to Table 2 -3 of the Land Use Element of the City’s General Plan, this designation is for “facilities built and maintained for public use such as academic facilities, institutional uses, community service facilities, water and sewer facilities, detention and drainage facilities, cemeteries, police and fire stations, and other government buildings and properties. This designation may include privately owned facilities built and maintained for public use” (City of San Marcos 2012).

The project is proposing a General Plan Amendment to change the designation to Specific Plan. The Armorlite Lofts Specific Plan provides regulations for the development of the project site including the proposed development standards, design guidelines, utilities, infrastructure, and public services necessary to implement and support the future development.

Table 3.7-7 at the end of this section summarizes the applicable San Marcos General Plan goals and policies relating to land use. As shown in Table 3.7-7, the project is consistent with the applicable goals and policies.

Mobility Element Consistency – Level of Service Analysis The following analysis focuses on automobile delay/LOS, consistent with the City’s TIAG. The LOS analysis was conducted to identify roadway deficiencies in the project study area and to recommend project improvements to address such deficiencies. The LTA is incorporated and addressed in this section as it relates to consistency with the City’s Mobility Element policies . A VMT analysis, which is required under CEQA, is included as Appendix O of the EIR and summarized in Section 3.11, Transportation.

Analysis Methodology - Intersections
The AM intersection analysis evaluates LOS during the hour with the highest vehicular traffic between 7:00 AM and 9:00 AM. The PM intersection analysis evaluates LOS during the hour with the highest vehicular traffic between 4:00 PM and 6:00 PM. Tables 3.7-2 and 3.7-3 summarize the LOS criteria for signalized intersections and unsignalized stop-controlled intersections.

The analysis of signalized intersections utilized the operational analysis procedure as outlined in the Highway Capacity Manual (HCM) 6th Edition signalized (Chapter 19) intersection analysis methodology. This method defines LOS in terms of delay, or more specifically, average stopped delay per vehicle. Delay is a measure of driver and/or passenger discomfort, frustration, fuel consumption and lost travel time. This technique uses 1,900 vehicles per hour per lane (VPHPL) as the maximum

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saturation volume of an intersection. This saturation volume is adjusted to account for lane width, on‐ street parking, pedestrians, traffic composition (i.e., percentage trucks) and shared lane movements (i.e., through and right‐turn movements originating from the same lane). The LOS criteria used for the analysis of signalized intersections are described in Table 3.7 -2, identifying the thresholds of control delays and the associated LOS. The computerized analysis of intersection operations was performed utilizing the Synchro Version 11 traffic analysis software by Trafficware Ltd.

Unsignalized intersections were analyzed using the Highway Capacity Manual 6th Edition side-street stop (Chapter 20) and all-way stop (Chapter 21) intersection analysis methodology. The computerized analysis of intersection operations was performed utilizing the Synchro Version 11 traffic analysis software by Trafficware Ltd.

LOS was determined as follows:
• All-way stop intersections: Reported for the entire intersection as an average value. • Side-street stop intersections: Reported for the worst-case movement.

The LOS criteria used for the analysis of unsignalized intersections are described in Table 3.7-3.

Analysis Methodology – Roadway Segments
Roadway segment LOS standards and thresholds provide the basis for analysis of arterial roadway segment performance. The analysis of roadway segment LOS is based on the functional classification of the roadway, the maximum capacity, roadway geometrics, and existing or forecast Average Daily Traffic (ADT) volumes. Table 3.7 -4 presents the roadway segment capacity standards found in the City’s TIAG. The actual capacity of a roadway facility varies according to its physical attributes.

Level of Service Standards
The City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards outlined in the General Plan Mobility Element. If the addition of the traffic generated from a proposed project results in any one of the followin g, improvements should be identified to increase performance to acceptable or pre-project conditions under each scenario:
• Triggers an intersection operating at acceptable LOS to operate at unacceptable LOS (LOS E or F) and increases the delay by more than 2.0 seconds. • Increases the delay for a study intersection that is already operating at unacceptable LOS (LOS E or F) by more than 2.0 seconds.
• Triggers a roadway segment operating at acceptable LOS (LOS A, B, C, D) to operate at unacceptable LOS and increases the volume/capacity (V/C) ratio by more than 0.02. • Increases the V/C ratio for a study roadway segment that is already operating at unacceptable LOS (LOS E or F) by more than 0.02.

Project Trip Generation
To determine the traffic generation of the proposed project, the April 2002 SANDAG Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002) rates were applied to the proposed project. The “Multi -family Residential” (more than 20 DU/acre)” trip rate was used to

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estimate the project residential trip generation. The “Specialty Retail/Strip Commercial” trip rate was used to estimate the commercial trip generation.

Table 3.7 -8 presents the trip generation rates and forecasted project -generated trips for weekday conditions. As shown in Table 3.7 -8, the project would generate approximately 1,214 average daily trips (ADTs), including 86 AM peak hour trips and 109 PM peak hour trips. The project trip distribution was manually developed based on the geographical location of the project, as well as the characteristics of the proposed and surrounding land uses. Additional considerations were taken for North Pacific Street and W. Mission Road, which allows for only right -in/right-out movements for the south leg.

Table 3.7-8. Project Trip Generation
Land Use Quantity
Daily Trip Ends
(ADT)
AM Peak Hour PM Peak Hour
% of
ADT
In:Out
Split
Volume % of
ADT
In:Out
Split Volume
Rate ADT In Out Total In Out Total
Apartments 165
units 6/DU 990 8% 20:80 16 63 79 9% 70:30 62 27 89
Commercial
Mixed Use
5,600
SF 40/KSF 224 3% 60:40 4 3 7 9% 50:50 10 10 20
Total 1,214 20 66 86 72 37 109
Source: LLG 2024a.

Note: Trip generation rates were obtained from the (Not so) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002 by SANDAG
DU = Dwelling Unit, ADT = Average Daily Traffic
Construction Trip Generation
Grading of the project site would consist of approximately 4,030 cubic yards (cy) of cut material and 12,270 cy of fill material requiring an import of approximately 8,240 cy of material. Grading would consist of approximately 6,950 cubic yards (CY) of cut material and 4,400 CY of fill material requiring an export of approximately 2,250 CY of material.

Assuming 20 work days for materials export and the use of a 15 cy truck, there would be approximately 8 truckloads per day. The grading phase of the project is not expected to generate trips above the trips associated with the 165 apartments and proposed commercial uses. Therefore, the grading phase would not result in any traffic related significant impacts or substantial effects above those associated with the project. No traffic related impacts are identified during construction.

Local Transportation Analysis of Near-Term (Year 2025) Conditions The following section presents the analysis of study area intersections and street segments under Near-Term Year 2025 Base conditions and Near-Term Year 2025 Base + Project conditions.

To forecast future traffic volumes for Near-Term (Interim Year 2025) conditions, the SANDAG ABM2+ Year 2016 and Year 2025 models were utilized to obtain the growth per year percent. Year 2025 traffic volumes were then developed based on an extrapolation us ing the calculated growth per year percent and applying it to the Year 2023 existing traffic volume counts for 2 years. In addition, traffic volumes from potential Cumulative projects provided by City of San Marcos staff were manually added

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onto the study area intersection and street segments. These Cumulative projects are listed in Table 7–1 below. Cumulative projects are other projects in the study area that will add traffic to the local circulation system by the Interim Year.

Near-Term Year 2025 Intersection Analysis
Table 3.7-9 summarizes the intersection operations through the study area for the Near -Term Year 2025 Base Condition and Base + Project conditions.

Table 3.7-9. Near-Term Year 2025 - Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour
Year 2025
Base Conditions
Year 2025
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.

Delay
(sec.)(1)
LOS(2)
Avg.

Delay
(sec.)(1)
LOS(2)
1 Mission Road/
Rancho Santa Fe
Road
Signal
AM 29.6 C 29.6 C 0.0 Yes
PM 31.6 C 31.8 C 0.2 Yes
2 Mission Road/
Pacific Street Signal
AM 29.6 C 29.8 C 0.2 Yes
PM 50.3 D 50.8 D 0.5 Yes
3 Mission Road/ Las
Posas Road Signal
AM 49.7 D 50.0 D 0.3 Yes
PM 52.5 D 53.2 D 0.7 Yes
4 Mission Road/
Knoll Road Signal
AM 53.4 D 53.9 D 0.5 Yes
PM 43.1 D 43.2 D 0.1 Yes
5 Armorlite Drive/
Las Posas Road Signal
AM 28.2 C 43.4 D 15.2 Yes
PM 25.2 C 31.6 C 6.1 Yes
6 Armorlite Drive/
Project Driveway(5) DNE(1)
AM -- -- 10.1 B -- Yes
PM -- -- 9.7 A -- Yes
7 Las Posas
Road/Descanso
Avenue
Signal
AM 116.5 F 117.1 F 0.6 Yes
PM 112.0 F 113.2 F 1.2 Yes
8 Las Posas Road/
SR-78 Westbound
Ramp
Signal
AM 34.8 C 36.2 D 1.4 Yes
PM 30.1 C 32.2 C 2.1 Yes

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# Intersection Control
Type
Peak
Hour
Year 2025
Base Conditions
Year 2025
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.

Delay
(sec.)(1)
LOS(2)
Avg.

Delay
(sec.)(1)
LOS(2)
9 Las Posas Road/
Grand Avenue Signal
AM 112.6 F 113.9 F 1.3 Yes
PM 130.8 F 132.1 F 1.3 Yes
10 Grand Avenue/ SR-
78 Eastbound
Ramp
Signal
AM 39.6 D 40.1 D 0.5 Yes
PM 43.4 D 43.8 D 0.4 Yes
Source: LLG 2024a.

Notes: (1) Average Delay expressed in seconds per vehicle (2) LOS = Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) Intersection does not exist under Year 2025 Base condition As shown in Table 3.7-9, in the Near-Term Year 2025 Base condition, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of the following intersections:
• Las Posas Road/Descanso Avenue – LOS F (AM and PM Peak Hours) • Las Posas Road/Grand Avenue – LOS F (AM and PM Peak Hours) With the addition of project traffic (Base + Project condition) all intersections would continue to operate acceptably at LOS D except for the following intersections which will continue to operate below an acceptable level of service:
• Las Posas Road/Descanso Avenue – LOS F (AM and PM Peak Hours) • Las Posas Road/Grand Avenue – LOS F (AM and PM Peak Hours) The addition of traffic from the proposed project would result in an increase in delay at the Las Posas Road/Descanso Avenue intersection of 0.6 seconds in the AM peak hour and 1.2 seconds on the PM peak hour. At the intersection of Las Posas Road/Grand Avenue, the proposed project would increase the delay at the intersection by 1.3 seconds in both the AM and PM peak hours. It take a 2 second increase in delay for intersections operating at LOS E or F for the improvements to be required. Since the proposed project’s increase in delay at these intersections is less than 2.0 seconds, no improvements are required.

Near-Term (Year 2025) Segment Analysis
Table 3.7-10 summarizes the segment operations throughout the study area for the Near -Term Year 2025 Base and Near-Term Year 2025 Base + Project conditions. As shown in Table 3.7-10, all of the study area segments are calculated to operate acceptably at LOS C without t he project . With the

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addition of project traffic, all of the study area segments would continue to operate at LOS C or better and no segment improvements would be required.

Table 3.7-10. Near-Term Year 2025 Roadway Segment Operations Without and With Project Roadway Segment
Capacity
(LOS E)
(1)
Year 2025 Base
Condition
Year 2025
Base + Project
Condition Δ(5)
Consistent
with City
LOS
Standards? ADT(2) V/C(3) LOS(4) ADT V/C LOS
Mission
Road
Rancho
Santa Fe
Road to Las
Posas Road
40,000 15,390 0.385 B 15,510 0.388 B 0.003 Yes
Las Posas
Road to
Knoll Road
40,000 21,266 0.532 C 21,368 0.535 C 0.003 Yes
Las Posas
Road
Mission
Road to SR-
78 WB
Ramps
60,000 33,637 0.561 B 34,607 0.577 B 0.016 Yes
Mission
Road to
Grand
Avenue
60,000 43,651 0.728 C 44,261 0.738 C 0.010 Yes
Source: LLG 2024a.

Notes: (1) Capacities based on San Marcos Roadway Classification and LOS table. See Appendix B of EIR Appendix O. (2) ADT = Average Daily Traffic
(3) V/C = Volume to Capacity
(4) LOS = Level of Services
(5) Denotes a project-induced increase in the volume to capacity ratio (6) City of San Marcos strives to maintain roadway segments operations based on LOS standards (LOS D or better) as outlined in the General Plan Mobility Element.

Local Transportation Analysis of Horizon Year 2050 Conditions Year 2050 Network Conditions
The Long-Term (Horizon Year 2050) street network in the SANDAG ABM2+ Year 2050 model includes the roadways built to their City Mobility Element Classification. For the Year 2050 analysis, no changes to the study area roadway geometry or intersection control were assumed.

To obtain future ADTs for Long -Term (Horizon Year 2050) conditions, the forecasted Year 2050 ADT volumes were used to calculate peak hour volumes based partially on the existing relationship between ADT and peak hour volumes.

Horizon Year 2050 Intersection Analysis
Table 3.7-11 summarizes the intersection operations throughout the study area for the Horizon Year 2050 Base and Horizon Year 2050 Base + Project conditions.

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Table 3.7-11. Horizon Year (2050) Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour
Year 2050
Base Conditions
Year 2050
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.

Delay
(sec.)(1)
LOS(2)
Avg.

Delay
(sec.)(1)
LOS(2)
1 Mission Road/
Rancho Santa Fe
Road
Signal
AM 34.4 C 34.4 C 0.0 Yes
PM 37.3 D 37.5 D 0.2 Yes
2 Mission Road/
Pacific Street Signal
AM 35.3 D 35.6 D 0.3 Yes
PM 75.0 E 76.4 E 1.4 Yes
3 Mission Road/ Las
Posas Road Signal
AM 58.9 E 59.4 E 0.5 Yes
PM 75.0 E 75.7 E 0.7 Yes
4 Mission Road/
Knoll Road Signal
AM 64.8 E 65.4 E 0.6 Yes
PM 71.4 E 71.6 E 0.2 Yes
5 Armorlite Drive/
Las Posas Road Signal
AM 32.1 C 46.9 D 14.8 Yes
PM 29.0 C 35.4 D 6.4 Yes
6 Armorlite Drive/
Project Driveway
(5)
DNE
TWSC
AM -- -- 10.3 B -- Yes
PM -- -- 10.0 A -- Yes
7 Las Posas
Road/Descanso
Avenue
Signal
AM 164.5 F 165.5 F 1.0 Yes
PM 161.4 F 162.5 F 1.1 Yes
8 Las Posas Road/
SR-78 Westbound
Ramp
Signal
AM 74.1 E 75.4 E 1.3 Yes
PM 80.7 F 82.5 F 1.8 Yes
9 Las Posas Road/
Grand Avenue Signal
AM 152.6 F 153.9 F 1.1 Yes
PM 202.9 F 203.1 F 0.2 Yes
10 Grand Avenue/ SR-
78 Eastbound
Ramp
Signal
AM 47.8 D 52.5 D 4.7 Yes
PM 52.4 D 54.5 D 2.1 Yes
Source: LLG 2024a.

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Notes: (1) Average Delay expressed in seconds per vehicle (2) LOS = Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) Intersection does not exist under Year 2025 Base condition As shown in Table 3.7-11, in the Horizon Year 2050 Base condition, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of the following intersections:
• Mission Road/Pacific Street – LOS E (PM Peak Hour)
• Mission Road/Knoll Road – LOS E (AM and PM Peak Hours) • Mission Road/Las Posas Road – LOS E (AM and PM Peak Hours) • Las Posas Road/Descanso Avenue – LOS F (AM and PM Peak Hours) • Las Posas Road/SR-78 Westbound Ramps – LOS E (AM Peak Hour) and LOS F (PM Peak Hour) • Las Posas Road/Grand Avenue – LOS F (AM and PM Peak Hours) With the addition of project traffic (Base + Project condition) the following intersections would continue to operate at below an acceptable LOS:
• Mission Road/Pacific Street – LOS E (PM Peak Hour)
• Mission Road/Knoll Road – LOS E (AM and PM Peak Hours) • Mission Road/Las Posas Road – LOS E (AM and PM Peak Hours) • Las Posas Road/Descanso Avenue – LOS F (AM and PM Peak Hours) • Las Posas Road/SR-78 Westbound Ramps – LOS E (AM Peak Hour) and LOS F (PM Peak Hour) • Las Posas Road/Grand Avenue – LOS F (AM and PM Peak Hours) The addition of traffic from the proposed project would increase the delay at these intersections, ranging from 0.2 to 1.8 seconds, depending on the intersection and the peak hour. It take a 2 second increase in delay for intersections operating at LOS E or F for the improvements to be required. Since the proposed project’s increase in delay at these intersections is less than 2.0 seconds, no improvements are required.

Horizon Year 2050 Segment Operations
Table 3.7 -12 summarizes the segment operations throughout the study area for the Horizon Year 2025 Base and the Horizon Year 2050 Base + Project conditions. As shown in Table 3.7-12, all of the study area segments are calculated to operate acceptably at LOS C without the project . With the addition of project traffic, all of the study area segments would continue to operate at LOS C or better and no segment improvements would be required.

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Table 3.7-12. Near-Term Year 2025 Roadway Segment Operations Without and With Project Roadway Segment
Capacity
(LOS E)
(1)
Year 2050 Base
Condition
Year 2050
Base + Project
Condition Δ(5)
Consistent
with City
LOS
Standards? ADT(2) V/C(3) LOS(4) ADT V/C LOS
Mission
Road
Rancho
Santa Fe
Road to Las
Posas Road
40,000 16,160 0.404 B 16,280 0.407 B 0.003 Yes
Las Posas
Road to
Knoll Road
40,000 22,330 0.558 C 22,450 0.561 C 0.003 Yes
Las Posas
Road
Mission
Road to SR-
78 WB
Ramps
60,000 35,320 0.589 B 36,290 0.605 B 0.016 Yes
Mission
Road to
Grand
Avenue
60,000 45,830 0.764 C 46,440 0.774 C 0.010 Yes
Source: LLG 2024a.

Notes: (1) Capacities based on San Marcos Roadway Classification and LOS table. See Appendix B of EIR Appendix O. (2) ADT = Average Daily Traffic
(3) V/C = Volume to Capacity
(4) LOS = Level of Services
(5) Denotes a project-induced increase in the volume to capacity ratio (6) City of San Marcos strives to maintain roadway segments operations based on LOS standards (LOS D or better) as outlined in the General Plan Mobility Element.

Community Facility District (Congestion Management) Participation As a condition of project approval, the applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD2011-01 (Congestion Management).

Multiple Habitat Conservation Program
The project’s consistency with the MHCP is analyzed in Section 3.3, Biological Resources, of this EIR.

The analysis concludes that while the project is located within the MHCP, it is not located within a FPA as defined in the MHCP and Draft San Marcos Subarea Plan. Additionally, the project would not impact any sensitive habitat. The project, therefore, is consistent with the MHCP and Draft San Marcos Subarea Plan.

3.7.5 Cumulative Impact Analysis
As described in Section 3.7 of the EIR, while the project seeks approval of a General Plan Amendment and Rezone of the project site, the proposed project would be consistent with the overarching goals and policies of the City’s General Plan (see Table 3.7-7). In addition to the City’s General Plan, the proposed project would also be consistent with the City’s Municipal Code, SANDAG Regional Plan, and

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City of San Marcos Page 3.7-24
applicable plans and polices. Furthermore, as analyzed throughout Chapter 3, implementation of the proposed project would not result in any significant unavoidable impacts that could further impact land use.

All cumulative projects would be subject to similar criteria as the proposed project, which would ensure compliance with existing applicable land use plans with jurisdiction over the project area. Any cumulative projects that propose amendments to the Gene ral Plan or Zoning Ordinance would be required to show that proposed uses would not result in significant environmental impacts due to a conflict with applicable policies in a similar way as the proposed project. Since all current and future projects would be analyzed for compatibility and compliance with land use regulations prior to approval, cumulative impacts related to land use and planning are determined to be less than significant.

Regarding the LOS analysis for compliance with the City’s Mobility Element, the preceding analysis of the proposed project in Section 3.7.4 is based on methodologies that incorporate the cumulative effects of traffic from general growth and anticipated dev elopment in the area. This reflects background traffic and traffic from area-wide growth already approved by the City of San Marcos plus the development of the proposed project. As discussed in Section 3.7.4, the project would not result in any required ro adway or intersection improvements due to degraded LOS in the 2025 and 2050 time frames. Therefore, the project would not result in any inconsistencies with the goals and policies of the Mobility Element relating to LOS. Cumulative impacts would be less than significant.

3.7.6 Mitigation Measures
No land use impacts were identified; therefore, no mitigation measures are required.

3.7.7 Conclusion
The current General Plan land use and zoning designation is Public -Institutional (P -I). With the proposed GPA and Rezone to SPA, the proposed project would be consistent with the applicable goals and policies of the City’s General Plan. The project would a lso be consistent with the MHCP. Based upon the analysis presented in Sections 3.7.3 and 3.7.4, including Table 3.7-7, implementation of the proposed project would not conflict with any land use plan, policy, or regulation adopted for the purposes of avoid ing or mitigating an environmental effect. The analysis also included a detailed analysis to determine the proposed project’s consistency with the Mobility Element policies that address LOS. The proposed project would not result in any decreases in LOS to the studies roadways or intersection in the 2025 and 2050 timeframe. Impacts would be less than significant.

Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-25
Figure 3.7-1. Existing Conditions – Traffic Analysis Area

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Table 3.7-7. Project Consistency with Applicable San Marcos General Plan Goals and Policies General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Land Use and Community Design Element
Goal LU-1 Achieve a balanced distribution and compatible mix of land uses to meet the present and
future needs of all residents and the business
community.

The project would construct 165 residential apartments and 15% of the units would be affordable at the very low income level (30 to 50% of the Area Median Income or AMI). These units would add to the housing stock within the city and the greater North County area of San Diego and would meet the demand for future housing in the city, as contemplated by the City’s General Plan. The proposed 5,600 s.f. of commercial use compliments the residential use and provides for a compatible mix of land uses.

The project is consistent with this goal.

Goal LU-1,
Policy LU-1.1/
Goal EJ-1,
Policy EJ-1.1
Ensure that adjacent land uses complement
one another by considering compatibility of
activities, development patterns and
architectural character elements, and access
to various mobility choices.

The project area is developed with a mix of residential, commercial and institutional uses and is near the Palomar College SPRINTER station stop. The proposed project, which includes residential and commercial uses, would be consistent with the development type in the vicinity which includes both multifamily residential (Palomar College SPRINTER Station and Marc San Marcos multifamily, as well as commercial uses. The project’s architectural design includes varied rooflines and facades to break up the bulk and scale of the building. Proposed materials include stucco walls, siding, stone veneer, metal and glass railings, metal or stucco awnings, decorative stucco frame and the use of decorative metal grills. The project is consistent with this policy.

Goal LU-1
Policy LU-1.3/
Goal EJ-1,
Policy EJ-1.2
Diversify land uses by providing mixed use land
uses in strategic locations within the City that
place housing adjacent to employment.

The project proposes a mixed-use development with residential and commercial uses. The project would add housing in an area that has existing residential and is located within the vicinity of Palomar College, as well as other commercial land uses.

The project places housing nearby an existing transit station, providing access to other areas with various employment opportunities. The project is consistent with this policy.

Goal LU-1,
Policy LU-1.4
Maintain the natural integrity of open space
preserves by ensuring development projects
are sensitively integrated along the edges of
preserved or protected areas.

The project site is a vacant, disturbed parcel, located in a developed portion of the city and is adjacent to development. There are no open space or protected areas adjacent to the project site. The project is consistent with this policy.

Goal LU-2 Promote development standards and land use
patterns that encourage long-term
environmental sustainability.

The project has been designed to maximize the residential density on a parcel in a developed portion of the city and adjacent to Las Posas Road and W. Mission Road which are served by bus service. The project is also adjacent to a SPRINTER rail

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy station. Developing housing near bus and transit stops encourages long-term environmental sustainability. The project complies with the City CAP, which includes measures to enhance project sustainability. Based upon the analysis in this EIR, the project would reduce all significant impacts to below a level of significance through the incorporation of mitigation measures. The project is consistent with this goal.

Goal LU-2,
Policy LU-2.1/
Goal EJ-1,
Policy EJ-1.3
Promote compact development patterns that
reduce air pollution and automobile
dependence and facilitate walking, bicycling,
and transit use.

The project proposes a residential based density of 67 units/acre. The project site is located within the SM-6 Mixed Use Transit Corridor as identified in the SANDAG Smart Growth Concept Map for North County and is adjacent to the SPRINTER Palomar College Station stop, bus stops, and pedestrian infrastructure. The proposed project is consistent with this policy.

Goal LU-2,
Policy LU-2.2
Encourage new development to be sited to
respond to climatic conditions, such as solar
orientation, wind, and shading patterns.

The project would comply with the latest applicable Title 24 standards (e.g., installation of rooftop PV solar, use of electric tank water heater, EV charging stations, shade trees etc.). The 2022 Title 24 standards required that all low-rise residential buildings shall have a photovoltaic system meeting the minimum qualification requirements such that annual electrical output is equal to or greater than the dwelling’s annual electrical usage. The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. The project will comply with this policy.

Goal LU-2,
Policy LU 2.3
Require the incorporation of green building
practices, technologies, and strategies into
development projects per code standards.

The project incorporates green features. As a design feature, the project would install 13 Level 2 electric vehicle (EV) spaces, 62 EV ready spaces and 25 EV capable spaces. The landscaping plan focuses on native, drought tolerant species and meets the City’s Water Efficiency Landscaping Ordinance and Municipal Code, Title 20. This minimizes the use of water for irrigation. The project has also been designed to meet current California Building Code requirements as related to green building practices.

The project is consistent with this policy.

Goal LU-2,
Policy LU-2.5
Promote landscaping (e.g., native, drought-
tolerant plants) that minimizes demands on
water supply.

The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes low and moderate water use species. Proposed tree species include: golden rain tree, Chinese pistache, fern pine, African suman, Japanese zelkova, Chitalpa, king palm, queen palm, Marina strawberry tree, gold medallion tree, desert museum palo verde, Brisbane box, swan hill fruitless olive, Mexican palo verde, tree aloe, eastern redbud, western redbud and crape myrtle. The proposed project would also comply with the City’s Model Water

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20. The landscape concept plan is included as Figure 2-4 and the complete landscape plan and planting palette is included in Appendix A.3. The project is consistent with this policy.

Goal LU-2,
Policy LU-2.7/
Goal EJ-1,
Policy EJ-1.5
Promote the installation of trees to reduce the
urban heat island effect and green
infrastructure to reduce storm water runoff.

The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes low and moderate water use species. Shade trees will reduce the urban heat island effect and help with stormwater runoff. Approximately 23% of the project site would be landscaped.

Proposed tree species include: golden rain tree, Chinese pistache, fern pine, African suman, Japanese zelkova, Chitalpa, king palm, queen palm, Marina strawberry tree, gold medallion tree, desert museum palo verde, Brisbane box, swan hill fruitless olive, Mexican palo verde, tree aloe, eastern redbud, western redbud and crape myrtle. The proposed project would also comply with the City’s WELO and Municipal Code, Title 20. The landscape concept plan is included as Figure 2-4. As discussed in greater detail in Section 5.6 (Hydrology/Water Quality) the project incorporates biofiltration features and source control and site design best management practices (BMPs) to reduce storm water runoff. The project is consistent with this policy.

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

The project’s internal pedestrian circulation network would connect to the existing sidewalk along the project frontage on Armorlite Drive and would provide a connection between the project site and the Palomar College SPRINTER station and bus stops on Las Posas Road. There is a bicycle lane that runs along the project frontage and the site is adjacent to the SPRINTER transit stop at Palomar College.

The project is consistent with this goal.

Goal LU-3,
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.

The project’s internal pedestrian circulation network would connect to the existing sidewalk along the project frontage on Armorlite Drive and would provide a connection between the project site and the Palomar College SPRINTER station and bus stops on Las Posas Road. There is a bicycle lane that runs along the project frontage and the site is adjacent to the SPRINTER transit stop at Palomar College.

The project is consistent with this policy.

Goal LU-3,
Policy LU-3.4/
Goal EJ-5,
Policy EJ-5.1
Provide non-motorized (pedestrian and bicycle)
access/circulation within, and to, mixed-use
centers to reduce reliance on the automobile.

The project includes internal walkways that would connect to sidewalk on Armorlite Drive and would provide a connection between the project site and the Palomar College SPRINTER station and bus stops on Las Posas Road. The commercial mixed- use component would provide additional commercial opportunities for area

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-29
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy residents. The project is also walkable to other mixed-use and commercial uses in the project vicinity. The project is consistent with the policy.

Goal LU-3,
Policy LU-3.5/
Goal EJ-5,
Policy EJ-5.2
Provide an interconnected open space system
that is accessible to the public, including
pedestrian and equestrian links, bicycle paths,
multi-use trails, recreation areas, and drainage-
ways.

The project incorporates 34,894 s.f. of common outdoor open space. The project incorporates pedestrian walkways which would connect to the City’s larger pedestrian and bicycle network. There are no public use trails in the project vicinity. The project is consistent with this policy.

Goal LU-5 Promote community design that produces a
distinctive, high-quality built environment with
forms and character that create memorable
places and enrich community life.

The project has been designed to incorporate architectural treatments, including varied rooflines to enhance the appearance of the project. This includes building articulation and setbacks and varied rooflines. Proposed materials include stucco walls, siding, stone veneer, metal and glass railings, metal or stucco awnings, decorative stucco frame and the use of decorative metal grills. The conceptual landscape plan provides for a mix of trees, shrubs, and groundcover to further enhance the look and feel of the project. The project is consistent with this goal.

Goal LU-5,
Policy LU-5.4
Require building and site design that respects
the natural topography and iconic ridgelines
that serve as the visual backdrop for San
Marcos.

The project has been designed to respect the existing topography on the site, which is relatively flat. No primary or secondary ridgelines are located within or adjacent to the project site. The nearest primary ridgeline is within the North City Area #1 map and includes Owens Peak and “P” Mountain. This primary ridgeline is located approximately 1.25 miles northeast of the project site. The project is consistent with this policy.

Goal LU-5,
Policy LU-5.7
Architecture shall be enhanced with high-end
building materials, varied roof lines, and
decorative details.

The project incorporates high-quality design. The project design incorporates architectural treatments and design to break up the bulk and scale of the buildings.

This includes building articulation and setbacks and varied rooflines. Proposed materials include stucco walls, siding, stone veneer, metal and glass railings, metal or stucco awnings, decorative stucco frame and the use of decorative metal grills.

The project is consistent with this policy.

Goal LU-7 Direct and sustain growth and expansion in
areas of San Marcos that can support a
concentration of a variety of uses and are
particularly suitable for multimodal
transportation and infrastructure expansion
and improvements.

The project site is within the City of San Marcos, surrounded by existing development including commercial and residential uses. Existing services and utilities are present in proximity to the project. The project is in proximity to transit and provides si dewalks to encourage non-motorized transportation. The project is consistent with this goal.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-30
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-7,
Policy LU-7-2/
Goal EJ-5,
Policy EJ-5.3
Coordinate pedestrian, transit and
infrastructure upgrades with infill and
redevelopment opportunities.

The project is in proximity to transit including the Palomar College Station SPRINTER station and the Palomar College Transit Center. The project will connect to existing pedestrian and bicycle infrastructure which provides access to these transit stations.

The project is consistent with this goal.

Goal LU-8 Ensure that existing and future development is adequately serviced by infrastructure and
public services.

As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for fire and police protection services would be offset with payment of appropriate development fees, including payment of Public Facility Fees (PFF) and annexation into and participation in applicable Community Facilities Districts (CFD). Impacts to parks would be offset through provision of on-site recreational facilities and payment of PFF. Additionally, as analyzed in Section 3.13 (Utilities and Service Systems) water and sewer services are available to serve the project and the project would either upgrade
Vallecitos Water District (VWD) facilities, pay applicable Water and Wastewater Capital Facility Fees to VWD per Ordinances Nos. 175 and 176 or a combination of upgrades and fees at an equitable level. The project is consistent with this goal.

Goal LU-8,
Policy LU-8.1
New development shall pay its fair share of
required improvements to public facilities and
services.

As described further in Section 3.10 (Public Services), the project’s demand for fire and police protection services would be offset with payment of appropriate CFD and PFF fees. The project is also required to pay appropriate statutory fees for schools, which would ensure impacts to schools are less than significant. Additionally, as analyzed in Section 3.12 (Utilities and Service Systems) water and sewer services are available to serve the project and the project would either upgrade VWD facilities, pay applicable Water and Wastewater Capital Facility Fees to VWD per Ordinances Nos. 175 and 176 or a combination of upgrades and fees at an equitable level. The project is consistent with this goal.

Goal LU-10 Fire protection, emergency services, and law enforcement: Provide effective, high-quality,
and responsive services.

As described further in Section 3.10 (Public Services), the project impacts related to fire protection, emergency services and law enforcement were determined to be less than significant. The project’s demand for fire and law enforcement services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. The project is consistent with this goal.

Goal LU-10,
Policy LU-10.1
Provide demand-based firefighting and
emergency medical services infrastructure,
As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-31
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy equipment, and personnel to provide a high
level of fire, emergency medical, and law
enforcement service in San Marcos to meet
existing and future demands.
fire services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. The project is consistent with this policy.

Goal LU-10,
Policy LU-10.2
Work closely with the County of San Diego
Sherriff’s Department to determine and meet
the community needs for adequate personnel,
equipment, and state-of-the-art technology to
effectively combat crime, and meet existing
and projected service demands.

As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for police protection services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. The project is consistent with this policy.

Goal LU-10,
Policy LU-10.3
Continue to conduct Public Outreach and
education regarding fire safety and crime
prevention within San Marcos.

The San Marcos Fire Department public education program provides comprehensive fire education via presentations, informational demonstrations, health fairs, and station tours, among others. The San Diego County Sheriff's Department provides safety presentations to youth groups and community groups through their Community Oriented Policing and Problem Solving deputies. Deputies also attend Neighborhood Watch meetings. In addition, the Crime Prevention Unit focuses on community outreach regarding crime prevention techniques, current trends, and prevention education. The project's annexation into and contribution to the applicable CFD would aid in the continued provision of these services. The project is consistent with this policy.

Goal LU-11 Schools: Ensure all residents have access to high-quality education.

The project site is within the attendance boundaries of La Mirada Academy for grades TK-8 and San Marcos High School for grades 9-12. SMUSD allows for intra district transfers, and students could attend other schools. The project applicant would be required to pay all applicable development fees including payment of school mitigation fees, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal Code Section 17.52.050, The project is consistent with this goal.

Goal LU-11,
Policy LU-11.1
Collaborate with the local public school district
(SMUSD), private schools, and institutions of
higher learning to ensure a range of traditional
and distance-learning educational
opportunities are provided in superior,
The project would generate 39 students for San Marcos Unified School District (SMUSD). The project developer would pay school mitigation fees to offset impacts to schools. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-32
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy accessible facilities that complement the
surrounding land uses.

Goal LU-11,
Policy LU-11.2
Work with San Marcos Unified School District
and developers to ensure adequate school
facilities are funded as required by State law
and through developer mitigation agreements
between the school district and the developer.

The City shall require a “will serve” letter
substantiating that the developer has paid fees
to the satisfaction of the school district prior to
issuance of building permits.

The project would generate 39 students for SMUSD. The project developer/applicant would pay school mitigation fees to offset impacts to schools and provide a letter to the City showing proof of payment. The project is consistent with this policy.

Goal LU-12 Libraries: Provide library resources and
services that meet the needs of the
community.

While the proposed project does not include construction of any library facilities, this EIR has determined the project would not have a significant impact on library facilities (see Section 3.10, Public Services). The project is consistent with this goal.

Goal LU-12,
Policy LU-12.1
Provide adequate library facilities and
technological access that enhance San
Marcos’s quality of life and create a civic
environment with vast opportunities for self-
learning and academic enrichment.

While the proposed project does not include construction of any library facilities, this EIR has determined the project would not have a significant impact on library facilities (see Section 3.10, Public Services). Additional library resources are also available to the community through California State University San Marcos (CSUSM) and Palomar Community College. The project is consistent with this policy.

Goal LU-12,
Policy LU-12.2
Accommodate technology needs of the
community and locate accessible technology in
the library.

While the proposed project does not include construction of any library facilities, project residents would have access to public computers through the existing library facilities. The project does not conflict with this policy.

Goal LU-13 Water Service and Supply: Manage and
conserve domestic water resources by reducing
water usage and waste on a per capita basis,
to ensure an adequate water supply for existing
and future residents.

The landscape plan for the project focuses on low-water use, native species. The Landscape Plan is presented in Figure 2-3. The proposed landscaping plan conforms to strict water conservation measures, including the City’s WELO. Additionally, the project is required to pay Water Capital Facility Fees to VWD. The project is consistent with this goal.

Goal LU-13,
Policy LU-13.1
Work closely with local and regional water
providers to ensure high quality water supplies
are available for the community.

VWD treats water to meet stringent state and federal standards. Ensuring quality at the source is cheaper than treatment. As described in Section 5.6 (Environmental Effects Found Not to be Significant - Hydrology/Water Quality), the project would not contribute significant polluted runoff due to the incorporation of bioretention and water quality BMPs. Therefore, the project would not impact any local or regional water supplies. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-33
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-13,
Policy LU-13.2
Actively promote water conservation programs
aimed at reducing demand.

VWD promotes conservation and has issued drought alerts under drought conditions.

While not currently in effect, future residential users within this district would be required to comply with any drought alerts and required conservation measures that would reduce demand. The project also incorporates low-water landscaping and would be required to comply with the City’s WELO and CalGreen standards aimed at water conservation and the reducing the demand for water. The project is consistent with this policy.

Goal LU-14 Wastewater: Ensure an adequate wastewater
system for existing and future development.

Based on the analysis in Section 3.13 (Utilities and Service Systems), there is currently adequate wastewater treatment capacity to serve the project. VWD periodically updates their master plan to ensure that long-term treatment capacity is available to match future demand For sewer service, the proposed project would connect to the existing 8- inch sewer main in Armorlite Drive. The project proposes to upsize approximately 539 feet of the existing 8-inch sewer main in Armorlite Drive to 10-inch diameter main (Pipe Segments AL-1 through AL-3). The project applicant would also pay VWD Wastewater Capital Facility Fees for portions of the improvements. The project is consistent with this goal.

Goal LU-14,
Policy LU-14.1
Work closely with local service providers to
ensure an adequate wastewater system for
existing and future development is in place.

Based on the analysis in Section 3.13 (Utilities and Service Systems), there is currently adequate wastewater treatment capacity to serve the project. VWD periodically updates their master plan to ensure that long-term treatment capacity is available to match future demand. For sewer service, the proposed project would connect to the existing 8- inch sewer main in Armorlite Drive. The project proposes to upsize approximately 539 feet of the existing 8-inch sewer main in Armorlite Drive to 10-inch diameter main (Pipe Segments AL-1 through AL-3). The project applicant would also pay VWD Wastewater Capital Facility Fees for portions of the improvements. The project is consistent with this policy.

Goal LU-14,
Policy LU-14.2
Ensure development approval is directly tied to
commitments for the construction or
improvement of primary water, wastewater,
and circulation systems.

Based on the analysis in Section 3.13 (Utilities and Service Systems), there is currently adequate water and wastewater treatment capacity to serve the project.

VWD periodically updates their master plan to ensure that long-term treatment capacity is available to match future demand. The project proposes to upsize approximately 223 feet of 8-inch water main to a 10-inch diameter main and approximately 539 feet of the existing 8-inch sewer main in Armorlite Drive to 10-inch diameter main. The project would also pay Water Capital Facility Fees to VWD and Wastewater Capital Facility Fees to VWD. No circulation network improvements are required for the proposed project. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-34
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-15 Flood control and storm water drainage
facilities: ensure adequate flood control and
storm water drainage is provided by the
community.

As identified in Section 5.6 (Hydrology/Water Quality), off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. Therefore, implementation of the project would not impact flood control or storm water drainage facilities. The project is consistent with this goal.

Goal LU-15,
Policy LU-15.1
Implement activities, practices, procedures, or
facilities that avoid, prevent, or reduce
pollution of the San Marcos Storm Water
Conveyance System and receiving waters.

As identified in Section 5.6 (Hydrology/Water Quality), the project would utilize two proprietary treatment facilities (e.g., Modular Wetland System or approved equal) and an underground storage vault beneath the parking lot to regulate stormwater discharge rates and provide a water quality treatment benefit. The project is consistent with this policy.

Goal LU-15,
Policy LU-15.2
Improve inadequate or undersized
drainage/flood control facilities to solve both
small neighborhood and large regional
drainage and flood control problems.

As identified in Section 5.6 (Hydrology/Water Quality), off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. No inadequate or undersized drainage/ flood control facilities were identified that serve the project area.

Therefore, implementation of the project would not impact flood control or storm water drainage facilities. The project is consistent with this policy.

Goal LU-15,
Policy LU-15.3
Avoid, to the extent possible, development in
floodplain and flood prone areas.

As identified in the Initial Study prepared for the proposed project (Appendix B.1), the project was determined to have no impact on 100-year flood hazards. The project does not propose development within a floodplain or flood prone area. The project is consistent with this policy.

Goal LU-15,
Policy LU-15.4
Retain drainage courses in their natural
condition, to the extent possible. Consider
smaller-scale drainage improvements to
protect the environment and avoid disturbing
natural drainage courses; consider detention
areas and raised building pads.

The project is adequately designed such that it would not substantially alter the existing drainage pattern of the site or area. The project detains and retains runoff through the site with combined water quality and hydromodification bioretention and BMPs. The project is consistent with this policy.

Goal LU-16 Solid waste: reduce the amount of waste
material entering regional landfills with an
efficient and innovative waste management
program.

As discussed in Section 3.13. (Utilities and Service Systems), the City of San Marcos is in compliance with AB 939 and AB 341, which requires not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter. The City is meeting these targets and the project would participate in the City’s recycling and composting efforts. The project is consistent with this goal.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-35
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-16,
Policy LU-16.1
Work closely with local service providers to
ensure adequate solid waste disposal,
collection, and recycling services.

Non-recyclable waste, including general trash and green materials, would be collected and transported for disposal by EDCO, a licensed hauler. The project is consistent with this policy.

Goal LU-16,
Policy LU-16.2
Increase recycling, composting, source
reduction, and education efforts throughout the
city to reduce the amount of solid waste
requiring disposal at landfills.

The City of San Marcos is in compliance with AB 939, which requires 50% waste diversion through recycling. The project will provide recycling bins to facilitate recycling among future residents. The project is consistent with this policy.

Goal LU-17 Utilities and Communications: Encourage
provision of power and communication systems
that provide reliable, effective, and efficient
services for San Marcos.

As discussed in Section 3.13 (Utilities and Service Systems) communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. However, no specific systems upgrades are proposed with this project, and the location and extent of future facilities is not known at this time. The project would be served by San Diego Gas & Electric (SDG&E) for electricity and gas service. The design for the dry utilities’ connection is still under preparation, however the project proposes to connect to existing infrastructure within Armorlite Drive. The project is consistent with this goal.

Policy LU-17.2 Require all new development and
redevelopment to provide the technology to
support multiple telecommunications facilities
and providers such as multi-media products,
wireless technologies, and satellite
communications.

As discussed in Section 3.13 (Utilities and Service Systems) communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. However, no specific systems upgrades are proposed with this project, and the location and extent of future facilities is not known at this time. The project would be served by SDG&E for electricity and gas service. The design for the dry utilities’ connection is still under preparation, however the project proposes to connect to existing infrastructure within Armorlite Drive. The project is consistent with this policy.

Policy LU-17.3 The City shall prohibit above ground utility equipment within any of the pedestrian
pathway and street frontage areas. All above
ground utilities shall be placed either within;
“wet closets” within the buildings, underground
vaults, or behind buildings where they are not
visible. The developer shall be responsible to
contact the applicable utility agencies in
As discussed in Section 3.13 (Utilities and Service Systems) communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. However, no specific systems upgrades are proposed with this project, and the location and extent of future facilities is not known at this time. Any above-ground utilities would be placed within “wet closets” within the buildings or underground vaults, or behind buildings where they are not visible, per the requirements of this policy. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-36
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy advance to coordinate utilities prior to approval
of the final street improvement plans for both
public and private street frontages and prior to
submittal of building permits.

Mobility Element
Goal M-1 Provide a comprehensive multimodal
circulation system that serves the City land
uses and provides for the safe and effective
movement of people and goods.

Internal circulation within the project would connect to the existing sidewalk along Armorlite Drive. The proposed project does not require any offsite roadway improvements, and would not adversely affect the existing multimodal circulation system that serves the city land uses. The project is consistent with this goal.

Goal M-1,
Policy M-1.1
Safely and efficiently accommodate traffic
generated by development and redevelopment
associated with implementation of the General
Plan Land Use Policy Map.

Based upon the traffic analyses prepared for the project by LLG (2024a and 2024b), the project does not result in any transportation impacts, nor does it result in any safety concerns. The project is consistent with this policy.

Goal M-1,
Policy M-1.2
Require new development to finance and
construct internal adjacent roadway circulation
and City-wide improvements as necessary to
mitigate project impacts, including roadway,
transit, pedestrian, and bicycle facilities.

The project has been designed to include an internal drive aisle. No private streets are proposed. The project does not result in any significant transportation related impacts and no improvements beyond what is already proposed as part of the project design are required. The project is consistent with this policy.

Goal M-1,
Policy M-1.3/
Goal EJ-1,
Policy EJ-1.6
Require new developments to prepare and
implement Transportation Demand
Management (TDM) programs to minimize
vehicle trip generation and promote alternative
modes of travel within the City. (See Policy M-

1.3)
The project would be required to prepare a TDM plan consistent with the reports of Measure T-9 of the City’s CAP Consistency Review Checklist. Per the CAP Checklist, the project will provide a transit discount, designation parking, pedestrian connections, bicycle space and a space for telecommuting. The project is consistent with this policy.

Goal M-1,
Policy M-1.4
Utilize multi-modal LOS techniques to evaluate
transportation facilities. For identified
prioritized modes (based on facility typology),
provide the following minimum LOS as shown
in Table 3-4 of the Mobility Element: LOS D or
better for Vehicles as a prioritized mode or the
City shall allow for flexible LOS where
The location transportation analysis prepared for the project (Appendix O) relied on this LOS technique to determine project-related impacts to the circulation network. As summarized in Section 3.7.4 (Land Use and Planning) of this EIR, there would not be any degradation of LOS to below acceptable levels with implementation of the project. The project would be consistent with this goal/policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-37
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy warranted (e.g., accepting a lower LOS than
identified above).

Goal M-1,
Policy M-1.6/
Goal EJ-2,
Policy EJ-2.10
Work to improve connectivity within the City by
closing gaps in the existing bicycle, pedestrian,
trail, transit, and roadway network. Work with
new development to provide connectivity and
redundancy in the mobility network.

The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network. There is an existing sidewalk along the project frontage on Armorlite Drive. The project is consistent with this policy.

Goal M-1,
Policy M-1.7/
Goal EJ-2,
Policy EJ-2.11
Strive to ensure that streets within San Marcos
shall be complete streets where feasible;
thereby providing accessibility, safety,
connectivity, and comfort for all modes and
users of the system. Appropriate new local
streets and Main Streets will prioritize
pedestrian and bicycle users through the
corridor.

Complete streets balance the needs of all users, both motorized and non-motorized, in design and construction. Armorlite Drive in front of the project site is constructed as a complete street. The project includes pedestrian pathways that would connect to the existing pedestrian and bicycle network. The project is consistent with this policy.

Goal M-2 Protect neighborhoods by improving safety for
all modes of travel and calming traffic where
appropriate.

Travel modes within and surrounding the project area include vehicular, pedestrian, and bicycle. The SPRINTER rail station is also located near the project site. The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network. The project is consistent with this policy.

Goal M-2,
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.

The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network on Armorlite Drive. The project is consistent with this policy.

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

The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network on Armorlite Drive. The project site is also near the SPRINTER rail station. As a design feature the project would install EV chargers. The project is consistent with this goal.

Goal M-3,
Policy M-3.1/
Goal EJ-1,
Policy EJ-1.8
Develop an integrated, multimodal circulation
system that accommodates transit, bicycles,
pedestrians, and vehicles; provides
opportunities to reduce air pollution and
The placement of high density residential along a transit corridor would provide for convenient nearby transit access to future residents of the project. The project site fronts Class I multi-use path, and sidewalks are provided to the nearby bus stops and the SPRINTER rail station. Therefore, the project site is already served by integrated,

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-38
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy greenhouse gas emissions; and reinforces the
role of the street as a public space that unites
the City.
multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles. Therefore, the project is consistent with this policy.

Goal M-3,
Policy M-3.2
Improve safety conditions, efficiency, and
comfort for bicyclists and pedestrians through
design, maintenance, and law enforcement.

Install wider sidewalks and curb extensions at
pedestrian crossings (bulb outs) where
appropriate.

The project would not impact any existing bicycle or pedestrian infrastructure. The project’s circulation network would connect to the existing pedestrian and bicycle infrastructure on Armorlite Dive. Therefore, the project is consistent with this policy.

Goal M-3,
Policy M-3.3
Provide a pedestrian and bicycle network in
existing and new neighborhoods that facilitates
convenient and continuous pedestrian and
bicycle travel free of major impediments and
obstacles.

The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network. The project is consistent with this policy.

Goal M-3,
Policy M-3.5/
Goal EJ-5,
Policy EJ-5.5
Ensure that streets in areas with high levels of
pedestrian activity (such as employment
centers, residential areas, mixed use areas,
and schools) support safe pedestrian travel by
providing detached sidewalks, bulb-outs,
enhanced pedestrian crossings, pedestrian
bridges, and medians.

The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network. The project is consistent with this policy.

Goal M-3,
Policy M-3.9/
Goal EJ-5,
Policy EJ-5.6

Create a pleasant walking environment for
roadway typologies where pedestrian travel is
prioritized. This includes providing shade trees,
landscaping, benches, pedestrian-scale
lighting, way finding signage, transit shelters,
and other appropriate amenities.

The project includes internal pedestrian pathways that would connect to the existing pedestrian and bicycle network. The landscape concept plan includes street trees along the project’s frontage with Armorlite Drive and internal to the project. The project is consistent with this policy.

Conservation and Open Space Element
Goal COS-1 Identify, protect, and enhance significant
ecological and biological resources within San
Marcos and its adaptive Sphere of Influence.

A biological technical report (Appendix D) was prepared for the project and summarized in Section 3.3. (Biological Resources). The project site contains Diegan coastal sage scrub and non-native grassland. No sensitive species were identified on the project site. Implementation of mitigation measures MM-BIO-1 through MM-BIO-3

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-39
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy would reduce impacts to biological resources to below a level of significance. The project is consistent with this goal.

Goal COS-1,
Policy COS-1.1
Support the protection of biological resources
through the establishment, restoration, and
conservation of high-quality habitat areas.

A biological technical report (Appendix D) was prepared for the project and summarized in Section 3.3 (Biological Resources). The project will mitigation for impacts to Diegan coastal sage scrub and nonnative grassland through off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof. The project is consistent with this policy.

Goal COS-1,
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.

No oak woodlands, jurisdictional wetlands, or habitat linkages occur on the project site (Dudek 2025 2024). The project is consistent with this policy.

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.

The project site is an undeveloped parcel in a developed portion of the city and has been identified for development in the City’s General Plan. The project site does not support any agricultural resources. The project is consistent with this policy.

Goal COS-2,
Policy COS-2.1
Provide and protect open space areas
throughout the City for its recreational,
agricultural, safety, and environmental value.

A total of 47,375 s.f. of open space is proposed. This includes a mix of common open space and private open space. These areas would provide recreation for the future residents. The project is consistent with this policy.

Goal COS-2,
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.

The project site is an undeveloped parcel in a developed portion of the city and has been identified for development in the City’s General Plan. The project would not result in the conversion of open space land. he project is consistent with this policy.

Goal COS-2,
Policy COS-2.5
Continue to review future development
proposals to ensure that cultural resources
(including prehistoric, historic, paleontological,
The proposed project’s potential impacts to cultural resources are detailed in Section

3.4 (Cultural Resources) and potential impacts to tribal cultural resources are addressed in Section 3.12 (Tribal Cultural Resources) of the EIR. A cultural resources

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-40
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy and SB 18 Tribal resources) are analyzed and
conserved in compliance with CEQA
requirements.
report was also prepared for the project. The City reached out to tribes consistent with the requirements of SB 18 and AB 52 and met with tribes that requested consultation. The project would implement cultural resources and tribal cultural resources mitigation measures to reduce impacts to below a level of significance. The project is consistent with this policy.

Goal COS-2,
Policy COS-2.6
Preserve healthy mature trees where feasible;
where removal is necessary, trees shall be
replaced at a ratio of 1:1.

There is one existing pepper tree on the southwest corner of the project site that would be removed to prepare the site for development. The project will implement a landscape plan which would provide replacement trees. Proposed tree species include: golden rain tree, Chinese pistache, fern pine, African suman, Japanese zelkova, Chitalpa, king palm, queen palm, Marina strawberry tree, gold medallion tree, desert museum palo verde, Brisbane box, Swan Hill fruitless olive, Mexican palo verde, tree aloe, eastern redbud, western redbud and crape myrtle. The project is consistent with this policy.

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

According to Section 3.1 (Aesthetics), the project has been designed to respect the existing topography on the site, which is relatively flat. Views of the surrounding hillsides would remain unobstructed from SR-78. The project site is not a protected scenic vista. The project also incorporates extensive design features that ensure that the visual character changes blend with the existing topography and surrounding development. The project is consistent with this goal.

Goal COS-3,
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.

None of the prominent landforms as identified in the General Plan are on-site. While implementation of the proposed project would result in changes in the viewshed, development would not alter or impede views of prominent landforms. Views to prominent landforms would remain unobstructed. In addition, the project site is not a protected scenic vista. The project is consistent with this policy.

Goal COS-3,
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.

According to Section 3.1 (Aesthetics), the Specific Plan includes an overall architectural design theme to ensure a pleasant, orderly, and visually appealing development. The proposed architectural design includes elevation treatments, varied rooflines, and a mix of materials. The project has been designed to respect the existing topography on the site. Landscape materials would be used to enhance architectural elements and the provided street trees would enhance the pedestrian experience along the project frontages. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-41
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-3,
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.

The project has been designed to respect the existing topography. The project site is relatively flat and located in a lower-elevation portion of the city. There are no view corridors in the project vicinity nor are there any wildlife corridors on the project site.

The project site is not identified as a scenic vista. The project is consistent with this policy.

Goal COS-3,
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.

Development of the proposed project would create new sources of light at a site that is currently undeveloped. Lighting would be guided by the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards to aid in the preservation of dark sky conditions. Lighting impacts were determined to be less than significant (Section 3.1 Aesthetics). The project is consistent with this policy.

Goal COS-4 Improve regional air quality and reduce GHG
emissions that contribute to climate change.

The project’s impact to air quality would be less than significant as described in Section 3.2 (Air Quality) of this EIR. The project would not conflict with or obstruct implementation of any air quality plan or violate any air quality standard. Based upon the analysis in Section 3.6 (Greenhouse Gas), GHG emissions under the proposed project would be 77% less than if the project was built out under the current General Plan Designation of Public-Institutional with a 160,000 s.f. data center. The project would also implement all of the applicable CAP Consistency Review Checklist (CAP Checklist) measures. The project is consistent with this goal.

Goal COS-4,
Policy COS-

4.1/ Goal EJ-1,
Policy EJ-1.9
Continue to work with the U.S. EPA, CARB,
SANDAG, and the SDAPCD to meet State and
federal ambient air quality standards.

Implementation of the proposed project would not exceed any air quality standard during construction or operation. Impacts are less than significant. The project is consistent with this policy.

Goal COS-4,
Policy COS-

4.3/ Goal EJ-1,
Policy EJ-1.11
Participate in regional efforts to reduce GHG
emissions.

The project is not anticipated to impair implementation of AB 32. Development of the project would not affect regional efforts to reduce GHG emissions. The City’s updated 2020 CAP quantifies community emissions, identifies emission reduction targets, and specifies climate action measures to reduce GHG emissions. Based upon the analysis in Section 3.6 (Greenhouse Gas), GHG emissions under the proposed project would be 77% less than if the project was built out under the current General Plan Designation of Public-Institutional with a 160,000 s.f. data center. The project would also implement all of the applicable CAP Checklist measures. The project is therefore consistent with the City’s CAP and the project would be consistent with the goals of AB 32. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-42
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-4,
Policy COS-

4.4/ Goal EJ-1,
Policy EJ-1.12
Quantify community wide and municipal GHG
emissions, set a reduction goal, identify, and
implement measures to reduce GHG emissions
as required by governing legislation.

The City’s updated 2020 CAP quantifies community emissions, identifies emission reduction targets, and specifies climate action measures to reduce GHG emissions.

Based upon the analysis in Section 3.6 (Greenhouse Gas), GHG emissions under the proposed project would be 77% less than if the project was built out under the current General Plan Designation of Public-Institutional with a 160,000 s.f. data center. The project would also implement all of the applicable CAP Checklist measures. The project is therefore consistent with the City’s CAP and the project would be consistent with the goals of AB 32. The project is consistent with this policy.

Goal COS-4,
Policy COS-

4.5/ Goal EJ-1,
Policy EJ-1.13
Encourage energy conservation and the use of
alternative energy sources within the
community.

As discussed in Section 3.13 (Utilities and Service Systems), the proposed project includes various on-site features and measures to reduce the proposed project’s energy consumption. Further, the proposed project would be required to be consistent with appropriate mandatory project design features in the CAP Consistency Review Checklist that would reduce operational electricity consumption.

The project would be built-in compliance with Title 24 requirements applicable at that time. Additionally, as a design feature, the project would install EV spaces. The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.

Goal COS-4,
Policy COS-4.6
Goal EJ-1,
Policy EJ-1.14
Promote efficient use of energy and
conservation of available resources in the
design, construction, maintenance and
operation of public and private facilities,
infrastructure, and equipment.

As discussed in Section 3.13 (Utilities and Service Systems), the proposed project includes various on-site features and measures to reduce the proposed project’s energy consumption. Further, the proposed project would be required to be consistent with appropriate mandatory project design features in the CAP Consistency Review Checklist that would reduce operational electricity consumption.

The project would be built-in compliance with Title 24 requirements applicable at that time. Additionally, as a design feature, the project would install EV spaces. The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.

Goal COS-4,
Policy COS-

4.8/ Goal EJ-1,
Policy EJ-1.15
Encourage and support the generation,
transmission, and use of renewable energy.

Development on the project site would meet the requirements of California’s Building Energy Efficiency Standards, which focus on several key areas to improve the energy efficiency of newly constructed buildings. The project has also been designed to meet current California Building Code requirements as related to green building practices.

The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-43
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-5 Reduce water consumption and ensure reliable water supply through water efficiency,
conservation, capture, and reuse.

VWD promotes conservation and has issued drought alerts under drought conditions.

Future residential users within this district would be required to comply with any issued alerts and required conservation measures that would reduce demand. The project proposes a landscape plan that emphasizes low water use species in adherence to the City of San Marcos Water Efficient Landscape Ordinance. The project is consistent with this goal.

Goal COS-6 Protect and restore appropriate surface water and groundwater beneficial uses through
prioritizing the improvement of locally impaired
water bodies within the City of San Marcos
subwatersheds.

The project is located within a watershed with numerous impaired water bodies. The BMP Design Manual requires that pollutants of concern for each impaired water body in the watershed be treated by engineered treatment controls to a medium pollutant removal efficiency or better prior to leaving the project site. The project proposes treatment of storm water runoff by constructing two treatment facilities, and an underground vault. Any groundwater infiltration would likely reach surface flows before reaching groundwater due to the approximate depth to groundwater.

Therefore, according to Section 5.6 (Hydrology/Water Quality), the project would not have a potentially significant adverse impact on groundwater quality or result in significant impacts to impaired water bodies. The project is consistent with this goal.

Goal COS-6,
Policy COS-6.2
Promote watershed stewardship as the
community norm.

The project includes a comprehensive water quality management approach, which incorporates two treatment facilities, an underground vault, and the use of BMPs, to ensure the project would not contribute any pollutants to area watersheds.

Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a Stormwater Pollution Prevention Plan, and implement BMPs in compliance with the National Pollution Discharge Elimination System (NPDES) permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would contribute to watershed stewardship. The project is consistent with this policy.

Goal COS-7 Achieve sustainable watershed protection for surface and ground water quality that balances
social, economic, and environmental needs.

The project includes a comprehensive water quality management approach, which incorporates two treatment facilities, an underground vault, and the use of BMPs, to ensure the project would not contribute any pollutants to area watersheds.

Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a
Stormwater Pollution Prevention Plan (SWPPP), and
implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would contribute to watershed stewardship. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-44
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-8 Focus watershed protection, surface and
groundwater quality management on sources
and practices that the City has the ability to
affect.

Implementation of the project’s comprehensive water quality management plan, which incorporates two treatment facilities, an underground vault, and the use of BMPs, would ensure that the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare an SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would reduce construction effects on receiving water quality and protect stormwater runoff. The project is consistent with this policy.

Goal COS-8,
Policy COS-8.4
Require new development and redevelopment
to protect the quality of water bodies and
natural drainage systems through site design,
source controls, storm water treatment, runoff
reduction measures, BMPs, LID,
hydromodification strategies consistent with
the Current San Diego RWQCB Municipal
Stormwater NPDES Permit, and all future
municipal stormwater permits.

Implementation of the project’s comprehensive water quality management plan, which incorporates two treatment facilities, an underground vault, and the use of BMPs, would ensure that the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare an SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would reduce construction effects on receiving water quality and protect stormwater runoff. The project is consistent with this policy.

Goal COS-10 Establish and maintain an innovative,
sustainable solid waste collection, recycling,
and disposal delivery system for present and
future generations.

As discussed in Section 3.13 (Utilities and Service Systems), the City of San Marcos is in compliance with AB 939 and AB 341, which requires not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter. The City is meeting these targets and the project would participate in the City’s recycling and composting efforts. The project is consistent with this goal.

Goal COS-10,
Policy COS-

10.1 Promote the curbside recycling program to
divert residential refuse from the landfills.

As discussed in Section 3.13 (Utilities and Service Systems), the City of San Marcos is in compliance with AB 939 and AB 341, which requires not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter . The City is meeting these targets and the project would participate in the City’s recycling and composting efforts. The project is consistent with this policy.

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-45
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-11 Continue to identify and evaluate cultural, historic, archaeological, paleontological, and
architectural resources for protection from
demolition and inappropriate actions.

A cultural resources report was prepared for the project site, summarized in Section

3.4 (Cultural Resources). Mitigation measures are incorporated (MM-CR-1a, MM-CR- 1b and MM-CR-2) to reduce potential impacts to cultural resources to below a level of significance. The project would not have the potential to impact paleontological resources. The project is consistent with this goal.

Goal COS-11,
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.

A cultural resources report was prepared for the project site, summarized in Section

3.4 (Cultural Resources). Mitigation measures are incorporated (MM-CR-1a, MM-CR- 1b and MM-CR-2) to reduce potential impacts to cultural resources to below a level of significance. The project is consistent with this policy.

Goal COS-11,
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 offsite, and/or photo-
preservation.

There are no historic structures on the project site, therefore the project would not have the potential to impact such resources. The project is consistent with this policy.

Parks, Recreation and Community Health Element
Goal PR-1 Plan for, acquire, develop, and maintain a
system of local parks connected through an
integrated network of trails and high quality
recreational facilities.

Section 5.12 (Recreation) analyzed the project’s impact on recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 369 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site.

The project includes 34,894 s.f. of common outdoor open space, 2,050 s.f. of common indoor space and 10,431 s.f. of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.

Goal PR-1,
Policy PR-1.1/
Goal EJ-2,
Policy EJ-2.6/
Goal EJ-5,
Policy EJ-5.7
Develop and maintain a complete system of
public parks and recreational amenities that
provide opportunities for passive and active
recreation at a minimum standard of 5 acres
per 1,000 residents. Parks, trails, and
recreational facilities will enhance community
livability, public health, and safety; should be
Section 5.12 (Recreation) analyzed the project’s impact on recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 369 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site.

The project includes 34,894 s.f. of common outdoor open space, 2,050 s.f. of common indoor space and 10,431 s.f. of private open space. With payment of the

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-46
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy equitably distributed throughout the City; and
be responsive to the needs and interests of
residents, employees, and visitors.

PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.

Goal PR-1,
Policy PR-1.3/
Goal EJ-
2,Policy EJ-2.7
Ensure that the development of parks, trails,
and recreation facilities and services keeps
pace with development and growth within the
City.

Section 5.12 (Recreation) analyzed the project’s impact on recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 369 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site.

The project includes 34,894 s.f. of common outdoor open space, 2,050 s.f. of common indoor space and 10,431 s.f. of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.

Goal PR-1,
Policy PR-1.4/
Goal EJ-5,
Policy EJ-5.8
Promote increased access to parks and open
spaces, pedestrian- and bike-oriented routes to
parks and open space, greening of public
rights-of-way, and a variety of active and
passive uses of parks and open space.

Section 5.12 (Recreation) analyzed the project’s impact on recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 369 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site.

The project includes 34,894 s.f. of common outdoor open space, 2,050 s.f. of common indoor space and 10,431 s.f. of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.

Goal PR-1,
Policy PR-1.5/
Goal EJ-5,
Policy EJ-5.8
Require new development to be designed and
constructed in accordance with the approved
Parks Master Plan to meet or exceed the City’s
parkland standard of 5 acres per 1,000
residents.

Section 5.12 (Recreation) analyzed the project’s impact on recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 369 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site.

The project includes 34,894 s.f. of common outdoor open space, 2,050 s.f. of common indoor space and 10,431 s.f. of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.

Goal PR-1,
Policy PR-1.7
Promote park and facility design that
discourages vandalism, deters crime, provides
Safety considerations of the proposed project are discussed in Section 3.10 (Public Services). As proposed, the proposed project, including development of park and

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-47
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy natural surveillance, and creates a safe and
comfortable environment.
open space areas, does not present any unique public safety challenges. The proposed project is consistent with this policy.

Goal PR-2,
Policy PR-2.2/
Goal EJ-5,
Policy EJ-5.10
Implement the trail network per the Master
Trails Plan to increase opportunities for
physical activity (e.g., walking, biking), healthy
lifestyles, and to reduce reliance on cars.

The City’s Master Trail Plan does not indicate any trails along the project frontage.

The closest trail is the Inland Rail Trail. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the city, in addition to what is provided on-site.

The project includes 34,894 s.f. of common open space and 10,431 s.f. of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.

Safety Element
Goal S-1 Reduce risks to the community from
earthquakes by regulating new development
and redevelopment to prevent the creation of
new geologic and seismic hazards.

The project would implement all recommendations from the geotechnical investigation (Appendix H of the EIR). Additionally, development on the project site would be subject to the requirements of the latest California Building Code (CBC) for resistance to seismic shaking and would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of the State of California Occupational Safety and Health Administration (Cal/OSHA) to minimize risks from earthquakes. The project is consistent with this goal.

Goal S-1, Policy
S-1.1
Reduce the risk of impacts from geologic and
seismic hazards by applying current and proper
land use planning, development engineering,
building construction, and retrofitting
requirements.

The project would implement all recommendations from the geotechnical investigation (Appendix H of the EIR). Additionally, development on the project site would be subject to the requirements of the latest California Building Code for resistance to seismic shaking, and would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of Cal/OSHA to minimize risks from earthquakes. The project is consistent with this policy.

Goal S-1, Policy
S-1.2
Investigate specific groundwater levels and
geologic conditions underlying all new
development or redevelopment proposals in
areas where potential fault rupture,
There is no known faulting at the project site so the potential for surface fault rupture is low. The project site is not located in a State liquefaction susceptibility zone and is mapped in an area with generally zero to low liquefaction. The project is c onsistent with this policy.

3.7 Land Use and Planning
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy liquefaction, or other geologic hazards are
suspected.

Goal S-2 Minimize the risk to people, property, and the environment due to flooding hazards.

The project site is not located within a 100-year flood hazard area nor within the City’s Flood Damage Prevention Overlay Zone. Additionally, off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. The project is consistent with this goal.

Goal S-2, Policy
S-2
Require existing private development to take
responsibility for maintenance and repair of
structures to resist flood damage.

The project site is not located within a 100-year flood hazard area nor within the City’s Flood Damage Prevention Overlay Zone. Additionally, off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. The project is consistent with this policy.

Goal S-3 Minimize injury, loss of life, and damage to
property results from structure or wildland fire
hazards.

Implementation of the proposed project would result in a developed area with roads, structures, and landscape vegetation. The project site is located in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. No impact is identified for this issue area. The proposed project is consistent with this goal.

Goal S-3, Policy
S-3.1
Require development to be located, designed,
and constructed to provide adequate
defensibility and reduce the risk of structural
loss and life resulting from wildland fires.

Development will consider hazards relative to
terrain, topography, accessibility, and proximity
to vegetation. One such provision for
development to minimize the risk of structural
loss and life shall be the inclusion of overhead
fire sprinklers.

The project site is located in a Local Responsibility Area with a Non-VHFHSZ designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. No impact is identified for this issue area. The proposed project is consistent with this policy.

Goal S-3, Policy
S-3.2
Provide sufficient level of fire protection service
to reduce risk from urban and wildland fire.

Advocate and support regional coordination
According to Section 3.10 (Public Services), the project would have a less than significant impact on fire protection services. Additional staff and resources would be provided via Community Facilities District No. 2001-01, which the project would

3.7 Land Use and Planning
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 3.7-49
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy among fire protection and emergency service
providers.
annex into and pay required mitigation fees. The proposed project is consistent with this policy.

Goal S-3, Policy
S-3.3
Require development to provide additional
access roads when necessary to provide for
safe access of emergency equipment and
civilian evacuation concurrently.

Access to the project site would be via one unsignalized driveways on Armorlite Drive.

The driveway and internal drive aisles have been designed to allow for access by emergency response equipment including fire trucks. The Fire Marshal has reviewed the project plans. The proposed project is consistent with this policy.

Goal S-3, Policy
S-3.4
Coordinate with fire protection and emergency
service providers to assess fire hazards before
and after wildfire events to adjust fire
prevention and suppression needs, as
necessary, commensurate with both short- and
long-term fire prevention needs.

The Fire Marshal has reviewed the project plans. The project site is located in a Local Responsibility Area with a Non-VHFHSZ designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non- VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. The proposed project is consistent with this policy.

Goal S-3, Policy
S-3.6
Protect communities from unreasonable risk of
wildfire within very high fire hazard severity
zones.
a. Assess site constraints when considering
land use designations near wildlands to avoid
or minimize wildfire hazards as part of a
community plan update or amendment.
b. Identify building and site design methods or
other methods to minimize damage if new
structures are located in very high fire hazard
severity zones on undeveloped land and when
rebuilding after fire.
c. Require ongoing brush management to
minimize the risk of structural damage or loss
due to wildfires.
d. Provide and maintain water supply systems
to supplies for structural fire suppression.
e. Provide adequate fire protection.

The Fire Marshal has reviewed the project plans. The project site is located in a Local Responsibility Area with a Non-VHFHSZ designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non- VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. The proposed project is consistent with this policy.

Goal S-4 Protect life, structures, and the environment
from the harmful effects of hazardous
materials and waste.

During construction, there is a potential for accidental upset of fuels, lubricants, and other materials; however, there are existing federal and state standards in place for the handling, storage, and transport of these materials. During operation, the only

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. The proposed project is consistent with this goal.

Goal S-4, Policy
S-4.1
Promote and support the proper disposal,
handling, transport, delivery, treatment,
recovery, recycling, and storage of hazardous
materials in accordance with applicable
federal, State, and local regulations.

During construction, there is a potential for accidental upset of fuels, lubricants, and other materials; however, there are existing federal and state standards in place for the handling, storage, and transport of these materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. The proposed project is consistent with this policy.

Goal S-4, Policy
S-4.2/ Goal EJ-
1, Policy EJ-

1.21 Require areas of known or suspected
contamination to be assessed prior to reuse or
redevelopment. Plan for reuse of contaminated
areas in a manner that is compatible with the
nature of the contamination and subsequent
remediation efforts.

A Phase I ESA and a Phase 2 ESA were for the project (Appendix I and J). Based upon the Phase 1 ESA, Phase 2 ESA, and subsequent exploratory investigations, there are not any Recognized Environmental Conditions (RECs) or significant hazards on the project site which has the potential to create a significant hazard to the public or environment. The proposed project is consistent with this policy.

Goal S-4, Policy
S-4.3/ Goal EJ-
1, Policy EJ-

1.22 Require that land uses using hazardous
materials be located and designed to ensure
sensitive uses, such as schools, hospitals, day
care centers, and residential neighborhoods,
are protected.

The proposed project is not anticipated to generate, release, or use large amounts of hazardous materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. The proposed project is not anticipated to impact any sensitive uses in the project vicinity. The proposed project is consistent with this policy.

Goal S-4, Policy
S-4.4/ Goal EJ-
1, Policy EJ-

1.23 Avoid locating sensitive uses near established
hazardous materials users or industrial areas
where incompatibilities would result, except in
cases where appropriate safeguards have been
developed and implemented.

A Phase I ESA and a Phase 2 ESA were for the project (Appendix I and J). Based upon the Phase 1 ESA, Phase 2 ESA, and subsequent exploratory investigations, there are not any RECs or significant hazards on the project site. The proposed project would not place sensitive uses near any known hazardous materials users or industrial areas. The proposed project is consistent with this policy.

Goal S-5 Establish and maintain an effective emergency
response program to respond to disasters and
maintain continuity-of-life support functions
during an emergency.

The Safety Element of the General Plan states that W. Mission Road is one of the east/west streets that should remain open and passable during an emergency. San Marcos is also included in the San Diego County Multi-Jurisdictional Hazard Mitigation Plan, which identifies risks posed by natural and human-caused disasters.

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy The project has been reviewed by the Fire Marshal. According to Section 5,5 (Environmental Effects Found not to be Significant - Hazards and Hazardous Materials), the project would not impact any roadway or staging areas identified in any emergency planning documents. The project is consistent with this goal.

Goal S-5, Policy
S-5.3
Develop, implement, and maintain an effective
evacuation program for areas of risk in the
event of a disaster.

The San Marcos Emergency Operations Plan identifies several main thoroughfares as primary evacuation corridors in an emergency. The project provides one driveway on Armorlite Drive. According to Section 5,5 (Environmental Effects Found not to be Significant - Hazards and Hazardous Materials), the project would not impact any roadway or staging areas identified in any emergency planning documents. The project is consistent with this policy.

Goal S-6 Provide neighborhood safety through effective
law enforcement.

Current staff levels are adequate to meet current law enforcement demand; however, development of the proposed project would increase this demand. To supplement police protection services, the project would contribute to CFD 98-01 Improvement Area #1. The project is consistent with this goal.

Goal S-6, Policy
S-6.1
Continue to maintain demand-based law
enforcement service levels to reduce the risk of
criminal activity.

Current staff levels are adequate to meet current law enforcement demand; however, development of the proposed project would increase this demand. To supplement police protection services, the project would contribute to CFD 98-01 Improvement Area #1. The project is consistent with this policy.

Goal S-6, Policy
S-6.2
Continue public education efforts and
community outreach programs to promote
community involvement in crime and drug
prevention.

The San Diego County Sheriff's Department provides presentations to schools through their Community Oriented Policing and Problem Solving (COPPS) deputies. A school resource officer who handles all crimes relating to school students is also assigned to high schools within the City of San Marcos. The project's contribution to CFD 98-01 Improvement Area #1 would aid in the continued provision of these services. The project is consistent with this policy.

Goal S-6, Policy
S-6.3/ Goal EJ-
4, Policy EJ-

4.12 Use Crime Prevention through Environmental
Design (CPTED) principles in the design or
redevelopment of projects and buildings.

The San Diego County Sheriff's Department provides CPTED reviews through their crime prevention unit. The project's required contribution to a CFD would aid in the continued provision of this service. The Sheriff's Department has reviewed all project plans. The project is consistent with this policy.

Goal S-7 Comply with the McClellan-Palomar Airport
Land Use Compatibility Plan.

The project site is located within Review Area 2 of the McClellan-Palomar airport influence area and may be subject to annoyances associated with noise, vibration, and overflights. Consistent with the ALUCP, recordation of overflight notification documents would be required as a condition of project approval. Review Area 2 also limits heights of structures in areas of high terrain. The project site is not

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy characterized as high terrain and proposed development would remain below surrounding prominent topographic features. The project is consistent with this goal.

Goal S-7, Policy
S-7.1
Record an overflight notification document in
association with the approval of any new
residential land use within the AIA overflight
notification area consistent with the ALUCP.

The project site is located within Review Area 2 of the McClellan-Palomar airport influence area and may be subject to annoyances associated with noise, vibration, and overflights. Consistent with the ALUCP, recordation of overflight notification documents would be required as a condition of project approval. Review Area 2 also limits heights of structures in areas of high terrain. The project site is not characterized as high terrain and proposed development would remain below surrounding prominent topographic features. The project is consistent with this goal.

Noise Element
Goal N-1 Promote a pattern of land uses compatible with current and future noise levels.

The noise study prepared for the project (Appendix P) modeled ambient and future noise levels at the project site and compared with exterior and interior noise thresholds contained in the City’s General Plan. The project would not result in any operational noise impacts and construction impacts will be mitigated to below a level of significance. Additionally, the project is not of a type that would generate excessive noise to neighboring uses during daily operation. Noise associated with increased traffic as a result of the project would not increase levels above the significance threshold of 3 dBA CNEL. Therefore, the project is consistent with this goal.

Goal N-1,
Policy N-1.1
Address the potential for excessive noise levels
when making land use planning decisions in
accordance with Table 7-3 Land Use
Compatibility Noise Standards.

The noise study prepared for the project (Appendix P) analyzed noise impacts to and generated from implementation of the proposed project. As summarized in Section

3.8 (Noise), operational noise impacts would be less than significant and construction related noise impacts would be mitigated to below a level of significance. The project is consistent with this policy.

Goal N-1,
Policy N-1.2
Ensure that acceptable noise levels are
maintained near noise-sensitive uses.

The noise study prepared for the project (Appendix P) analyzed noise impacts to and generated from implementation of the proposed project. As summarized in Section

3.8 (Noise), operational noise impacts would be less than significant and construction related noise impacts would be mitigated to below a level of significance. Mitigation measures would ensure that adjacent residential uses would not be impacted. The project is consistent with this policy.

Goal N-1,
Policy N-1.3/
Incorporate design features into residential
land use projects that can be used to shield
residents from excessive noise. Design
The project design includes rooftop parapets and shielding to minimize noise from HVAC equipment. The project design also includes balcony shielding for units facing

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal EJ-4,
Policy EJ-4.11
features may include, but are not limited to:
berms, walls, and sound attenuating
architectural design and construction methods.

W. Mission Road to ensure private outdoor spaces do not have noise levels in excess of City standards. The project is consistent with this policy.

Goal N-1,
Policy N-1.4
Require new development projects to provide
barriers to reduce noise levels, or provide
sufficient spatial buffers to separate excessive
noise generating land uses and noise-sensitive
land uses.

The project design includes rooftop parapets and shielding to minimize noise from HVAC equipment. The project design also includes balcony shielding for units facing W. Mission Road to ensure private outdoor spaces do not have noise levels in excess of City standards. The project is consistent with this policy.

Goal N-1,
Policy N-1.5
Require an acoustical study for proposed
developments in areas where the existing and
projected noise level exceeds or would exceed
the Normally Acceptable levels identified in
Table 7-3.

A noise study was prepared for the project (Appendix P) and summarized in Section

3.8, (Noise), of the EIR. Operational noise impacts were determined to be less than significant. Construction noise impacts related to potential blasting and rock crushing would be mitigated to below a level of significance. The project would not exceed the Normally Acceptable levels in Table 7-3. The project is consistent with this policy.

Goal N-2 Control transportation-related noise from
traffic, rail, and aviation sources near noise
sensitive land uses.

A noise study was prepared for the project (Appendix P) and summarized in Section

3.8, (Noise), of the EIR. Operational noise impacts were determined to be less than significant. Construction noise impacts related to potential blasting and rock crushing would be mitigated to below a level of significance. The analysis considered the influence of adjacent roadway noise and the SPRINTER rail line. The project is consistent with this goal. The project is consistent with this policy.

Goal N-2,
Policy N-2.1
Encourage only noise-compatible land uses
along existing and future roadways, highways,
and freeways.

A noise study was prepared for the project (Appendix P) and summarized in Section

3.8, (Noise), of the EIR. For residential units with line-of-site to W. Mission Road, private outdoor spaces would have enhanced balcony shielding consisting of a minimum 3.5-foot barrier. The location where the enhanced shielding would be incorporated is shown on Figure 3.8-2. The project is consistent with this policy.

Goal N-2,
Policy N-2.2
Promote coordinated site planning and traffic
control measures that reduce traffic noise on
noise-sensitive land uses.

A noise study was prepared for the project (Appendix P) and summarized in Section

3.8, (Noise), of the EIR. Operational noise impacts were determined to be less than significant. Construction noise impacts related to potential blasting and rock crushing would be mitigated to below a level of significance. The analysis considered the influence of adjacent roadway noise and the SPRINTER rail line. The project is consistent with this policy.

Goal N-2,
Policy N-2.3
Advocate the use of alternative transportation
modes such as walking, bicycling, mass transit,
The project’s internal pedestrian circulation network would connect to the existing sidewalk on Armorlite Drive. The project is adjacent to the NCTD SPRINTER rail line and near the Palomar College transit center. The project design incorporate bicycle

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy and non-combustible engine vehicles to reduce
traffic noise.
racks per the requirements of the City’s CAP Checklist. The project would also require the property manage make transit passes available to residents and business of the building per the requirements of the CAP Checklist. The project is consistent with this policy.

Goal N-3 Control non-transportation-related noise from
commercial, industrial, construction, and other
sources on noise sensitive land uses.

The nearest noise-sensitive land uses are the existing multi-family units to the south and east of the project site. As analyzed in Section 3.8, (Noise), operational noise impacts will be less than significant and construction noise impacts will be reduced to below a level of significance. HVAC equipment would be shielded with parapets as part of the project design. The project is consistent with this goal.

Goal N-3,
Policy N-3.1
When adjacent to noise sensitive receptors,
require developers and contractors to employ
noise reduction techniques during construction
and maintenance operations.

The nearest noise-sensitive land uses are the existing multi-family units to the south and east of the project site. As analyzed in Section 3.8, (Noise), operational noise impacts will be less than significant and construction noise impacts will be reduced to below a level of significance. Construction activities would comply with the City’s Municipal Code requirement and all construction activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. Therefore, the project is consistent with this goal.

Goal N-3,
Policy N-3.2
Limit the hours of construction and
maintenance operations located adjacent to
noise-sensitive land uses.

Construction activities would comply with the City’s Municipal Code requirement and all construction activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. No construction activities will occur on weekends or holidays. The project is consistent with this policy.

Housing Element
Goal H-1 Provide a broad range of housing opportunities with emphasis on providing housing which
meets the special needs of the community.

The project would construct 165 apartments and 15% of the units would be affordable units at the very-low income level. The project proposes a mix of one- bedroom and two-bedroom units ranging from 620 s.f. to 1,020 s.f. The project is consistent with this goal.

Goal H-1,
Policy 1.1/
Goal EJ-4,
Policy EJ-4.5
Designate land for a variety of residential
densities sufficient to meet the housing needs
for a variety of household sizes and income
levels, with higher densities being focused in
the vicinity of transit stops and in proximity to
significant concentrations of employment
opportunities.

The project would construct 165 apartments and 15% of the units would be affordable units at the very-low income level. The project proposes a mix of one- bedroom and two-bedroom units ranging from 620 s.f. to 1,020 s.f. The project site is adjacent to the SPRINTER rail line along W. Mission Road, which is a highly traveled transportation corridor. The project is in proximity to employment opportunities, including Palomar College. The project is consistent with this policy.

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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal H-2 Protect, encourage, and provide housing
opportunities for persons of lower and
moderate incomes.

The project would construct 165 apartments and 15% of the units would be affordable units at the very-low income level. The project is consistent with this policy.

Goal H-4,
Policy 4.4
Balance the need to protect and preserve the
natural environment with the need to provide
additional housing and employment
opportunities.

The project balances the provision of housing with the preservation of open space.

The project would develop 165 apartments and 5,600 s.f. of commercial use. All impacts would be mitigated to below a level of significance. Additionally, Section 4.0, (Alternatives), of the EIR provides a range of alternative development scenarios, including a no development alternative, considered for the project site.

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Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos

3.8 Noise
Introduction
This section addresses the potential noise effects resulting from the construction of the project and analyzes the noise compatibility of the project site with surrounding land uses. The analysis is based on the following report, which is included as Appendix P of the Environmental Impact Report (EIR):17 • Noise Assessment, Armorlite Lofts Residential Development GPA23-002, R23-0001, SDP23- 0003, CUP23-002 City of San Marcos, prepared by LDN Consulting, November 4, 2024 (LDN 2024).

In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to have an adverse impact resulting from excessive noise levels from being located within the vicinity of a private airstrip or within two miles of a public airport.

Therefore, this issue is not discussed further in this section. Section 5.9, Environmental Effects Found Not to Be Significant – Noise of the EIR provides additional information on this topic.

Table 3.8-1 summarizes the project- and cumulative-level noise impacts, by threshold.

Table 3.8-1. Noise Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 – Generation of a substantial temporary
or permanent increase in ambient noise
levels in the vicinity of the project in excess
of standards established in the location
general plan or noise ordinance, or
applicable standards of other agencies.

Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant
#2 - Generation of excessive groundborne
vibration or groundborne noise levels.

Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation

3.8.1 Existing Conditions
This section provides background on noise analysis and a description of the existing noise environment on the project site and surrounding area and details the results of the ambient noise monitoring.

Background
Noise
Noise is generally defined as “unwanted sound” that interferes with normal activities. Excessive levels of noise can cause hearing loss, although the principal human response to environmental noise is annoyance. Noise is measured on a logarithmic scale of sound pressure level known as decibel (dB).

17 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.

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A-weighted decibels (dBA) approximate the subjective response of the human ear to broad frequency noise sources by discriminating against very low and very high frequencies of the audible spectrum.

They are adjusted to reflect only frequencies audible to t he human ear. Equivalent sound level (Leq) is the noise metric used to collect short-term noise level measurement samples. It represents a steady state sound level containing the same total energy as a time varying signal over a given sample period, with Lmax and Lmin as the maximum and minimum, respectively. Community receptors are more sensitive to unwanted noise intrusion during the evening and at night. State law requires that, for some planning purposes, an artificial dBA increment be added to quiet ti me noise levels in a 24- hour A- weighted average noise descriptor called the Community Noise Equivalent Level (CNEL). In general, a change of 10 dBA is perceived as twice as loud (i.e., 65 dBA sounds twice as loud as 55 dBA to a human ear), a 5 dBA change i n community noise levels is clearly noticeable, and a 3 dBA change is the smallest increment that is perceivable by most people. Changes of 1 to 2 dBA are not usually detectable by the human ear.

The decibel level of a sound decreases (or attenuates) exponentially as the distance from the source of that sound increases. For a single point source, such as a piece of mechanical equipment, the sound level normally decreases by about 6 dBA for each dou bling of distance from the source. Sound that originates from a linear, or “line” source, such as a heavily traveled traffic corridor, attenuates by approximately 3 dBA per doubling of distance, provided that the surrounding site conditions lack ground effects or obstacles that either scatter or reflect noise.

Surrounding site conditions, meteorological conditions, and the presence of manmade obstacles such as buildings and barriers may also reduce noise at the location of a receiver. For example, vegetation and loose soils may either absorb or scatter the sound from roadways, yielding sound attenuation rates in environments with these major ground effects that are as high as 4.5 dBA for each doubling of distance (compared to 3 dBA without major ground effects). In addition, barriers between a noise source and a receiver can substantially reduce noise levels at the receiver. A barrier that breaks the line of sight between a source and a receiver will typically result in at least 5 dBA of noise reduction.

Taller barriers will provide increased noise reduction.

Vibration
Vibration is an oscillatory motion through a solid medium in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. Human response to vibration is best approximated by the vibration velocity level.

Heavy equipment operation, including stationary equipment that produces substantial oscillation or construction equipment that causes percussive action against the ground surface, may be perceived by building occupants as perceptible vibration known as “st ructureborne/groundborne” vibration.

Vibration in buildings is typically perceived as rattling of windows or items on shelves or the motion of building surfaces. The vibration of building surfaces can also be radiated as sound and heard as a low- frequency rumbling noise, known as groundborne noise. Although the perceived vibration from such equipment operation can be intrusive to building occupants, the vibration is seldom of sufficient magnitude to cause even minor cosmetic damage to buildings unless the receptors are in proximity to heavy equipment.

Vibration energy spreads out as it travels through the ground, causing the vibration amplitude to rapidly decrease with distance away from the source. Soil properties also affect the propagation of vibration.

Man-made vibration issues are, therefore, usually confined to short distances from the source (i.e., 50 feet or less).

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Vibration amplitudes are usually described in terms of peak levels, as in peak particle velocity (PPV) in inches/second that correlates best with human perception. The particle velocity is the velocity of the soil particles resulting from a disturbance. Ag encies such as the California Department of Transportation (Caltrans) use the PPV descriptor because it correlates well with damage or complaints.

Caltrans estimates that the threshold of perception is approximately 0.006 inches/second PPV and the level at which continuous vibration begins to annoy people is approximately 0.010 inches/second PPV (Caltrans 2020).

Existing Noise Environment
The project site is located on Armorlite Drive, north of State Route 78 (SR -78) and east of Las Posas Road between W. Mission Road and Armorlite Drive. The project site is vacant and does not currently contain any sources of noise or vibration generation. The project vicinity is developed with existing commercial and retail uses to the west, existing multi -family residential units to the east, W. Mission Road, and the San Diego Northern Railroad (SPRINTER rail line) to the north, and Armorlite Drive to the south. Existing multi-family residential units are located across Armorlite Drive to the south.

Existing ambient noise measurements were collected for a 24 -hour period by LDN Consulting from approximately 1:00 PM on Thursday, December 7, 2023 to 1:00 PM on Friday, December 8, 2023.

The sound level meter and microphone were mounted on a tripod approximately five feet above the ground and equipped with a windscreen during all measurements. The monitoring location was determined based on site access and noise impact potential to the proposed sensitive uses. Long - term monitoring location 1 (LT-1) was located at the northern portion of the project site , as shown in Figure 3.8-1.

Table 3.8-2 provides the hourly noise levels along with Leq and CNEL values. As shown in Table 3.8-2, the overall sound level was found to be 61.8 dBA Leq and 67.6 CNEL.

Table 3.8-2. Measured Long-Term Noise Levels
Date Time
Noise Levels (dBA)
Leq CNEL
Thursday, December 7, 2023
2:00 PM 60.0 60.0
3:00 PM 62.5 62.5
4:00 PM 62.6 62.6
5:00 PM 64.9 64.9
6:00 PM 63.4 63.4
7:00 PM 63.6 63.6
8:00 PM 62.9 67.9
9:00 PM 63.6 68.6
10:00 PM 57.1 62.1
11:00 PM 60.4 70.4
Friday, December 8, 2023
12:00 AM 51.7 61.7
1:00 AM 50.6 60.6

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Date Time
Noise Levels (dBA)
Leq CNEL
2:00 AM 49.4 59.4
3:00 AM 49.7 59.7
4:00 AM 49.5 59.5
5:00 AM 62.4 72.4
6:00 AM 65.1 75.1
7:00 AM 65.3 75.3
8:00 AM 62.9 62.9
9:00 AM 64.4 64.4
10:00 AM 61.7 61.7
11:00 AM 58.4 58.4
12:00 PM 60.6 60.6
1:00 PM 60.4 60.4
Overall 61.8 67.6
Source: LDN 2024

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

Federal
Federal Bodies
Title 49 Chapter 65 of the United States Code of Federal Regulations provides for the regulation of noise to protect the public health, safety, and welfare. The Federal Highway Administration (FHWA); Federal Rail Administration and Federal Transit Administration (FTA); and the Federal Aviation Administration, respectively, regulate roadway, rail, and aircraft.

Vibration and Groundborne Noise Impact Regulations
Publications of the FTA and Caltrans are two of the seminal works for the analysis of groundborne noise and vibration relating to transportation and construction-induced vibration. While the project is not subject to FTA or Caltrans regulations, these guidelines serve as a useful tool to evaluate vibration impacts. Caltrans guidelines recommend that a standard of 0.2 in/sec PPV not be exceeded for the protection of normal residential buildings, and that 0.08 in/sec PPV not be exceeded for the protection of old or historically significant structures. With respect to human response within residential uses (i.e., annoyance, sleep disruption), FTA recommends a maximum acceptable vibration standard of 80 vibration velocity (VdB).

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State
State noise standards regulate noise levels of motor vehicles, sound transmission through buildings, occupational noise control, and noise insulation. State regulatory guidelines governing noise levels generated by individual motor vehicles and guidelines governing occupational noise control are not applicable to planning efforts nor are these areas typically subject to California Environmental Quality Act (CEQA) analysis.

Office of Planning and Research General Plan Guidelines The State of California General Plan Guidelines, published by the Governor’s Office of Planning and Research (OPR), provides guidance for the acceptability of specific land use types within areas of specific noise exposure. The guidelines also present adjustment factors that may be used to arrive at noise acceptability standards that reflect the noise control goals of the community, the community’s sensitivity to noise, and the community’s assessment of the relative importance of noise pollution.

General Plan guidelines are advisory in nature. Local jurisdictions, including San Marcos, have the responsibility to set specific noise standards based on local conditions.

State of California Code of Regulations Title 24
In 1974, the California Commission on Housing and Community Development adopted noise insulation standards for hotels, motels, dormitories, and multi -family residential buildings (Title 24, Part 2, California Code of Regulations). Title 24 establishes stan dards for interior room noise (attributable to outside noise sources). The regulations also specify that acoustical studies must be prepared whenever a multi-family residential building or structure is proposed to be located near an existing or adopted fre eway route, expressway, parkway, major street, thoroughfare, rail line, rapid transit line, or industrial noise source, and where such noise source or sources create an exterior CNEL (or LDN) of 60 dBA or greater. Such acoustical analysis must demonstrate that the residence has been designed to limit intruding noise to an interior CNEL (or LDN) of at least 45 dBA [California’s Title 24 Noise Standards, Chap. 2-35].

Local
City of San Marcos General Plan
The following are applicable goals and policies from the City of San Marcos General Plan, Noise Element:
• Goal N-1: Promote a pattern of land uses compatible with current and future noise levels. o Policy N -1.1: Address the potential for excessive noise levels when making land use planning decisions in accordance with Table 7-3 Land Use Compatibility Noise Standards. o Policy N-1.2: Ensure that acceptable noise levels are maintained near noise-sensitive uses. o Policy N-1.3: Incorporate design features into residential land use projects that can be used to shield residents from excessive noise. Design features may include, but are not limited to: berms, walls, and sound attenuating architectural design and constr uction methods.
o Policy N-1.4: Require new development projects to provide barriers to reduce noise levels, or provide sufficient spatial buffers to separate excessive noise generating land uses and noise-sensitive land uses.

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o Policy N-1.5: Require an acoustical study for proposed developments in areas where the existing and projected noise level exceeds or would exceed the Normally Acceptable levels identified in Table 7-3.
• Goal N-2: Control transportation-related noise from traffic, rail, and aviation sources near noise sensitive land uses.
o Policy N -2.1: Encourage only noise -compatible land uses along existing and future roadways, highways, and freeways.
o Policy N-2.2: Promote coordinated site planning and traffic control measures that reduce traffic noise on noise-sensitive land uses.
o Policy N -2.3: Advocate the use of alternative transportation modes such as walking, bicycling, mass transit, and non-combustible engine vehicles to reduce traffic noise. • Goal N-3: Control non-transportation-related noise from commercial, industrial, construction, and other sources on noise sensitive land uses.
o Policy N -3.1: When adjacent to noise sensitive receptors, require developers and contractors to employ noise reduction techniques during construction and maintenance operations.
o Policy N-3.2: Limit the hours of construction and maintenance operations located adjacent to noise-sensitive land uses.

The following is an applicable goal and policy from the City of San Marcos General Plan, Safety Element:
• Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan. o Policy S-7.1: Record an overflight notification document in association with the approval of any new residential land use within the AIA overflight notification area consistent with the ALUCP.

The following is an applicable goal and policy from the City of San Marcos General Plan, Environmental Justice Element:
• Goal EJ-4: Foster healthy living conditions for people of all backgrounds and incomes o Policy EJ-4.11: Incorporate design features into residential use projects that can be used to shield residents from excessive noise. Design features may include, but are not limited to: berms, walls and sound attenuating architectural design and construction methods.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As deta iled in Table 3.7 -7 in Section 3.7, the project is consistent with the applicable goals and policies.

City of San Marcos Municipal Code
Chapter 10.24 (Noise)
Chapter 10.24 of the San Marcos Municipal Code prohibits loud, annoying, or unnecessary noises.

However, the Noise Ordinance does not specifically provide quantified property line noise level limits.

Section 10.24.020 provides definitions for and examples of prohibited noise sources. Included in the list of prohibited noise sources is demolition and building construction activities that occur Monday

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through Friday before 7:00 AM and after 6:00 PM or on Saturdays before 8:00 AM or after 5:00 PM.

No grading, extraction or construction is allowed on Sundays or City holidays. The noise ordinance does not include a quantified noise level limit for construction noise. Section 10.24.030 describes the standards for how sound is assessed. Commonly, the City has utilized Section 36.409 the County of San Diego’s Noise Ordinance noise limit of 75 dBA Leq (8-hour) for construction activities.

The Noise Element of the County of San Diego General Plan establishes limitations on sound levels to be received by various land uses. New development may cause an existing noise sensitive land use (NSLU) to be affected by noise caused by the new development, or it may create or locate a NSLU in such a place that it is affected by noise. The Noise Element identifies airports and traffic on public roadways as the major sources of noise. The County Noise Element establishes the exterior noise level standards and provides interior standards and definitions. If the exterior noise level would exceed 75 dBA CNEL, new development would not be approved.

Section 17.08.080 (Hours of Work)
The City of San Marcos Municipal Code (Section 17.08.080) restricts the hours of construction related activities to between 7:00 AM and 6:00 PM Monday through Friday, 8:00 AM. and 5:00 PM Saturdays, and no construction work is allowed on Sundays or City holidays.

Section 17.60.06 (Blasting Operations Procedures)
The City of San Marcos Section 17.60.06 of the City’s Municipal Code states that all blasting operations within the City of San Marcos are prohibited unless a Certificate of Authorization is first obtained from the San Marcos Building Director and an Operations Permit issued by the Fire Chief.

Additional relevant sections of the City’s Code for Blasting are provided below:
• The general contractor or property owner/developer shall give reasonable notice in writing at the time of issuance of a building permit, grading permit or encroachment license to all residences or businesses within 600 feet of any potential blast location. The notice shall be in a form approved by the Building Director. Any resident or business receiving such notice may request of the Building Director that a notice of impending blasting be given by the blaster at the time of the 12-hour advance notice given to the Building Director. The general contractor or property owner/developer shall make all reasonable efforts to contact any and all parties requesting the second notice.
• The blaster shall file a written certification with the Building Director certifying that the general notice required by Section 17.60.060(b) has been given. The certificate shall include addresses and date(s) of notification. A copy shall be retained on file at the Building Division. • Inspections of all structures within 300 feet of the blast site shall be made before blasting operations. The persons inspecting shall obtain the permission of the building owner to conduct an inspection. The inspections shall be done by a registered struc tural engineer employed by the blaster or project contractor. The inspection shall be only for the purpose of determining the existence of any visible or reasonably recognizable pre -existing defects or damage in any structure. Inspection refusal shall be at the discretion of the property owner. • Blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday, Monday through Friday, exclusive of City recognized holidays unless special circumstances warrant another time or day and special approval is granted by the Building Director and Fire Chief.

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Chapter 20.300 (Zoning Ordinance)
The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.

Section 20.300, Performance Standards, within the Zoning Ordinance identifies noise regulations to prohibit unnecessary, excessive, and annoying noises. Table 20.300-4, included below as Table 3.8-3 identifies allowable noise levels (dBA) by zone type. For multifamily residential and commercial uses, the allowable noise level, as measured at the property line is 65 dBA from 7:00 AM to 10:00 PM. and 55 dBA from 10:00 PM to 7:00 AM. Increases in allowable noise levels listed in Table 3.8-3 may be permitted in accordance with the standards outlined in Table 3.8-4.

1. Noise shall be measured with a sound-level meter that meets the standards of the American National Standards Institute (ANSI) (Section S1.4 -1979, Type 1 or Type 2). Noise levels shall be measured in decibels at the property line of the receptor property, and at least five (5) feet above the ground and ten (10) feet from the nearest structure or wall. The unit of measure shall be designated as an A-weighted decibel (dBA) Leq standard. A calibration check shall be made of the instrument at the time any noise measurement is made.

2. No person shall create or allow the creation of exterior noise that causes the noise level to exceed the noise standards established by Table 20.300-4 (shown as Table 3.8-3). Increases in allowable noise levels listed in Table 20.300-4 (shown as Table 3.8-3) may be permitted in accordance with the standards outlined in Table 20.300- 5 (shown as Table 3.8-4).

3. No person shall create nor allow the creation of noise that causes the interior noise level when measured within a dwelling unit to exceed forty-five (45) dBA at any time, except as permitted by Table 20.300-6 (shown as Table 3.8-5).

4. Use of compressors or other equipment, including vents, ducts, and conduits, but excluding window or wall-mounted air conditioners, that are located outside of the exterior walls of any building, shall be enclosed within a permanent, noncombustible, view-obscuring enclosure to ensure that the equipment does not emit noise in excess of the ANSI standards.

Table 3.8-3. Exterior Noise Standards by Zone
Zone Allowable Noise Level (dBA Leq) Measured from the
Property Line
Single-Family Residential (A, R-1, R-2)1,2
7:00 AM and 10:00 PM (daytime) 60
10:00 PM and 7:00 AM (overnight) 50
Multifamily Residential (R-3) (1)(2)
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 55
Commercial (C, O-P, SR)(3)
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 55
Industrial
7:00 AM and 10:00 PM (daytime) 65

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Zone Allowable Noise Level (dBA Leq) Measured from the
Property Line
10:00 PM and 7:00 AM (overnight) 60
Source: City of San Marcos 2023 (Table 20.300-4).

Notes: (1) For single-family detached dwelling units, the "exterior noise level" is defined as the noise level measured at an outdoor living area which adjoins and is on the same lot as the dwelling, and which contains at least the following minimum net lot area: (i) for lots less than 4,000 square feet in area, the exterior area shall include 400 square feet, (ii) for lots between 4,000 square feet to 10 acres in area, the exterior area shall include 10 percent of the lot area; (iii) for lots over 10 acres in area, the exterior area shall include 1 acre. (2) For all other residential land uses, "exterior noise level" is defined as noise measured at exterior areas which are provided for private or group usable open space purposes. "Private Usable Open Space" is defined as usable open space intended for use of occupants of one dwelling unit, normally including yards, decks, and balconies.

When the noise limit for Private Usable Open Space cannot be met, then a Group Usable Open Space that meets the exterior noise level standard shall be provided. "Group Usabl e Open Space" is defined as usable open space intended for common use by occupants of a development, either privately owned and maintained or dedicated to a public agency, normally including swimming pools, recreation courts, patios, open landscaped areas, and greenbelts with pedestrian walkways and equestrian and bicycle trails, but not including off -street parking and loading areas or driveways.
(3) For non-residential noise sensitive land uses, exterior noise level is defined as noise measured at the exterior area provided for public use.

Table 3.8-4. Permitted Increase in Noise Levels
Permitted Increase (dBA) Duration
(cumulative minutes per hour)
5 15
10 5
15 1
20 Less than 1 minute
Source: City of San Marcos 2023 (Table 20.300-5).

Table 3.8-5. Permitted Increase in Interior Noise Levels Permitted Increase (dBA) Duration
(cumulative minutes per hour)
5 1
10 Less than 1 minute
Source: City of San Marcos 2023 (Table 20.300-6).

3.8.3 Thresholds of Significance
According to Appendix G of the California Environmental Quality Act (CEQA) Guidelines, noise impacts are considered potentially significant if they cause:
• Threshold #1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the location general plan or noise ordinance, or applicable standards of other agencies. • Threshold #2: Generation of excessive groundborne vibration or groundborne noise levels.

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The term “substantial increase” is not defined by any responsible agency. Under ambient conditions, people generally do not perceive that noise has clearly changed until there is a 3 dBA difference.

Therefore, a threshold of 3 dBA is commonly used to define “substantial increase,” as it is noticeable to humans under typical ambient conditions.

As identified above, impacts related to being in the vicinity of a private airstrip or airport land use plan are not discussed in this section. Section 5.9, Environmental Effects Found Not to Be Significant – Noise, provides additional information on this topic.

San Marcos Noise Impact Thresholds
Construction Noise Standards
The City of San Marcos Municipal Code does not set noise limits on construction activities. Commonly, the City utilizes the County of San Diego’s Noise Ordinance Section 36.4 09 noise limit of 75 dBA at any existing sensitive receptor for construction activities. Municipal Code Section s 10.24.020 and Section 17.08.080 limit the hours of grading, extraction, and construction activities to between the hours of 7:00 AM and 6:00 PM, Monday through Friday, 8:00 AM and 5:00 PM Saturdays, No grading, extraction or construction is allowed on Sundays or City holidays.

As mentioned, typically, the threshold for determining whether construction noise is significant is 75 dBA. However, in the past, the City of San Marcos has applied the operational noise standards to rock crushing activities when operating on a longer -term basis. The City’s 65 dBA Leq operational noise - standard at the nearest multi -family residence and 70 dBA for commercial has been applied in the analysis.

City of San Marcos Ground Vibration Standards
The City of San Marcos does not have adopted vibration criteria for construction. The FTA provides guidelines for acceptable levels of groundborne vibration for various types of buildings that are sensitive to vibration and for potential human annoyance . While the project is not subject to FTA or Caltrans regulations, these guidelines serve as a useful tool to evaluate vibration impacts . For purposes of identifying potential project-related vibration impacts resulting from the proposed project, the FTA guidelines will be used. Table 3.8-6 shows the FTA groundborne vibration and noise impact guidelines for human annoyance.

Table 3.8-6. Groundborne Vibration and Noise Impact Criteria (Human Annoyance)

Groundborne Vibration
Impact Levels
(VdB re 1 microinch/second)
Groundborne Noise Impact Levels
(dB re 20 micropascals)
Frequent
Events1
Occasional
Events2
Infrequent
Events3
Frequent
Events1
Occasional
Events2
Infrequent
Events3
Category 1: Buildings where low
ambient vibration is essential for
interior operations.
65 VdB4 65 VdB4 65 VdB4 N/A4 N/A4 N/A4
Category 2: Residences and
buildings where people normally
sleep.
72 VdB 75 VdB 80 VdB 35 dBA 38 dBA 43 dBA
Category 3: Institutional land uses
with primarily daytime use. 75 VdB 78 VdB 83 VdB 40 dBA 43 dBA 48 dBA

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Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.

1. “Frequent Events” are defined as more than 70 vibration events per day. Most rapid transit projects fall into this category.

2. “Occasional Events” are defined as between 30 and 70 vibration events of the same source per day. Most commuter trunk lines have this many operations.

3. “Infrequent Events” are defined as fewer than 30 vibration events of the same kind per day. This category includes most commuter rail branch lines.

4. This criterion limit is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes. Vibration-sensitive manufacturing or research would require detailed evaluation to define the acceptable vibration levels. Ensu ring lower vibration levels in a building often requires special design of the HVAC systems and stiffened floors.

5. Vibration-sensitive equipment is not sensitive to groundborne noise.

In addition to the vibration annoyance standards presented in Table 3.8 -6, the FTA also applies the following standards for construction vibration damage. As shown in Table 3.8-7, structural damage is possible for typical residential construction when the PPV exceeds 0.2 inch per second (in/sec). This criterion is the threshold at which there is a risk of damage to normal dwellings.

Table 3.8-7. Groundborne Vibration Impact Criteria (Structural Damage) Building Category PPV (in/sec) VdB
I. Reinforced-concrete, steel, or timber (no plaster) 0.5 102 II.Engineered concrete and masonry (no plaster) 0.3 98
III. Non-engineered timber and masonry buildings 0.2 94 IV. Buildings extremely susceptible to vibration damage 0.12 90 Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.

Note: RMS = Root Mean Square (RMS) velocity calculated from vibration level (VdB) using the reference of one microinch/second.

Transportation Noise Standards
To control transportation -related noise sources such as arterial roads, freeways, airports, and railroads, the City of San Marcos has established guidelines for acceptable community noise levels in the Noise Element of the General Plan (Table 7-3 of the Ge neral Plan Noise Element). For noise sensitive rural and single-family residential uses, schools, libraries, parks, and recreational areas, the City Noise Element requires an exterior noise level of less than 60 dBA CNEL for outdoor usable areas, such as yard and patio areas. For multi-family developments, the standard is 65 dBA CNEL. A standard of 70 dBA CNEL is typically applied to commercial uses. The City has also established an interior noise limit of 45 dBA CNEL for all residential uses. Noise sensitive indoor spaces are subject to compliance with CCR Title 24 noise insulation standards demonstrating a 45 dBA CNEL interior noise level with all windows of the structure closed.

For this analysis, a direct roadway noise impact would be considered significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and increases noise levels above an unacceptable noise level per the City’s General Plan in the area adjacent to the roadway segment.

Operational Noise Standards
The City noise regulations that apply to the proposed project are found in Chapter 20.300 Site Planning and General Development Standards of the City Municipal Code. These regulations aim to prohibit unnecessary, excessive, and annoying noises from all sources, as certain noise levels are detrimental

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to the health and welfare of individuals. The standards of this section and of Chapter 10.24 Noise of the Municipal Code apply to all land uses unless otherwise specified. No person shall create or allow the creation of exterior noise that causes the noise level to exceed the noise standards established by Table 20.300-4 of the Municipal Code. See Table 3.8-3 earlier in this section.

The City Ordinance limits noise generation in commercial and multi-family zones to 65 decibels (dB) Leq (one-hour average) between the hours of 7:00 am and 10:00 pm and 55 dB Leq between the hours of 10:00 PM and 7:00 AM as measured at the project property line as shown above in Table

3.8-3. Per the City of San Marcos General Plan Noise Element (GPNE), noise standards for commercial, multi-family, and mixed-use land uses are the same, and are higher than single-family residential areas because they reflect a more urban environment (GPNE, pg. 7-10). Higher thresholds are permitted due to the integrated mix of residential and commercial activity and their usual location near major arterials (GPNE, pg. 7-9). Retail uses are located adjacent to the project to the west and are zoned Commercial.

The existing AT&T lot located adjacent to the project to the west is zoned Public-Institutional (P-I). The nearest residential uses are the multi -family units located adjacent to the project to the east and to the south acr oss Armorlite Drive, which are zoned under the Palomar Station Specific Plan Area for Mixed-Use. Therefore, the City Ordinance limits of 65 dBA hourly noise standard during the daytime hours between 7:00 AM and 10:00 PM and a 55 dBA standard during the nig httime hours between 10 PM and 7 AM would apply at all property lines.

3.8.4 Project Impact Analysis
Construction and operation of the project have the potential to result in short term and long term increases in noise on the project site in the project vicinity. As part of the project design, residential units with direct line -of-site to W. Mission Road and Las Posas Road would have enhanced balcony and patio shielding consisting of 3.5-foot barriers. The location where the enhanced shielding would be incorporated is shown on Figure 3.8 -2. The shielding would be constructed of a non -gapping material consi sting of masonry, ¼ inch thick glass, earthen berm, or any combination of these materials. Additionally, as part of the project design features, to ensure compliance with CCR Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).

Threshold #1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the location general plan or noise ordinance, or applicable standards of other agencies.

Construction Noise
This section addresses the construction noise impacts associated with the project to determine if they would result in the exposure of persons to or generation of noise level in excess of applicable noise standards. Construction noise represents a short -term impact on the ambient noise levels, primarily from construction equipment. Grading activities typically represent one of the highest potential sources for noise impacts. The most effective method of controlling construction noise is through local control of construction hours and by limiting the hours of construction to normal weekday working hours. As stated above, the City of San Marcos Municipal Code does not set noise limits on construction activities. Commonly, the City utilizes the County of San Diego’s Noise Ordinance Section

36.410 noise limit of 75 dBA at any existing sensitive receptor for construction activities.

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The U.S. Environmental Protection Agency (USEPA) has compiled data regarding the noise generating characteristics of specific types of construction equipment. Noise levels generated by heavy construction equipment can range from 60 dBA to in excess of 100 dBA when measured at 50 feet.

However, these noise levels diminish rapidly with distance from the construction site at a rate of approximately 6 dBA per doubling of distance. For example, a noise level of 75 dBA measured at 50 feet from the noise source to the receptor would be reduced to 69 dBA at 100 feet from the source to the receptor and reduced to 63 dBA at 200 feet from the source.

LDN used a point-source noise prediction model to calculate the expected construction noise impacts.

The essential model input data for these performance equations include the source levels of each type of equipment, relative source to receiver horizontal and vertical separations, the amount of time the equipment is operating in a given day, also referred to as the duty -cycle and any transmission loss from topography or barriers (LDN 2024).

The equipment needed for the most intensive grading activities would consist of a medium sized rubber tire tractor/backhoe, a large bulldozer, a medium sized front loader, a water truck, and a small to medium sized paver/blade. Based on the USEPA noise emi ssions, empirical data and the amount of equipment needed, worst case noise levels from the construction equipment for site preparation would occur during grading operations.

The potential noise sensitive uses are located adjacent or near the property lines. The affected land uses include the existing retail uses adjacent to the project to the west , and the existing multi-family residential uses to the east and south across Armorlite Drive. These uses would be on average over 100-feet from the center of the proposed construction activities. W. Mission Road and the railroad line are located to the north and are not considered sensitive uses. As shown in Table 3.8 -2, existing ambient sound levels were found to be 61 dBA Leq and 67.6 CNEL.

Grading
The grading activities would consist of the preparation of parking, finished pads, and retaining walls .

The grading equipment would be spread out over the project site from distances near the occupied property lines to distances of 200 feet or more away at the western property line . Based on the site plan, the majority of the grading operations, on average, would occur more than 100 feet from the property lines. This means that most of the time the average distance from all the equipment to the nearest property line is 100 feet.

As shown in Table 3.8-8, at an average distance of 100 feet from the construction activities to the nearest property line would result in a noise attenuation of 6.0 dBA without shielding. Given this, the noise levels would comply with the 75 dBA Leq (8-hour) standard at the property lines. Therefore, the construction noise impacts would be considered
less than significant, and no mitigation is required
during construction of the proposed project. Additionally, as a project design feature, all equipment would be properly fitted wit h mufflers and all staging and maintenance would be conducted as far away from the existing residences as possible.

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Table 3.8-8. Construction Noise Levels
Equipment Type Quantity Used Source @ 50 Feet
(dBA)
Cumulative Noise Level
@ 50 Feet (dBA)
Tractor/Backhoe 1 72 72.0
Dozer D9 Cat 1 74 74.0
Loader/Grader 1 73 73.0
Water Truck 1 70 70.0
Paver/Blade 1 75 75.0
Cumulative Level 80.1
Distance to Sensitive Uses 100
Noise Reduction due to Distance -6.0
Property Line Noise Level 74.1
Source: LDN 2024.

Grading Materials Export
Construction grading operations for the project are anticipated to include 6,950 cubic yards (cy) of cut material and 4,400 cy of fill material requiring an export of approximately 2,250 cy of fill material once materials shrinkage is considered. Assuming the use of 15 CY trucks and 15 work days, this equates to approximately 10 truck trips per day. Noise level changes greater than 3 dBA are often identified as audible and considered potentially significant, while changes less than 1 dBA would not be discernible to local residents. In the range of 1 to 3 dBA, residents who are very sensitive to noise may perceive a slight change. Community noise exposures are typically over a long time period rather than the immediate comparison made in a laboratory situation. Therefore, the level at which changes in community noise levels become discernible is likely greater than 1 dBA, and 3 dBA appears to be appropriate for most people. For the purposes of this analysis, direct and cumulative roadway noise impacts would be considered significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and if the project increases noise levels above an unacceptable noise level per the City’s General Plan in the area adjacent to the roadway segment. Typically, it requires a project to double (or add 100%) to the traffic volumes to result in a 3 dBA CNEL increase, which is considered a potential impact. Based on a current traffic volume of approximately 5,000 average daily traffic (ADT) or more on the roadways along the site and along the anticipated haul route, the additional trucks (10 per day) would add less than 0.5 dBA to the overall noise level. This is well below a 3 dBA increase that is considered a potential impact. No noise impacts are anticipated at the residential uses that are located along the roadway due to the low volume of trucks. Impacts would be less than significant.

Rock Drilling and Blasting
The project has been designed to avoid blasting; however, due to bedrock conditions on the project site, blasting and rock crushing may be required once grading commences. Should blasting be required, the project would comply with all provisions identified in the City’s Municipal Code Section

17.60.06 as it relates to blasting and blasting shall only be permitted between the hours of 9:00 AM

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and 4:00 PM during any weekday. Blasting also require s issuance of a Blasting Permit from the San Marcos Fire Department.

During project grading and site preparation activities, areas of the project site that require deeper cuts and where the native material is not easily rippable (graded) may require blasting and the use of a rock drill. The rock drill would be moved around the site on an as needed basis dependent upon the site characteristics. The use of a rock drill would occur independently of all other proposed equipment.

The drilling and blasting activities would occur in one area and then the grading equipment would relocate or remove the debris. To determine the worst-case noise levels from the drilling operations, it was assumed that the noise level from the rock drill would be 85 dBA at 50 feet (FHWA 2006; OML 2016). Utilizing a 6 dBA reduction per doubling of distance, the rock drill would need to be located at an average distance of 160 feet from any property line to comply with the 75 dBA standard as shown in
Table 3.8-9.

Table 3.8-9. Construction Noise Levels from Rock Drill
Construction
Equipment Quantity
Source Level
@ 50 Feet
(dBA)
Duty Cycle
(Hours/Day)
Noise Level @ 50 Feet
(dBA)
Rock Drill 1 85 8 85.0
Noise Reduction Needed to Comply -10.0
Distance Required to Reduce Noise Levels 160
Nearest Property Line Noise Level 74.9
Source: LDN 2024.

Rock drilling and blasting would occur on an as-needed basis on site. In the event that the rock drill is staged within 160 feet of any occupied noise sensitive land use, a potentially significant impact (N-1) would occur.
• Impact N-1 Due to temporary rock drilling and blasting activities during construction, the proposed project has the potential to create noise levels in excess of the 75 dBA standard if rock drilling equipment is staged closer than 160 feet to an occupied noise sensitive land use’s property line.

Rock Crushing
The project’s requested approvals include a Conditional Use Permit, which would allow for the use of a temporary rock crusher. Rock crushing would occur between the hours of 7:00 AM and 4:00 PM .

The rock crushing equipment would be located in the northwest corner of the site in the proposed parking area, which is over 200 feet from the nearest residences to the east, over 500 feet from the residences to the south and over 200 feet from the nearest commercial use to the southwest. Based on empirical data col lected at the existing Mission 316 residential development from a similar rock crusher, noise levels ranged between 70-72 dBA at 100 feet (LDN 2021). Therefore, a worst -case noise level of 72 dBA at 100 feet was used to analyze noise levels from rock crushing equipment (LDN 2024). The analysis assumed the project would use a Thunderbird Hazemag #CP300 or equivalent rock crusher. Typically, the threshold for determining whether construction noise is significant is 75 dBA. However, in the case of rock crushin g, to be conservative, the City has applied the operational noise standard to rock crushing activities when operating on a longer-term basis. The operational noise standards of 65 dBA for multi-family residential and 70 dBA for commercial have been applied in the

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analysis. Because the closest sensitive receptor to the rock crusher would be the multi -family residences located adjacent to the project site to the east, the daytime threshold of 65 dBA Leq is used to determine significance. The property directly to the west is zoned Public-Institutional (P-I) with minimal usage and would not be considered a sensitive use.

It was determined that the noise levels of the rock crusher would be reduced by a minimum of 6.8 dBA due to the topography blocking line of sight to the existing multi -family homes to the east. As can be seen in
Table 3.8-10, based on the proposed location of the rock crusher, the anticipated noise levels at the eastern residential property line would be in compliance with the City’s 75 dBA Leq construction noise standard and in compliance with the applied 65 dBA Leq operational noise standard for multi - family residential.

Table 3.8-10. Rock Crushing Noise Levels (Residential Receptors) Equipment Type Quantity
Used
Source @ 100
Feet (dBA)
Duty Cycle
(hours/day)
Cumulative Noise Level @ 100
Feet (dBA)
Thunderbird Hazemag
#CP300 1 72 8 72.0
Distance to Sensitive Use 220
Noise Reduction Due to Distance -6.8
Property Line Noise Level 65
Source: LDN 2024.

Additionally, the rock crushing equipment would be located over 200 feet from the nearest commercial use to the southwest. As can be seen in Table 3.8-11, at 220 feet, the noise levels would be reduced to 65 dBA and would not exceed the City’s 75 dBA Leq construction noise standard or the applied 70 dBA Leq operational noise standard for commercial.

Table 3.8-11. Rock Crushing Noise Levels (Commercial Receptors) Equipment Type Quantity
Used
Source @ 100
Feet (dBA)
Duty Cycle
(hours/day)
Cumulative Noise Level @ 100
Feet (dBA)
Thunderbird Hazemag
#CP300 1 72 8 72.0
Distance to Sensitive Use 220
Noise Reduction Due to Distance -6.8
Property Line Noise Level 65
Source: LDN 2024.

However, in the event that the rock crusher is staged within 210 feet of multi -family residential uses or within 160 feet from commercial uses without shielding, noise levels may exceed the applied thresholds of 65 dBA for any multifamily use or 70 dBA at a commercial use (LDN 2024) . This represents a potentially significant impact (Impact N-2) and mitigation is required. • Impact N-2 Due to temporary rock crushing activities, the proposed project has the potential to create noise levels in excess of the applied operational noise standards for multi- family residential (65 dBA Leq) and commercial use (70 dBA Leq) if the rock crusher is staged within 210 feet of a multi-family residential use or within 160 feet of a commercial use.

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Operational Noise
This section addresses the operational noise associated with the project to determine if it would result in the exposure of persons to or generation of noise level in excess of applicable noise standards.

Operational noise associated with the project would include traffic generated by the project that travels on area roadways , railway noise from the SPRINTER line, as well as noise that is generated on the project site. The modeled observer locations for the outdoor use areas are shown in Figure 3.8-3.

Future Onsite Roadway Noise
To determine the future noise environment and impact potential resulting from increased traffic associated with the proposed project, the FHWA model was utilized. Table 3.8 -12 presents the roadway parameters used in the analysis including the peak traffic volumes, vehicle speeds, and the hourly traffic flow distribution (vehicle mix). The vehicle mix provides the hourly distribution percentages of automobiles, medium trucks, and heavy trucks for input into the FHWA Model. The Buildout conditions for W. Mission Road, Las Posas Road, and Armorlite Drive include the future year 2050 traffic volume forecasts provided by the project traffic study by LLG (LLG 2024). In addition, the project is located over 1,000 feet north of SR -78. According to the City of San Marcos’ General Plan Noise Element, background noise levels from future traffic along SR -78 is 60 dBA CNEL at approximately 800 feet. The noise contours for this area would also include traffic noise from W.

Mission Road and Las Posas Road. SPRINTER noise may also contribute to that contour.

Table 3.8-12. Future Traffic Parameters
Roadway Average Daily
Traffic (ADT)1
Peak Hour
Volumes1
Modeled
Speeds
(MPH)
Vehicle Mix %2
Auto Medium
Trucks
Heavy
Trucks
Mission Road 22,450 2,245 45 96 2 2
Las Posas Road 36,290 3,629 45 96 2 2
Armorlite Drive 6,704 670 25 96 2 2
Source: LDN 2024.

Notes: (1) Peak hour volumes are Year 2050 volumes identified in the Local Transportation Analysis prepared by LLG, 2024.
(2) Typical City vehicle mix.

Onsite Rail Line Noise
The proposed project is located approximately 42 feet from the San Diego Northern Railroad consisting of SPRINTER service operated by the North County Transit District (NCTD). According to the City of San Marcos General Plan Noise Element, the 65 dBA CNEL noise contour from the rail activity, with no shielding, is located 130 feet from the centerline of the railroad.

Cumulative Roadway and Train Noise Levels
The noise levels determined for the roadway and train activities were combined to determine the overall cumulative noise levels at the proposed receptors. The modeling results for the adjacent roadways and the cumulative noise levels with the background noise from Las Posas Road, SR -78, and train noise are provided in Table 3.8-13. Additionally, three decibels of attenuation is allowed for the first row of buildings when they block 40 to 65% of the line of sight to the noise source, and five decibels of attenuation is allowed when the buildings obstruct more than 65% of the line of sight (LDN

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2024). The line of sight to the roadways is blocked by the existing and proposed structures, therefore, a factor of 3 or 5 dBA was taken into account as shown in Table 3.8-13.

The modeling results for the future unmitigated exterior noise levels is shown in Table 3.8-13, including any noise reduction from the distance between the source and receptor. Based upon these findings, noise levels at the upper floor balconies along W. Mission Road and Las Posas Road would exceed the City’s Noise Standard of 65 dBA CNEL if design features were no t included. However, as part of the project design, residential units with direct line-of-sight to W. Mission Road and Las Posas Road would have enhanced balcony shielding consisting of 3.5 -foot barriers , as shown on Figure 3.8 -2. The shielding would be constructed of a non -gapping material consisting of masonry, ¼ inch thick glass , earthen berm, or any combination of these materials. To determine the required barrier heights at the balconies along W. Mission Road and Las Posas Road, the Fresnel Barrier Reduction Calculations was used to determine the barrier attenuation based on distance, source height, receiver elevation and the top of barrier were modeled. It was determined that 3.5-foot noise barriers located at the balconies would provide a 6.1 dBA noise reduction along the northern façade and a 5.3 dBA noise reduction along the western façade.

Table 3.8-14 shows that with incorporation of these design features, the sound level at the building façades along W. Mission Road and Las Posas Road would not exceed 65 dBA CNEL. It was also determined that noise levels at the common outdoor areas would comply with the City’s 65 dBA CNEL noise standard wi th no design features. Additionally, the project is proposing minimum 3.5-foot barriers at the pool area which would further reduce noise levels.

It should be noted that the ground floor flex units along Armorlite Drive to the south could potentially be converted to residential units and would be required to comply with the City’s 65 dBA CNEL noise standard. The units would comply with the City’s 65 dBA CNEL noise standard without additional noise reduction measures.

Additionally, as part of the project design features described in Table 2-1, to ensure compliance with CCR Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces). As shown in Table 3.8- 14, with incorporation of design features, transportation related noise impacts would be less than significant.

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Table 3.8-13. Future Exterior Noise Levels Before Balcony Design Features Traffic Volumes, Distance and Speeds
Roadway ADT Speed
(MPH) Distance Noise Level (dBA
CNEL)
Mission Road 22,450 45 50 72.7
Las Posas Road 36,290 45 50 74.8
Armorlite Drive 6,704 25 50 63.2
SR-78 -- -- 800 60.0
SPRINTER -- -- 130 65
Noise Reduction due to Distance and Shielding (dBA CNEL) Receptor(1) Receptor Location Roadway Distance
Reduction
from
Distance
Reduction from
Shielding
Resultant Noise
Level
1 Building Facades
along
Mission Road
Mission Road 200 -6.02 0.0 66.7
Las Posas
Road 338 -8.30 -3.0 63.5
SPRINTER 100 1.14 0.0 66.1
Cumulative Noise Level 70.4
2 Building Facades
facing Las Posas
Road

Mission Road 300 -7.78 -3.0 62.0
Las Posas
Road 288 -7.60 0.0 67.2
Armorlite
Drive 316 -8.01 -3.0 52.2
SR-78 1,470 -3.96 -5.0 51.0
SPRINTER 200 -1.87 -3.0 60.1
Cumulative Noise Level 69.1
3 Internal Courtyard
Mission Road 370 -8.69 -10.0 54.1
Las Posas
Road 378 -8.79 -10.0 56.1
Armorlite
Drive 246 -6.92 -10.0 46.2
SR-78 1,402 -2.44 -10.0 47.6
SPRINTER 270 -3.17 -10.0 51.8
Cumulative Noise Level 59.6
4 Pool Area
Las Posas
Road 370 -8.69 -5.0 61.1
Armorlite
Drive 65 -1.14 0.0 62.0
SR-78 1,220 -2.75 -5.0 52.3
Cumulative Noise Level 64.9
5 Las Posas
Road 412 -9.16 -5.0 60.7

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Traffic Volumes, Distance and Speeds
Building Facades
along Armorlite
Drive
Armorlite
Drive 48 0.18 0.0 63.3
SR-78 1,200 -2.64 -5.0 52.4
Cumulative Noise Level 65.4
Source: LDN 2024.

Notes: (1) See Figure 3.8-3
Table 3.8-14. Future Exterior Noise Levels with Balcony Design Features Receptor
Number(1) Receptor Location
Noise Level @
Receptor
(dBA CNEL)
Reduction Due to
Shielding
(dBA CNEL)
Resultant Noise
Level
(dBA CNEL)
1 Building Facades along
Mission Road 70.4 -6.1 64.3
2 Building Facades facing
Las Posas Road 69.1 -5.3 63.8
3 Internal Courtyard 59.6 - 59.6
4 Pool Area 64.9 -5.0 59.9
5 Building Facades along
Armorlite Drive 65.4 - 65.4
Source: LDN 2024.

Notes: (1) See Figure 3.8-3
Project Related Offsite Transportation Noise
For the purposes for this analysis, direct and cumulative roadway noise impacts would be considered significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and if the project increases noise levels above an unacceptable noise level per the City’s General Plan in the area adjacent to the roadway segment . To determine if direct or cumulative off -site noise level increases associated with the development of the proposed project would create noise impacts, the traffic volumes for the existing conditions were compared with the traffic volume increase of existi ng plus the proposed project. According to the project traffic study, the project is estimated to generate 1,214 daily trips with a peak hour volume of 109 trips (LLG 202 4). As shown in Table 3.8 -13, the existing traffic volume on W. Mission Road is 22,450 ADT, 36,290 ADT on Las Posas Road and 6,704 ADT on Armorlite Drive. Typically, it requires a project to double (or add 100%) the traffic volumes to have a direct impact of 3 dBA CNEL or be a major contributor to the cumulative traffic volumes. The project would not double the traffic volumes on any adjacent roadways. Therefore, no direct or cumulative impacts are anticipated. Impacts would be
less than significant.

Operational Noise – HVAC Equipment
This section examines the potential operational noise source levels associated with the development and operation of the proposed project. Noise from a fixed or point source drops off at a rate of 6 dBA for each doubling of distance; for example, a noise level of 70 dBA at 5 feet would be 64 dBA at 10 feet and 58 dBA at 20 feet. A review of the proposed project indicates that noise sources such as the roof mounted mechanical heating, ventilation, and air conditioning (HVAC) system are the primary source of stationary noise.

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Properties adjacent to the project site to the east and south are multi-family residential units zoned as mixed use under the Palomar Station Specific Plan Area. Therefore, the City Ordinance limits of 65 dBA hourly noise standard during the daytime hours between 7:00 AM and 10 PM, a 55 dBA standard during the nighttime hours between 10:00 PM and 7:00 AM would apply at all property lines.

Roof-mounted HVAC units would be installed at the proposed building. The project anticipates installing Carrier CA15NA (Series, 24 -A) or equivalent HVAC units with a reference noise level of 71 dBA at 3-feet. The manufacturer’s specifications and noise levels are provided in Attachment B of the Noise Report, which is Appendix P of this EIR. The HVAC units would cycle on and off throughout the day. Typically, HVAC units run for approximately 20 minutes each operating cycle to provide the necessary heating or cooling. It is anticipated that the HVAC units would operate twice in any given hour or run for 40 minutes in any given hour. Noise levels drop 3 decibels each time the duration of the source is reduced in half. Therefore, hourly HVAC noise level over a 4 0-minute period would be reduced approximately 2 decibels to 69 dBA based on operational time. To predict the property line noise level, a reference noise level of 69 dBA at 3- feet was used to represent the HVAC units (LDN 2024).

The HVAC units are located a minimum of 46 feet from the eastern residential property line and would be shielded by the parapet walls that would break the line of sight to the HVAC units and would provide a minimum 5 dBA reduction. The typical locations of the proposed HVAC units are shown in Figure 3.8-

4. Up to 20 HVAC units would be clustered together closest to the nearest residential property line to the east. The remainder of the HVAC units would be separated by at least 80 feet and this separation would result in a 20 dBA difference between other HVAC clusters and would not cumulatively increase the noise levels. Therefore, the worst-case combined noise from the HVAC would occur from 20 units.

Utilizing a 6 dBA decrease per doubling of distance, noise levels at the nearest residential property line as described above were calculated for the HVAC units. The HVAC units are located a minimum of 46 feet from the nearest residential property line to the east. The noise level reductions due to distance and the building for the nearest property line is provided in Table 3.8-15 below.

Table 3.8-15. Project HVAC Noise Levels (Eastern Residential Property Line) Distance to
Nearest
Observer
Location
(Feet)
Hourly
Reference
Noise Level
(dBA)
Noise
Source
Reference
Distance
(Feet)
Noise
Reduction
Due to
Distance
(dBA)
Reduction
Due to
Buildings
(dBA)
Noise Level
at Property
Line
(dBA)
Quantity
Property Line
Cumulative
Noise Level
(dBA)(1)
46 69.0 3.0 -23.7 -5.0 40.3 20 53.3
Source: LDN 2024.

Note: (1) Complies with the nighttime noise standard of 55 dBA.

Additionally, the noise levels at the nearest retail uses adjacent to the project to the west were analyzed using the same methodology described above. Up to 20 units would be clustered closest to the western property line and would be separated by the rem aining HVAC units by parapet walls and distance. Based on the distance to the property line to the west, noise associated with the operation of the HVAC units are expected to be 48.0 dBA or lower, which is below the 55 dBA nighttime threshold for commercial uses. The multi-family residential property line to the south is located further than the property line to the east, therefore, would also comply.

The noise levels from the proposed roof -mounted HVAC would be considered less than significant at the residential property lines to the east and south the commercial property lines to the west with the

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proposed parapet walls and would be in compliance with the City of San Marcos Municipal Code Section 10.24.

In summary, the proposed project would not result in a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the location general plan or noise ordinance, or applicable standards of other agencies.

Threshold #2: Generation of excessive groundborne vibration or groundborne noise levels.

This section analyzes the potential for the project to expose a person to or generation of excessive vibration or groundborne noise. Proposed residential uses would not be characterized as creating excessive vibration during project operation. The noise mo deling is based upon project construction details and schedule provided by the project applicant. As discussed above, the City does not have adopted vibration criteria. While the project is not subject to FTA or Caltrans regulations, the FTA guidelines serve as a useful tool to evaluate vibration impacts.

Grading
The nearest vibration-sensitive uses are the existing multi -family residential units to the east and to the south on the opposite side of Armorlite Drive. These units, are, on average, over 100 feet from the center of the proposed construction activities. Table 3.8-16 lists the average vibration levels that would be experienced at the nearest vibration sensitive land uses from the temporary construction activities.

Table 3.8-16. Vibration Levels from Construction Activities (Residential Receptors) Equipment
Approximate
Velocity Level at 25
Feet
(VdB)
Approximate
PPV Level at 25
Feet
(in/sec)
Approximate
Velocity Level at
100 Feet
(VdB)
Approximate
PPV Level at 100
Feet
(in/sec)
Small Bulldozer 58 0.003 40.0 0.0004
Jackhammer 79 0.035 61.0 0.0044
Loaded Trucks 86 0.076 68.0 0.0095
Large Bulldozer 87 0.089 69.0 0.0111
FTA Criteria 80(1) 0.2(2)
Significant Impact? No No
Source: LDN 2024.

Notes: (1) FTA criterion for infrequent vibration induced annoyance. (2) FTA criterion for vibration induced structural damage.

The FTA has determined vibration levels that would cause annoyance to a substantial number of people and potential damage to building structures. The FTA criterion guideline for vibration induced structural damage is 0.20 in/sec for the PPV. Project construction activities would result in PPV levels below the FTA’s criteria for vibration induced structural damage. Therefore, project construction activities would not result in vibration induced structural damage to residential buildings near the construction areas during regular construction activities . The FTA criterion for infrequent vibration induced annoyance is 80 VdB for residential uses. Grading activities would generate levels of vibration that would not exceed the FTA criteria for nuisance for nearby residential uses during regular construction activities. Short term grading impacts would be less than significant.

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Blasting Vibration
Blasting for construction projects typically results in an RMS vibration velocity of about 100 VdB at 50 feet from the blast, based on FTA findings. This is equivalent to a PPV of about 0.4 inch per second.

Given attenuation of vibration velocities with di stance, if the blasting activity was located 200 feet from the nearest residence, the vibration and peak particle velocities at the nearest existing residence would be about 82 VdB and 0.05 inch per second, respectively. Based on the construction vibration damage criteria published by the FTA (Table 3.8-7), the threshold vibration levels for damage to "non- engineered timber and masonry buildings" are 94 VdB and 0.20 inch per second. Therefore, the effect of the blasting activity on nearby residential structures would be less than significant.

The FTA human annoyance criterion for Category 2 buildings, which are residences and buildings where people normally sleep is 80 VdB (for infrequent transit noise ). As noted in Table 3.8-6, infrequent events are defined as fewer than 30 vibration events of the same kind per day. This category includes most commuter rail branch lines. This criterion would be slightly exceeded when blasting occurred within about 250 feet of existing residences . However, this project is not a transportation project and is not subject to FTA regulations. Additionally, the potential for short term annoyance would be minimized by following the City’s blasting procedures as stated above in Section

3.8.2, including proper notice to residences and limited hours to between 9:00 AM and 4:00 PM on weekdays. With adherence to Section 17.60.06 of the City’s Municipal Code and the required Blasting Permit from the San Marcos Fire Department, short term blasting vibration impacts would be less than significant.

3.8.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to noise, the cumulative analysis is based upon a li st approach to determine the proposed project’s contributing effect on potential cumulative noise impacts.

Cumulative construction noise and vibration could occur if there are other projects under construction in the vicinity of the proposed project. Based upon the location of the project and the timing for development and location of the cumulative project s included in Table 2 -3, cumulative noise and vibration impacts are not anticipated and impacts would be less than significant.

Future traffic noise levels were analyzed comparing existing traffic with existing plus proposed project traffic levels. This analysis accounts for reasonably foreseeable cumulative traffic levels in the vicinity of the project. As discussed in Section 3.8.4, impacts would be less than significant.

3.8.6 Mitigation Measures
Noise Levels During Rock Drilling and Blasting (Impact N-1) MM-N-1 Prior to issuance of a blasting permit, the project applicant or contractor shall provide the final location of the construction equipment, topography, and construction schedule to the Planning Division. If the rock drill is shown to be

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located within 160 feet from a sensitive land use’s property line, an acoustical engineer shall prepare a noise assessment to determine whether noise levels in excess of the 75 dBA standard would occur during construction.

If the rock drilling and blasting noise assessment determines noise levels at the affected property lines would exceed 75 dBA, the acoustical engineer shall develop a mitigation plan to ensure during rock drilling and blasting would be below 75 dBA at the property line. Potential measures to reduce drilling and blasting noise levels could include: 1) construction of a temporary noise barrier of solid non -gaping material ranging from 8 to 12 feet in height along any property line where the impacts could occu r; 2) limits on usage of the equipment (amount of time used and/or the location in respect to the property line) or other measures to ensure the levels would be below 75 dBA. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

Noise Levels During Rock Crushing (Impact N-2)
MM-N-2 Prior to issuance of a Conditional Use Permit for a rock crusher, the project applicant or contractor shall provide the final location and rock crusher type to the Planning Division. If the rock crusher is shown to be located within 210 feet of a multi-family residential use or within 160 feet of a commercials use without shielding, an acoustical engineer shall prepare a noise assessment to determine whether noise levels would be above the applied threshold of 65 dBA Leq for multi- family residential use and 70 dBA Leq for commercial use.

If th e rock crushing noise assessment determines noise levels at the affected property lines would exceed the standards, the acoustical engineer shall develop a mitigation plan to reduced noise levels to 65 dBA at any existing multi-family use and 70 dBA at an existing commercial use. Mitigation may include sound barriers, sound absorbing materials and/or operational limits on the crusher equipment’s usage. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

3.8.7 Conclusion
Based on the proposed location of construction equipment relative to surrounding land uses, the noise analysis prepared for the project (LDN 2024) concluded that noise impacts during construction would be below City standards and less than significant. However, the potential exists that construction equipment, specifically a rock drill and rock crusher, could be required and staged closer to sensitive uses than anticipated potentially resulting in noise levels exceeding the 75 dBA (8-hour) threshold for rock drilling and the applied operational thresholds of 65 dBA at multi -family uses and 70 dBA at commercial uses during operation of a rock crusher. These potentially significant impacts would be mitigated to below a level of significance through implementation of mitigation measures MM -N-1 through MM-N-2.

Specifically, implementation of mitigation measures MM-N-1 and MM-N-2 provide for preparation of a noise assessment to be prepared prior to issuance of a blasting permit for the rock drill and conditional use permit for the rock crusher to confirm that noise levels would not exceed applicable City standards.

If noise levels would exceed standards, then noise mitigation plans would be prepared and implemented to ensure noise levels are in compliance.

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With incorporation of project design measures, including enhanced balcony shielding consisting of 3.5- foot barriers for residential units with direct line of sight to W. Mission Road and Las Posas Road, operational noise impacts at the project site would not exceed the City’s General Plan Noise Element 65 dBA exterior noise threshold nor increase roadway noise levels by more than 3 dBA. Therefore, impacts related to operational noise would be less than significant.

Construction activities would generate levels of vibration that would not exceed the FTA criteria for nuisance and structural damage for nearby residential uses. If blasting is required within 250 feet of existing residences, the FTA human annoyance criterion (for infrequent transit noise) would be slightly exceeded. However, this project is not a transportation project and is not subject to FTA regulations.

Also, the potential for short term annoyance would be minimized by following the City’s blasting procedures as stated above in Section 3.8.2, including proper notice to residents and limited hours to between 9:00 AM and 4:00 PM on weekdays . With adherence to Section 17.60.06 of the City’s Municipal Code and the required Blasting Permit from the San Marcos Fire Department, s hort term blasting vibration impacts would be less than significant.

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Figure 3.8-1. Ambient Monitoring Location

Source: LDN 2024.

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Figure 3.8-2. Area of Enhanced Shielding on Patios and Balconies

Source: LDN 2024.

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Figure 3.8-3. Modeled Receptor Locations

Source: LDN 2024.

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Figure 3.8-4. Locations of Proposed HVAC Units

Source: LDN 2024.

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3.9 Population and Housing
This section analyzes the potential for impacts related to population and housing resulting from development of the proposed project. This section considers population and housing characteristics in the area and discusses project consistency with regional growth projections.

In the Initial Study prepared for the proposed project (Appendix B.1), implementation of the proposed project was determined to have no impacts related to the displacement of housing or people. There is no existing housing on the project site and the site is vacant. The construction of the proposed project would not displa ce a substantial number of existing homes, necessitating the construction of replacement housing elsewhere, nor would it displace a substantial number of people. This issue is not discussed further in this section. Section 5.10, Environmental Effects Found Not to Be Significant – Population and Housing, of the Environmental Impact Report (EIR) provides additional information on this topic.

Table 3.9-1 summarizes the project - and cumulative-impact analysis by threshold for the proposed project.

Table 3.9-1. Population/Housing Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
Threshold #1: Induce substantial
unplanned population growth in an
area, either directly (for example by
proposing new homes and
businesses) or indirectly (for
example, through extension of roads
or other infrastructure).

Less than Significant Less than Significant Less than Significant Without Mitigation

3.9.1 Existing Conditions
This section provides background information regarding population and housing forecasts for the City of San Marcos based upon demographic information from the San Diego Association of Governments (SANDAG).

Population
As of January 1, 2023, the California Department of Finance (DOF) estimates the population of the City is 94,530 (DOF 2023). Based on growth projections provided by the Series 14: 2050 Regional Growth Forecast prepared by the San Diego Association of Governments (SANDAG), it is estimated that the City’s population growth will reach 104,365 persons by 2035, and 119,098 persons by 2050 (SANDAG 2022).

Housing
As of January 1, 2023, the City of San Marcos had 32,339 housing units. The housing stock is comprised of approximately 59 percent single-family detached and attached units, 31 percent multi- family units, and 10 percent mobile homes (DOF 2023). Based on th e Series 14: 2050 Regional Growth Forecast, the city is expected to have 42,050 housing units by 2050 (SANDAG 2022).

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3.9.2 Regulatory Setting
This section describes the local regulatory setting as it relates to population and housing for the proposed project.

State
California Planning and Zoning Law
The legal framework within which California counties and cities exercise local planning and land use functions is provided in the California Planning and Zoning Law (Sections 65000 through 66499.58 of the California Government Code). Under that law, each county and city must adopt a comprehensive, long-term general plan. The law gives counties and cities wide latitude in how a jurisdiction may create a general plan, but there are fundamental requirements that must be met. The requirements include seven mandatory elements described in the Government Code. Each element must contain text and descriptions setting forth objectives, principles, standards, policies, and plan proposals; diagrams and maps that incorporate data and analysis; and implementation measures.

Once the general plan of a county or city is adopted, it should be construed as a dynamic document, for which adaptability is a key component. Each jurisdiction frequently reviews its general plan for consistency and to ensure it addresses growth-related issues in a comprehensive manner. State law allows up to four general plan amendments per general plan element per year, so each jurisdiction can make changes as justified.

Senate Bill 375
Senate Bill 375 (codified in the Government Code and Public Resources Code) took effect in 2008 and provides a new planning process to coordinate land use planning, regional transportation plans, and funding priorities in order to help California meet the greenhouse gas (GHG) reduction goals established in Assembly Bill 32. Senate Bill 375 requires metropolitan planning organizations to incorporate a Sustainable Communities Strategy (SCS) in their Regional Transportation Plans (RTPs) that will achieve GHG e missions reduction targets by reducing vehicle miles traveled from light -duty vehicles through the development of more compact, complete, and efficient communities.

Regional Housing Needs Allocation
A Regional Housing Needs Allocation (RHNA) is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. The RHNA quantifies the need for housing within each jurisdiction during specified planning periods. Communities use the RHNA in land use planning, prioritizing local resource allocation, and deciding how to address identified existing and future housing needs resulting from population, employment, and household growth. The RHNA does not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that collectively the region and subregion can grow in ways that enhance quality of life, improve access to jobs, promotes transportation mobility, and address social equity and fair share housing needs.

Regional
San Diego Association of Governments
SANDAG is a public agency, composed of 18 cities and the County of San Diego, which builds strategic plans guiding the San Diego region in land use, growth, economics, and the environment. SANDAG

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also provides population and housing estimates for the region, which are based, in part, on local jurisdictional planning data and inform regional planning.

The SANDAG Regional Comprehensive Plan, adopted in 2004, provides a long -term planning framework for the San Diego region. The Regional Comprehensive Plan identified smart growth and sustainable development as important strategies to direct the region’s future growth toward compact, mixed-use development in urbanized communities that already have existing and planned infrastructure, and then connecting those communities with a variety of transportation choices.

In 2011, SANDAG approved the 2050 Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS). This approval marked the first time SANDAG’s RTP included a sustainable communities strategy, consistent with the Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill 375. This RTP/SCS provided a blueprint to improve mobility, preserve open space, and create communities, all with transportation choices to reduce GHG emissions and meet specific targets set by the Cal ifornia Air Resources Board (CARB) as required by the 2008 Sustainable Communities and Climate Protection Act. In 2010, CARB established targets for each region in California governed by a metropolitan planning organization. SANDAG is the metropolitan planning organization for the San Diego region.

San Diego Forward: The 2021 Regional Plan
SANDAG is required by law to update its regional transportation plan every 4 years. In December 2021, SANDAG adopted the most recent update to its RTP/SCS. SANDAG’s 2021 RTP/SCS, known as San Diego Forward: The 2021 Regional Plan (Regional Plan), provides a long -term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal access to jobs, education, healthcare, and other community resources. The plan is the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies. Because the Regional Plan combines the RTP, SCS and Regional Comprehensive Plan, it must comply with specific state and federal mandates that achieves GHG emission reduction targets set by the CARB; compliance with federal civil rights requirements (Title VI); and environmental justice considerations, air quality conformity, and a public participation process.

In September 2022, the SANDAG Board directed staff to prepare an amendment to the 2021 Regional Plan removing the regional road usage charge. In developing the amendment, SANDAG will refine the financial strategies used in the 2021 Regional Plan to achieve the region's GHG emissions target set by the CARB, without the road usage charge. SANDAG will also assess the region's continued ability to meet air quality standards. An Amendment to the 2021 Regional Plan removing the regional road user charge was adopted by the SANDAG Board, in October 2023. The 2025 Regional Plan is currently in development and also will not include a regional road user charge.

The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants. The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications.

Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Di ego region,

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including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.

The project site is located within the SM -3 Mixed Use Transit Corridor as identified in SANDAG Smart Growth Concept Map for North County.

Regional Growth Forecast
SANDAG estimates future population, housing, land use, and economic growth throughout San Diego County and its comprising cities, including the City of San Marcos. In August 2022, SANDAG accepted the Series 14: 2050 Regional Growth Forecast. This forecast serves as the foundation for San Diego Forward: The 2021 Regional Plan and other planning documents across the region. SANDAG growth projections for the region and for the City of San Marcos are outlined in Table 3.9-2 below.

Table 3.9-2. Forecasted Growth for the San Diego Region and the City of San Marcos Jurisdiction
Year Change 2016-2050
2016 2025 2035 2050 Numeric Percent
Population
San Diego Region 3,309,510 3,470,838 3,620,329 3,746,054 436,544 13.2% City of San Marcos 94,258 101,707 104,365 119,098 24,840 26.4% Housing Units
San Diego Region 1,190,555 1,288,207 1,409,853 1,471,286 280,371 23.6 City of San Marcos 30,539 34,250 36,113 42,050 11,511 37.7% Employment
San Diego Region 1,629,948 1,788,970 1,935,565 2,094,017 464.069 28.5% City of San Marcos 41,096 45,786 51,523 63,031 21,935 53.4% Source: SANDAG 2022 Series 14: 2050 Regional Growth Forecast.

The City of San Marcos is expected to experience a higher growth rate for population, housing, and employment when compared to the entire region of San Diego. It should also be noted that the 2050 Regional Growth Forecast is not intended to be an exact for mula utilized to determine growth in the region and comprising jurisdictions; rather it should be utilized as a starting point for regional planning.

Regional Housing Needs Allocation
Based on a methodology that weighs a number of factors (i.e., projected population growth, employment, commute patterns, and available sites), SANDAG determined quantifiable needs for housing units in the region according to various income categories. In its final RHNA figures, SANDAG allocated 3,116 housing units to the San Marcos area for the 2021– 2029 RHNA period. The City has already achieved approximately half of its overall RHNA with housing units constructed, under construction, or approved/entitled or under review (1,585 units). With these units taken into account, the City has fulfilled its allocation of moderate income units and has a remaining RHNA of 1,531 units (640 extremely low/ very low income units, 475 low income units, and 416 above-moderate income units after accounting for the surplus of moderate income units) (City of San Marcos 2021).

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Local
City of San Marcos General Plan
The City’s Housing Element identifies three goals and associated policies that pertain to population and housing:
• Goal H-1: Provide a broad range of housing opportunities with emphasis on providing housing which meets the special needs of the community.
o Policy 1.1: Designate land for a variety of residential densities sufficient to meet the housing needs for a variety of household sizes and income levels, with higher densities being focused in the vicinity of transit stops and in proximity to significant concentrations of employment opportunities.
• Goal H -2: Protect, encourage, and provide housing opportunities for persons of lower and moderate incomes.
• Goal H-4: Reduce or remove governmental constraints to the development, improvement, and maintenance of housing where feasible and legally permissible. o Policy 4.4: Balance the need to protect and preserve the natural environment with the need to provide additional housing and employment opportunities.

The following goal and policy from the City of San Marcos General Plan, Environmental Justice Element pertain to population and housing:
• Goal EJ-4: Foster healthy living conditions for people of all backgrounds o Policy 1.1: Designate land for a variety of residential densities sufficient to meet the housing needs for a variety of household sizes and income levels, with higher densities being focused in the vicinity of transit stops and in proximity to significant concentrations of employment opportunities (See Housing Policy 1.1).

The proposed project’s consistency with applicable General Plan goals and policies is discussed in Table 3.7-7 in Section 3.7, Land Use and Planning, of this EIR. As detailed in Section 3.7.4, the project is consistent with the applicable goals and policies pertaining to population and housing.

The City adopted its 2021-29 Housing Element on July 13, 2021. According to the 2021- 29 Housing Element, the City had already constructed approximately 50 percent (approximately 1,585 units) of its RHNA allocation of 3,116 units with housing units constructed, under construction, or approved.

Based on a residential sites inventory assessment, the City has the ability to adequately accommodate the remaining RHNA requirements within land that currently permits residential development (comprised of proposed applications, vacant residential sites, and vacant land in Specific Plan Areas).

The project site is not identified within the City’s 2021-29 Housing Element inventory assessment as a site that could contribute to the RHNA allocation (City of San Marcos 2021).

3.9.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts. A project may be deemed to have a significant impact to population and housing if it would:

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• Threshold #1: Induce substantial unplanned population growth in an area, either directly (for example by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).

3.9.4 Project Impact Analysis
Threshold #1: Induce substantial population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure).

Increases in population, housing, and employment are generally considered to be social or economic effects, as opposed to physical effects, which are the focus of CEQA analysis. There are circumstances where social and economic changes could indirectly cau se physical environmental impacts or result in changes to environmental resources, such as air quality, traffic, or noise levels. In other situations, lead agencies may evaluate social or economic change related to a physical change in determining whether the physical change is significant (CEQA Guidelines Section 15131).

The approximately 2.44-acre project site is located entirely within the City of San Marcos. A General Plan Amendment is required to re -designate the project site from its existing PI (Public Institutional) designation to Specific Plan Area (SPA). The General Plan Amendment and Rezone would allow the project to build 165 multi -family residential units and 5, 600 s.f. of commercial use on the site. As proposed, 15% of the residential units would be affordable at the very low-income level (30 to 50% of the Area Median Income or AMI).

Construction of the proposed project would result in a temporary increase in construction employment.

Given the relatively common nature and scale of the construction associated with the proposed project, the demand for construction employment would likely be met within the existing and future labor market in the City and North County San Diego area. The size of the construction workforce would vary during the different stages of construction, but a substantial quantity of workers from outside the local area would not be expected to relocate permanently. Therefore, project construction would result in a less than significant impact related to population and employment growth.

The proposed project would directly induce growth through the development of 165 multi -family residential dwelling units. Based on the City’s population rate of 3.1 persons per household, the proposed project would directly induce population growth to the area and would potentially add an estimated 512 people to the area (SANDAG 2022). The proposed project would not, however, indirectly induce a growth in population as no extension of infrastructure is proposed beyond what is required to adequately serve th e proposed project. The SANDAG population growth forecasts rely, in part, on individual jurisdiction’s planning documents, such as the City’s General Plan. Because the project proposes a General Plan Amendment and Rezone, the estimated population of 512 people would not have been accounted for in SANDAG’s projections. Therefore, the project’s induced population would exceed these projections. However, determination of impacts related to population growth are based upon whether the induced growth would be considered substantial.

The future commercial uses are anticipated to have approximately 6 employees. It is expe cted that these employees would come from the local job market and would not require workers to relocate from outside the area. The proposed commercial use would not induce population growth.

As shown in Table 3.9-2 above, the City’s population is projected to grow from 94,258 people in 2016 to 104,365 people by 2035 (an increase of 10,107 people). The population increase of 512 people would account for approximately 5% of SANDAG’s projected population growth.

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There is no hardline number or percentage available to determine whether or not this estimated introduction of 512 people (5% of projected growth) could be considered a substantial increase in population. However, SANDAG’s 2050 Regional Growth Forecast is intended to be used as a starting point for regional planning as opposed to a prescribed growth pattern. Although the City determined that there are adequate sites available with appropriate designations/zoning to accommodate the remaining RHNA allocation for the current Housing Element planning period, the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with approved/constructed residential development (City of San Marcos 2021).

Therefore, while the proposed project would directly induce growth beyond current estimates and forecasts, it would not be considered substantially growth inducing, and impacts would be less than
significant.

3.9.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect.

The cumulative projects are listed in Table 2-3, and include single -family residential and multi-family (affordable and market rate). In addition, commercial, industrial, and institutional developments are proposed or approved. Collectively, the cumulative projects in Table 2 -3 include 3,978 residential units, approximately 852,473 s.f. of commercial/industr ial/office and 122 hotel rooms. When the proposed project is added into these totals it would be 4,143 residential units and approximately 858,073 s.f. of commercial/industrial/office use and 122 hotel rooms. These cumulative projects have the potential to either directly or indirectly induce population growth through development of new housing units and new employment opportunities. It is important to note that the introduction of new residential units and the associated population is not, in and of itself, a significant impact.

As discussed above, SANDAG determined quantifiable needs for housing units in the region according to various income categories. In its final RHNA figures, SANDAG allocated 3,116 housing units to the San Marcos area for the 2021 –2029 RHNA period. After credits for constructed and approved units the City has a remaining 2021-2029 RHNA of 1,5 31nits. The development of the proposed project and the cumulative projects would assist the City in meeting its RHNA goals, including goals for affordable housing. Additionally, for the longer term as shown in Table 3.9-2, SANDAG has forecasted an increase of population (26.4% increase), housing (37.7% increase) and employment (53.4% increase) for the City from 2016 to 2050. The growth associated with the proposed project and the cumulative projects, combined, would be wit hin the long -term forecasts from SANDAG. Therefore, cumulative impacts associated with population and housing would be less than significant.

3.9.6 Mitigation Measures
Based upon the analysis presented in Sections 3.9.4 and 3.9.5, impacts were determined to be less than significant. No mitigation measures are required.

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3.9.7 Conclusion
Physical impacts related to population growth associated with the proposed project are addressed throughout the topic -specific chapters of this EIR. See Sections 3.1 through 3.13. When significant impacts were identified in the EIR, mitigation measures hav e been identified to reduce impacts to below a level of significance. All impacts would be mitigated to below a level of significance.

Construction of the proposed project would represent a temporary increase in construction employment. Given the relatively common nature and scale of the construction associated with the proposed project, the demand for construction employment would likely be met within the existing and future labor market in the City and North County San Diego area. The size of the construction workforce would vary during the different stages of construction, but a substantial quantity of workers from outside the local are a would not be expected to relocate permanently. Impacts would be less than significant.

As discussed above, the proposed project would introduce an estimated 512 people resulting from the development of 165 multi-family residential units. Based upon regional projections, comparisons to current land use designations, and comparison with the RHNA planning periods, the introduction of the estimated 512 people would not be considered substantial. The future commercial uses are anticipated to have approximately 6 employees. It is expected that these employees would come from the local job market an d would not require workers to relocate from outside the area. The proposed commercial use would not induce population growth. Impacts would be less than significant.

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3.10 Public Services
Introduction
This section analyzes the potential impact of the proposed project on public services including fire protection services, police protection services, schools, and libraries. Please see Section 3.13, Utilities and Service Systems, for an analysis of water, wastewater, energy, telecommunications, stormwater, and solid waste services. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, i ncluding the City of San Marcos General Plan. The General Plan is available on the City’s web site. 18 Service provider letters are
included in Appendix Q of the Environmental Impact Report (EIR). In the Initial Study prepared for the proposed project ( Appendix B.1 ), it was determined that with the provision of on -site recreational amenities and payment of Public Facility Fees (PFF), impacts to recreational facilities would be less than significant. Section 5.11, Environmental Effects Found Not to be Significant - Public Services, of the EIR provides additional information on th is topic.

Table 3.10 -1 summarizes the project - and
cumulative-level public services analysis impact, by threshold of significance.

Table 3.10-1. Public Services Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for:

Fire protection services Less than
Significant Less than Significant
Less than
Significant
Without Mitigation
Police protection services Less than
Significant Less than Significant
Less than
Significant
Without Mitigation
Schools Less than
Significant Less than Significant
Less than
Significant
Without Mitigation
Other public facilities (Libraries) Less than
Significant Less than Significant
Less than
Significant
Without Mitigation

3.10.1 Existing Conditions
This section details the existing service providers and resources related to fire protection, police protection, schools, parks, and libraries.

18 http://www.san-marcos.net/work/economic-development/general-plan

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Fire Protection
The San Marcos Fire Department (SMFD) would provide fire protection and emergency medical services to the project. The SMFD has existing automatic mutual aid fire agreements in place with the Cities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District. The SMFD has an Insurance Service Office Rating 1, on a scale of one to ten with one being superior service.

The SMFD currently operates 4 fire stations, 4 paramedic assessment engine companies, 1 paramedic assessment truck company, 5 paramedic transport ambulances (24-hour units), 1 shift battalion chief, and 1 on -call duty chief. SMFD also cross -staffs three wi ldland fire engines and a State of California/Office of Emergency Services wildland fire engine (City of San Marcos 202 4). The Department also cross-staffs three wildland fire engines and a State of California/Office of Emergency Services (Cal/OES) wildland fire engine.

The SMFD Station 1, located at 180 W. Mission Road in San Marcos, is the closest station to the project site and would likely serve the project site should fire response or emergency services be needed (City of San Marcos 202 4). SMFD Station 1 is located approximately 1.4 miles east of the project site. SMFD Station 1 houses an engine, truck, brush engine, ambulance, and battalion chief.

Police Protection
The San Diego County Sheriff’s San Marcos Station provides law enforcement services to the city and unincorporated communities of Harmony Grove, Elfin Forest, Lake San Marcos, Hidden Meadows, Ivy Del, Del Dios, Lake Hodges, and the San Pasqual Valley (SDCS D 2024). The San Marcos Station is located at 182 Santar Place, approximately 2.3 miles east of the project site.

Law enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services (City of San Marcos 2012a). Services are available 24 hours a day, 7 days a week.

The San Marcos Station serves more than 111,000 residents and staffs more than 100 deputies, volunteers, and professional staff members. Additionally, Community Oriented Police and Problem - Solving teams are assigned to investigate community quality -of-life issues. Lastly, the Sheriff’s San Marcos Station has the only Aerial Support to Regional Enforcement Agencies helicopter landing pad in the County, which assists ground units and extends the range deputies can patrol (SDCSD 2024).

The County Sheriff’s Department does not set response time goals. The Sheriff’s Department does, however, prioritize different types of calls to better facilitate deputy dispatches. The Sheriff Department’s priority categories are as follows: priority level 1 (lifesaving response calls), priority level 2 (expeditious response calls within confines of vehicle codes), priority level 3 (calls responded to as soon as possible), and priority level 4 (calls responded to when clear, still being alerted to violatio ns that require immediate law enforcement action) (City of San Marcos 2012a).

Schools
The project site is located within the San Marcos Unified School District (SMUSD). SMUSD is 49 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. As of 2023, there were 10 elementary schools, two K–8 schools, three middle schools, three

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high schools, and one independent high school program that are a part of the SMUSD. SMUSD serves more than 19,500 students (SMUSD 2024a).

Based upon information from SMUSD , the project site falls within the attendance boundaries of La Mirada Academy (Grades TK-8) and San Marcos High School (Grades 9-12). La Mirada Academy has a maximum capacity of 1,202 students with a 2023/24 school year enrollment of 890 students. San Marcos High School has a maximum capacity of 3,184 students, which is currently being exceeded with a 2023/24 school year enrollment of 3,195 students (SMUSD 2024b).

Other Public Facilities (Libraries)
The San Diego County Library system has 33 branches, two bookmobiles, and five kiosks (San Diego County Library 2024). The City is served by the San Diego County Library, San Marcos Branch located at 2 Civic Center Drive, approximately 1.6 miles southeast of the project site. The San Marcos Branch is 15,394 square feet (s.f.) (City of San Marcos 2012b). The library is open seven days a week.

3.10.2 Regulatory Setting
Local
San Marcos General Plan
The following are applicable goals and policies from the City of San Marcos General, Land Use and Community Design Element related to public services:

Land Use and Community Design Element
• Goal LU -8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU -8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities. • Goal LU-10: Fire protection, emergency services, and law enforcement: Provide effective, high- quality, and responsive services.
o Policy LU -10.1: Provide demand -based firefighting and emergency medical services infrastructure, equipment, and personnel to provide a high level of fire, emergency medical, and law enforcement service in San Marcos to meet existing and future demands. o Policy LU -10.2: Work closely with the County of San Diego Sherriff’s Department to determine and meet the community needs for adequate personnel, equipment, and state- of-the-art technology to effectively combat crime, and meet existing and projected service demands.
o Policy LU-10.3: Continue to conduct public outreach and education regarding fire safety and crime prevention within San Marcos.
• Goal LU-11: Schools: Ensure all residents have access to high-quality education. o Policy LU-11.1: Collaborate with the local public school district (SMUSD), private schools, and institutions of higher learning to ensure a range of traditional and distance -learning

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educational opportunities are provided in superior, accessible facilities that complement the surrounding land uses.
o Policy LU-11.2: Work with San Marcos Unified School District and developers to ensure adequate school facilities are funded as required by State law and through developer mitigation agreements between the school district and the developer. The City shall require a “will serve” letter substantiating that the developer has paid fees to the satisfaction of the school district prior to issuance of building permits. • Goal LU -12: Libraries: Provide library resources and services that meet the needs of the community.
o Policy LU-12.1: Provide adequate library facilities and technological access that enhance San Marcos’s quality of life and create a civic environment with vast opportunities for self- learning and academic enrichment.
o Policy LU-12.2: Accommodate technological needs of the community and locate accessible technology in the library.

Safety Element
The following are applicable goals and policies from the City of San Marcos General Plan, Safety Element related to public services, including fire protection, police protection, parks, and libraries:
• Goal S -3: Minimize injury, loss of life, and damage to property resulting from structural or wildland fire hazards.
o Policy S-3.1: Require development to be located, designed, and constructed to provide adequate defensibility and reduce the risk of structural loss and life resulting from wildland fires. Development will consider hazards relative to terrain, topography, accessibility, and proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead fire sprinklers. o Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire. Advocate and support regional coordination among fire protection and emergency service providers.
o Policy S-3.3: Require development to provide additional access roads when necessary, to provide for safe access of emergency equipment and civilian evacuation concurrently. o Policy S-3.4: Coordinate with fire protection and emergency service providers to assess fire hazards before and after wildfire events to adjust fire prevention and suppression needs, as necessary, commensurate with both short- and long-term fire prevention needs. • Goal S-6: Provide neighborhood safety through effective law enforcement. o Policy S-6.1: Continue to maintain demand-based law enforcement service levels to reduce the risk of criminal activity.
o Policy S -6.2: Continue public education efforts and community outreach programs to promote community involvement in crime and drug prevention. o Policy S-6.3: Use Crime Prevention through Environmental Design (CPTED) principles in the design or redevelopment of projects and buildings.

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Environmental Justice Element
The following are applicable goals and policies from the City of San Marcos General Plan, Environmental Justice Element related to parks:
• Goal EJ-2: Locate public facilities and services equitably throughout the community. o Policy EJ-4.12: Use Crime Prevention through Environmental Design (CPTED) principles in the design or redevelopment of projects and buildings (See Policy S-6.3).

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As detailed in Table 3.7-7 in Section 3.7, Land Use and Planning, the project is consistent with all applicable goals and policies related to public services.

San Marcos Municipal Code
Section 17.44 – Development Services and Public Facilities Exactions, Fees, and/or Costs This code requires that each applicant for a grading, construction, building and/or development permit or entitlement shall, prior to the issuance of such permit or entitlement, pay the fees including Development Services Fees and Public Facilities Fees (PFF).

3.10.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to public services are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to public services would occur if the project would:
• Threshold #1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: fire protection, police protection, schools and other public facilities.

3.10.4 Project Impact Analysis
Threshold #1: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire Protection
As discussed in Section 3.10.1, above, the SMFD provides fire protection services to the city and would serve the project site. The proposed project would increase the demand for SMFD resources as a result of the development of residential uses and the associated population increase (512 residents), as well as the proposed new commercial uses. These future residents and employees would increase the need for fire protection services through routine fire and emergency medical calls. As a condition of project approval, prior to the issuance of a grading permit, the applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property,

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the special taxes levied by the following Community Facility District: CFD 2001 -01 (Fire and Paramedic)19. This would offset the project’s increase in demand for fire protection services. Thus, while new development places increased demand on fire protection services, it is not anticipated that the proposed project would result in the need for construction of new fire facilities or expansion of existing fire facilities. The project would not result in substantial adverse physical impacts associated with the provision of new fire protection facilities and impacts would be less than significant.

Police Protection
As discussed in Section 3.10.1, above, the San Diego County Sheriff’s Department provides law enforcement services to the city. More specifically, the project would be served by the San Marcos Station, located approximately 2.3 miles from the project site. The project would introduce approximately 512 residents on-site, resulting in an increased de mand for existing police protection resources. The increased density of development on the project site would be expected to increase the frequency of emergency a nd non -emergency calls to the Sherriff’s Department. However, as discussed in Section 3.10.1 above, over 100 deputies, volunteers, and professional staff serve the residents of the city. Law enforcement services include general patrol, criminal investigati on, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services. Unlike fire services, which respond solely to emergencies, law enforcement services consist of patrolling larg e areas 24 hours a day, 365 days a year. Police units are continuously mobile, and service calls are responded to by the nearest available mobile unit. At the San Marcos Station, patrol deputies are assigned to a geographical “beat” area, allowing deputies to become familiar with citizens and problems within their “beats”. As such, the location of the proposed project relative to the nearest station would not affect police protection. Further, to minimize the increased demand for police protection services, the project has been designed to improve the safety for future residents and visiting guests. Safety features proposed for the project include walls, fencing and lighting as described in Section 2.2.3 (Chapter 2, Project Description). Additionally, as a condition of project approval, prior to the issuance of a grading permit, the applicant/developer/property owner would submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the followin g Community Facility District: CFD 98 -01 (Police) . Thus, while new development places increased demand on police protection services, it is not anticipated that the proposed project would result in the need for construction of new police facilities or expansion of existing police facilities. Therefore, the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police facilities. Impacts resulting from the propose d project would be less than
significant.

Schools
The project site is located within the service boundary of the SMUSD. Per SMUSD the following schools would serve the project:
• La Mirada Academy (grades K-8), 3697 La Mirada Drive, San Marcos • San Marcos High School (grades 9-12), 1615 W. San Marcos Boulevard, San Marcos Table 3.10-2 presents the number of students anticipated to be generated by the 165-unit residential portion of the project. As shown in Table 3.10 -2, the project would generate 4 TK students, 13

19 https://www.san-marcos.net/home/showpublisheddocument/24248/637163295768400000

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elementary school students, 9 middle school students, and 13 high school students for a total of 39 students.

Table 3.10-2. Student Generation
Grade Generation Rate(1) Number of Units
Proposed Students Generated
TK 0.0206 165 4
K-5 0.077 165 13
6-8 0.051 165 9
9-12 0.074 165 13
Total Students 39
Source: SMUSD 2024b.

Note: (1) SMUSD has rates for single family, multifamily and apartments. The apartment rate was used for the project.

Based upon information from SMUSD, San Marcos High School is currently over capacity (SMUSD 2024b) and SMUSD as a whole is experiencing capacity issues. The addition of students generated by the project would contribute to the se District-wide capacity issues. The project applicant shall pay school mitigation fees pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) in effect at the time of building permit issuance. Current Level II school fees are $5.17/s.f. $4.79/s.f. for residential development and $0.84/s.f. $0.78/s.f. for commercial development ( SMUSD 2023). Further, consistent with General Plan Policy LU -11.2, the applicant shall provide a letter from the school district to the City prior to the issuance of building permits confirming these fees have been paid.

Payment of these fees would assist in funding SMUSD’s long -range plans. Senate Bill (SB) 50 states that the fees imposed by school districts shall constitute the exclusive method of considering and mitigating impacts on school facilities caused by a development project. Such payment shall provide “full and complete mitigation of the impacts of any legislative or adjudicative act...on the provision of adequate school facilities” (Government Code Section 65995(h)). As such, with contribution of required development fees, impacts to schools would be
less than significant.

Other Public Facilities (Libraries)
The project would develop 165 residential units, introducing approximately 512 new residents at the project site. Although not all of these residents would be new residents to the city, the generation of residents at the project site would increase the demands on other public facilities, including library services and additional resource s. However, additional library services are available in the County through the Serra Cooperative Library System and California State University San Marcos (CSUSM).

The Serra Cooperative Library System is a network of public, academic, and special libraries in the southern California counties of Imperial and San Diego. Serra helps member libraries provide expanded resources and services at reduced costs. The City of Oceanside Library and the City of Carlsbad Library are Serra member libraries in North County San Diego. CSUSM also allows community members to obtain a Community Borrow Card by showing a valid photo identification (CSUSM 2023).

Community members can also borrow ma terials at Palomar College with a valid photo identification and proof of current mailing address (Palomar College 2023). Thus, while new development places increased demand on library services and facilities, it is not anticipated that the proposed project would result in the need for construction of new library facilities or expansion of existing library

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facilities. Therefore, adequate library services are available to serve the proposed project, and a less than significant impact is identified for this issue area.

3.10.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to public services, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to public services (see Table 2-3, Cumulative Projects).

Fire Protection Services
The geographic area for the cumulative analysis of fire protection and emergency services is those areas that are serviced by the SMFD. The cumulative projects that fall within this geographic area would add to the increase in demand for fire protection an d emergency services, and the potential need for additional fire protection resources. The SMFD provides service to the City of San Marcos and has existing automatic mutual aid fire agreements in place with the Cities of Carlsbad, Vista, Escondido, Encinit as, and the Rancho Santa Fe Fire Protection District. However, all cumulative projects would be required to participate in existing Community Facilities Districts as determined necessary. Future projects would be required to offset the increase in demand c aused by their respective projects. Development fee payments would go towards providing the additional staff and equipment that would be needed by SMFD in the future to provide fire protection services, including potential new fire stations. Similarly, to offset any potential cumulative impacts to fire protection services, the project would pay all required development impact fees. Thus, cumulative impacts to fire protection services would be
less than significant.

Police Protection Services
The geographic area for the cumulative analysis of police protection is those areas that are serviced by the San Diego County Sheriff’s Department. All cumulative projects listed in Table 2-3 would result in an increase in demand for police protection serv ices from the Sheriff’s Department, and the potential need for additional police protection resources. Nonetheless, all cumulative project s would be required to offset increased demand for police protection services through the payment of fees.

These fees would provide for additional staff and equipment to assist in the provision of law enforcement services. As such, with payment of fees, cumulative impacts to police protection services would be
less than significant.

Schools
Based upon information from SMUSD, there are district -wide capacity issues including San Marcos High School, which is currently over capacity (SMUSD 2024b). The addition of students generated by the project along with cumulative development projects would contribute to the district-wide capacity issues.

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As discussed in Section 3.10.4, the proposed project would be required to contribute development fees to SMUSD, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal C ode Section 17.52.050. All the cumulative projects included in Table 2 -3 that include residential development would result in increased demand for school services and would be required to pay school fees to offset the increased demand, similar to the proposed project. Additionally, non-residential projects are also required to pay school fees consistent with SMUSD’s developer fee schedule. As such, with contribution of required development fees by the proposed project and cumulative development projects, cumulative impacts to schools would be
less than significant.

Other Public Facilities (Libraries)
Cumulative projects within the service area of the San Marcos Branch Library would result in an increase in demand for library services. However, additional library services are available in the County through the Serra Cooperative Library System and Calif ornia State University San Marcos (CSUSM).

Community members can also borrow materials at Palomar College with a valid photo identification and proof of current mailing address (Palomar College 2023). Therefore, adequate library resources are available to serve cumulative development in San Marcos, and cumulative impacts to library services would be
less than significant.

3.10.6 Mitigation Measures
No significant impacts to public services were identified; thus, no mitigation measures are required.

3.10.7 Conclusion
Development of the proposed project would result in an increase in demand for fire protection, emergency medical services, police protection, school services, and library facilities. However, the project applicant would be required to pay all applicable development fees including payment of school mitigation fees, and development fees. These fees are utilized to provide improvements to public services in San Marcos, including fire and police protection, schools, and libraries The payment of all required development fees by the proposed project and cumulative development projects would offset any potential cumulative impacts to public services. The project applicant would also annex into CFD 2001-01 (Fire and Paramedic) and CFD 98 -01, Improvement Area No. 1 (Police) which would offset and minimize potential impacts. As such, with payment of fees towards schools, fire, and police, impacts to public services would be
less than significant.

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3.11 Transportation
This section provides a transportation impact analysis for the proposed project related to transit, roadway, bicycle and pedestrian facilities, vehicle miles traveled, design feature hazards and emergency access. The section is based on the following reports, which are included as Appendices O and R of the Environmental Impact Report (EIR):
• Local Transportation Analysis, Armorlite Lofts . Prepared by Linscott Law & Greenspan, November 4, 2024 (LLG 2024a)
• Vehicle Miles Traveled (VMT) Study, Armorlite Lofts. Prepared by Linscott Law & Greenspan, November 4, 2023 (LLG 2024b)
In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to substantially increase hazards due to a design feature or result in inadequate emergency access. Section 5.13, Environmental Effects Found Not to be Significant – Transportation, of the EIR provides additional information on these topics.

Section 3.7 (Land Use and Planning) includes a description of existing traffic conditions, methodology, baseline conditions and trip generation for the local transportation analysis/level of service (LOS) analysis. Table 3.7-7 in Section 3.7 analyzes the project’s consistency with the Mobility Element of the General Plan. Table 3.11-1 summarizes the project- and cumulative-level traffic impact analysis, by threshold.

Table 3.11-1. Transportation Summary of Impacts
Thresholds of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1: Conflict with a program plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle, and
pedestrian facilities?
No Impact Less than
Significant
Less than
Significant
Without Mitigation
#2: Would the project conflict or be inconsistent
with CEQA Guidelines Section 15064.3,
subdivision (b)?
Less than
Significant
Less than
Significant
Less than
Significant
Without Mitigation

3.11.1 Existing Conditions
The City strives to create a robust, city -wide system of roadways, bicycle and pedestrian paths and routes, as well as public transit options, which provide residents with alternative modes of travel as well as recreational opportunities.

Existing Roadways
Access to the project site from the regional transportation network would be provided via California State Route 78 (SR -78) freeway, Las Posas Road , W. Mission Road, and Armorlite Drive. These facilities will either provide a direct connection to the project site via project driveway or will provide a critical link between the project site and the regional transportation network.

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Existing Transit Service
Transit service is provided to the area via North County Transit District (NCTD). The nearest bus stop is located about 500 feet south of the project site (2-minute walk), just south of the Armorlite Drive / Las Posas Road intersection. This bus stop serves bus routes 347, 445 and 645. The Palomar College Station, which serves the SPRINTER, is located about 1,000 feet east of the W. Mission Road / Las Posas Road intersection (8 -minute walk from the project site). Continuous sidewalk connectivity is provided between the project site and these transit stops. A description of the nearest transit service is as follows:
• Bus Route 347 provides bus service to the area via Mission Road and Las Posas Road, within the City of San Marcos. During weekdays, headways are 30 minutes for the duration of the day. During Saturdays, headways are one hour for the duration of the day. • Bus Route 445 provides bus service to the area via W. Mission Road and Las Posas Road, connecting Carlsbad to San Marcos. During weekdays, headways are one hour for the duration of the day. This bus route does not run on weekends.
• Bus Route 645 provides bus service to the area via W. Mission Road and Las Posas Road, within the City of San Marcos. During weekdays, there are only two services in the morning starting at 7:50 AM, and only one service in the afternoon sometime between 3:30 PM and 3:50 PM.
• The SPRINTER runs between Escondido and Oceanside. There are 15 stops along this route.

SPRINTER service provides 34 daily trips on the weekdays with an additional six trips on Friday nights. It also provides 25 daily weekend trips with an additional three trips on Saturday nights.

Existing Bicycle Infrastructure Conditions
Currently, there are bike lanes on both sides of W. Mission Road, and they are a mix of Class I, Class II and Class III depending on the location. Closest to the project site is a Class I bike lane which runs on the north side of W. Mission Road west of Pacific Street, and on the south side of W. Mission Road east of Pacific Street. This Class 1 bike lane is associated with the Inland Rail Trail. Additionally, a Class I Multi-Use Path currently exists along the north side of Armorlite Drive, between Las Poses Road and Bingham Drive along the project frontage.

Planned Bicycle Infrastructure
In the City’s Active Transportation Plan, (ATP) recommendations for future bicycle classifications are characterized as interim and ultimate conditions. The interim bicycle network is composed of recommendations that can be accomplished in the near term without requiring redevelopment, right- of-way, or easements, or major environmental documentation/ permitting. The ultimate network contains long-term recommendations that can be completed over time as the City redevelops and right-of-way is acquired. In some cases, and ultimate improvement may be constructed first, rendering the interim improvement unnecessary.

Under interim and ultimate conditions, the existing Class I Multi -Use Path on Armorlite Drive will be extended east to Vallecitos de Oro. From there it would split with one segment connecting to Furniture Row and another segment connecting to Knoll Road (City of San Marcos 2023).

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Existing Pedestrian Connections
Existing sidewalk connection is provided between the p roject site and the Palomar College Station SPRINTER Station and area bus stops via Armorlite Drive to Las Posas Drive. Sidewalks are provided on both sides of Armorlite Drive and other study area roadways except for the south side of W. Mission Road from Pacific Street to 350 feet west, the north side of W. Mission Road from Pacific Street to 170 feet west, and the north side of W. Mission Road from Pacific Street to 670 feet east. There are no plans to add or alter sidewalks within the immediate project vicinity according to the City’s ATP (City of San Marcos 2024).

3.11.2 Regulatory Setting
The following provides a general description of the applicable regulatory requirements and guidelines for the project area.

State Regulations
California Department of Transportation
The California Department of Transportation (Caltrans) is the primary state agency responsible for transportation issues. One of its duties is the construction and maintenance of the state highway system. Caltrans has established standards for roadway traffic flow and has developed procedures to determine if intersections require improvements. For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. For projects that would not physically affect facilities but may influence traffic flow and levels of services at such facilities, Caltrans may recommend measures to mitigate the traffic impacts of such projects.

AB 1358 – California Complete Streets Act of 2008
The California Complete Streets Act of 2008 (Assembly Bill [AB] 1358) requires circulation elements as of January 1, 2011 to consider the transportation system from a multi-modal perspective, including public transit, walking, and biking, which have traditionally been marginalized in comparison to autos in contemporary American urban planning.

SB 743, CEQA Guidelines Update
In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package, which included the California Natural Resources Agency Guidelines for the Implementation of CEQA. As a result, the California Governor’s Office of Planning and Research (OPR) updated and released the Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory) in December 2018. According to the updated guidelines, lead agencies had until July 1, 2020 to comply with the updated CEQA revision. The City of San Marcos has adopted Vehicle Miles Traveled (VMT) thresholds as part of their Transportation Impact Analysis Guidelines (City of San Marcos 2020).

While VMT is the preferred quantitative metric for assessing potentially significant transportation impacts under CEQA, it should be noted that SB 743 does not prevent a city or county from using metrics such as LOS as part of the application of local gene ral plan policies, municipal and zoning codes, conditions of approval, or any other planning requirements through a city’s planning approval process; cities can still ensure adequate operation of the transportation system in terms of transportation congestion measures related to vehicular delay and roadway capacity. As such, the City

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can continue to require congestion -related transportation analysis and mitigation projects through planning approval processes outside CEQA. Section 3. 7, Land Use and Planning, includes results of the LOS analysis prepared for the project.

Local Plans and Policies
SANDAG San Diego Forward: The 2021 Regional Plan
The Regional Plan, adopted in 2021 by the San Diego Association of Governments (SANDAG), provides a long-term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal access to jobs, educat ion, healthcare, and other community resources. The plan is the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative transportation demand and management strategies.

The Regional Plan combines the Regional Comprehensive Plan and the Regional Transportation Plan/ Sustainable Communities Strategy (RTP/SCS). By integrating land use and transportation plans, the Regional Plan is intended to achieve greenhouse gas emission reduction targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act.

The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the city and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants. The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications.

Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Di ego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.

The Regional Plan also supports other regional transportation planning and programming efforts, including overseeing which projects are funded under the Regional Transportation Improvement Program and the TransNet program. SANDAG is applying data -driven strategies, innovative technologies, and stakeholder input to create a future system that is faster, fairer, and cleaner. Part of this data-driven approach includes the implementation of five key transportation strategies referred to as the 5 Big Moves. Thes e strategies provide the framework for the Regional Plan and consider policies and programs, changes in land use and infrastructure, the existing transportation highway and transit networks, and trends in technology to optimize use of the transportation sy stem. Together, these initiatives will create a fully integrated, world -class transportation system that offers efficient and equitable transportation choices, meets state climate targets, and supports local jurisdictions’ achievements of Climate Action Plan goals.

In September 2022, the SANDAG Board directed staff to prepare an amendment to the 2021 Regional Plan without the regional road usage charge. In developing the amendment, SANDAG will refine the financial strategies used in the 2021 Regional Plan to achieve the region's greenhouse gas emissions target set by CARB, without the road usage charge. SANDAG will also assess the region's continued ability to meet air quality standards. An Amendment to the 2021 Regional Plan removing the regional road user charge was adopted by SANDAG in October 2023. The 2025 Regional Plan is currently in development and will not include a regional road user charge.

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SANDAG Smart Growth Opportunity Area
The project site is located within the SM -3 Mixed Use Transit Corridor as identified in the SANDAG Smart Growth Concept Map for North County. The Smart Growth Concept Map identifies locations in the region that can support smart growth, transit, walking, and biking. The map serves as the foundation for prioritizing transportation investments and determining eligibility for local smart growth incentive funds.

Congestion Management Program
The 2008 Congestion Management Program (CMP) for San Diego County was developed to meet the requirements of Section 65089 of the California Government Code. Since that time, the local agencies within San Diego County approved to opt out of the CMP requirem ents, as allowed within the Government Code. As such, there are no CMP -specific requirements associated with this project.

However, to ensure the region’s continued compliance with the federal congestion management process, SANDAG has prepared San Diego Fo rward: The 2021 Regional Plan in compliance with 23 Code of Federal Regulations 450.320. The Regional Plan incorporates performance monitoring and measurement of the regional transportation system, multimodal alternatives to single -occupancy vehicles, land use impact analysis, congestion management tools, and Integration with the Regional Transportation Improvement Program process.

City of San Marcos Transportation Impact Analysis Guidelines The City of San Marcos approved Transportation Impact Analysis Guidelines (TIAG) on November 16, 2020 (City of San Marcos 2020). The TIAG provide screening criteria for determining whether a land development project should conduct a VMT analysis. These thresholds are based on the project’s consistency with the General Plan, estimated daily trips, project location, and other project characteristics. A VMT analysis applies to all land development projects except for those that meet at least one of the provided screening criteria.

City of San Marcos Active Transportation Plan
The City’s Active Transportation Plan (ATP) supplements the General Plan Update by recommending specific pedestrian and bicycle -related projects, programs, and policies for the City. The ATP Plan focuses on encouraging non -motorized modes of transportation – primarily walking and biking - by recommending projects, programs, and policies that enhance the active transportation experience in the community. The ATP evaluates the current state of walking and biking opportunities; analyzes user demographics, safety data and more; engages community members; and provides recommendations to support mobility in the city. The ATP also incorporates a Safe Routes to School (SRTS) Study to identify challenges associated with the schools located within the San Marcos Unified School District.

The ATP will be used to create active transportation -oriented projects for the City’s Capital Improvement Program (CIP) and for construction as required by the city for private development projects.

In the City’s ATP, recommendations for future bicycle classifications for each roadway were broken down into interim and ultimate conditions. The interim bicycle network is composed of recommendations that can be accomplished in the near term without requiring redevelopment, right- of-way, or easements, or major environmental documentation/ permitting. The ultimate network contains long-term recommendations that can be completed over time as the City redevelops and right-of-way is acquired. In some cases, and ultimate improvement may be constructed first, rendering the interim improvement unnecessary.

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Developers will be required to implement the ultimate bicycle network recommendations when considering setbacks, frontage improvements, and design, and may be required to construct the ultimate facilities based upon roadway characteristics, adjacent facilities, and the ability to design and construct safe transitions into the ultimate improvements. For two -way bicycle facilities —such as a Class I multi-use path or a Class IV two-way bikeway—the City may require a developer to construct or provide setbacks for these types of facilities that may be identified on the side of the roadway opposite the project’s frontage. Locations of desired facilities may, in some cases, be placed on either side of the roadway, at the discretion of the City. Parallel facilities may be required by the City as opportunities arise to create similar connectivity on other routes. The City may require other connectors between the high-level infrastructure shown in this plan in order to ensure a seamless network.

San Marcos Transportation Demand Management (TDM) Ordinance and Policy To implement the City’s Climate Action Plan measures and to reduce traffic impacts from development projects, the City of San Marcos adopted a TDM Ordinance and Policy in December 2023. The TDM Ordinance and Policy will be applicable to any development project that is not exempt from CEQA requirements and would result in emission of more than 500 metric tons of carbon dioxide (MT of CO 2)
per year. Projects that are subject to this Ordinance shall submit a project specific TDM Plan for the City’s review and approval with the entitlement application to show compliance with the TDM Policy and Ordinance.

Its intent is to encourage a shift away from single-occupancy vehicles to alternative travel options such as walking, biking, carpooling, or taking transit. Reducing reliance on roadways will likewise result in reduced congestion, vehicle miles traveled, and greenhouse gases. The TDM policy lists six mandatory strategies that are required for all projects to implement and 29 optional strategies, each assigned a specific point value. Applicable projects would have to establish a project specific TDM Plan that should include all mandatory and a selection of optional strategies to achieve a minimum of a ten-point score.

San Marcos General Plan
The Land Use and Community Design Element of the General Plan identifies specific policies related to congestion management. Those that are applicable to the proposed project are identified below. • Goal LU -1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community. o Policy LU-1:1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices.
• Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
o Policy LU-3.4: Provide non-motorized (pedestrian and bicycle) access/circulation within, and to mixed-use centers to reduce reliance on the automobile. o Policy LU -3.5: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways.
o Policy LU -3.7: Require new development to prepare traffic demand management programs.

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o Policy LU -3.8: Require new development and discretionary actions to annex into a Congestion Management Community Facilities District.

The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to the transportation analysis for the propos ed project are identified below. Policy M -1.4, which addresses LOS, is analyzed in Section 3.10, Land Use and Planning. • Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods. o Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map. o Policy M -1.2: Require new development to finance and construct internal adjacent roadway circulation and City-wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian, and bicycle facilities. o Policy M -1.3: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the city.
o Policy M-1.4: Utilize multi-modal LOS techniques to evaluate transportation facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
 LOS D or better for Vehicles as a prioritized mode
⸋ Generally, provides facilities that have minimum vehicle congestion during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
 The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).
o Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network. o Policy M-1.7: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor. • Goal M-2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.
o Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate, within residential neighborhoods, while maintaining the City’s desire to provide connectivity on the roadway network. o Policy M-2.3: Consider roundabouts, as appropriate, as an intersection control device with demonstrated air quality, traffic efficiency, and safety benefits. • Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City.

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o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City.
o Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance, and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate. o Policy M-3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.
o Policy M-3.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians.
o Policy M -3.9: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian-scale lighting, way finding signage, transit shelters, and other approp riate amenities.

The Environmental Justice Element of the General Plan identifies specific goals and policies related to access to and facilitation of walking, bicycling, and transit use. Those that are applicable to the proposed project are identified below.
• Goal EJ -1: Reduce greenhouse gas emissions, enhance air quality, and reduce impacts associated with climate change.
o Policy EJ -1:1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices (See Policy LU-1.1). o Policy EJ -1.3: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use (See Policy LU -

2.1).
o Policy EJ -1.6: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the city (See Policy M-1.3). o Policy EJ-1.8: Develop an integrated multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City (See Policy M-3.1).
• Goal EJ-2: Locate public facilities and services equitably throughout the community. o Policy: EJ-2.10: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network (See Policy M-1.6). o Policy: EJ-2.11: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all

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modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor (See Policy M-1.7). • Goal EJ-5: Encourage physical activity and improved physical fitness. o Policy: EJ-5.1: Provide non-motorized (pedestrian and bicycle) access/ circulation within, and to, mixed-use centers to reduce reliance on the automobile (See Policy LU-3.4). o Policy EJ - 5.2: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways (See Policy LU-3.5).
o Policy EJ-5.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians (See Policy M-3.5). o Policy EJ -5.6: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian-scale lighting, way finding signage, transit shelters, and other appro priate amenities (See Policy M-3.9).

The proposed project’s consistency with a pplicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As presented in Table 3.7 -7 in Section 3.7, the project is consistent with the applicable transportation-related goals and policies.

3.11.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts. A project may be deemed to have a significant impact on transportation if it would:
• Threshold #1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; or • Threshold #2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b); or

3.11.4 Project Impact Analysis
Threshold #1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Access to the proposed project from the regional transportation network would be provided via the SR- 78 freeway, Las Posas Road, W. Mission Road, and Armorlite Drive. These facilities would either provide a direct connection to the proposed project, via the project driveway, or would provide a critical link between the proposed project and the regional transportation network.

The project would not result in any conflicts related to plans or policies addressing transit, bicycle, and pedestrian facilities. The project is located within 500 feet of the nearest bus stop and about 1,000 feet (8-minute walk) to the closest SPRINTER s tation. Continuous sidewalk connectivity is provided between the project site and these transit stops. Existing sidewalks are already provided on both sides of Armorlite Drive, the project site’s frontage road, and the project would not interfere with anticipated

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improvements to the existing Class I Mult-Use Path on Armorlite Drive or bike lanes on Las Posas Road (City of San Marcos 2023).

Additionally, based upon the analysis presented in Section 3.7.4, the project would not result in an inconsistency with the Mobility Element of the City’s General Plan. The Local Transportation Analysis determined that the project would result in 1,214 total average daily trips (ADT). All roadway segments are calculated to operate acceptably at LOS D or better with the addition of project and cumulative project traffic under Near Term 2025 and Horizon Year 2050 conditions. All study intersections are calculated to operate acceptably at LOS D or better with the addition of project and cumulative project traffic under Near Term 2025 conditions with the exception of the Las Posas Road/ Descanso Avenue and Las Posas Road/ Grand Avenue intersections. These intersections are forecast to operate at LOS F with and without the proposed project in the Near Term 2025 condition. The trips associated with the proposed project would not be enough to add two seconds of average vehicle delay, which is the threshold for intersections operating at LOS E or F, as identified in the Mobility Element of the General Plan (LLG 2024a).

All study intersections are calculated to operate acceptably at LOS D or better with the addition of project and cumulative project traffic under Horizon Year 2050 conditions with the exception of the following intersections: Mission Road/Pacific Street, Mission Road/ Las Posas Road, Mission Road/ Knoll Road, Las Posas Road/ Descanso Avenue, Las Posas Road/ SR-78 Westbound Ramps, and Las Posas Road/ Grand Avenue intersections. These intersections are forecast to operate at LOS E or F with and without the pr oposed project in the Horizon Year 2050 condition. The trips associated with the proposed project would not be enough to add two seconds of average vehicle delay, which is the threshold for intersections operating at LOS E or F (LLG 2024a).

Therefore, impacts related to a conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities would be less than significant.

Threshold #2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b).

The TIAG (City of San Marcos 2020) provides several screening approaches to identify when a project should be expected to cause a less -than-significant impact related to VMT. The City of San Marcos TIAG suggest that a detailed transportation VMT analysis applies to all land development projects, except those that meet at least one of the screening criteria. Relevant screening criteria for the proposed project is described below:
• Map-Based Screening for (Projects Located in VMT Efficient Areas) – Residential and employment projects that are proposed in areas that generate VMT below adopted City thresholds can be presumed to have a less -than-significant transportation impact and would not require a detailed VMT analysis. This determination must be made using SANDAG’s online residential and employment VMT maps for existing year or model baseline year VMT (whichever is available at the time analysis is being conducted), which show census tracts in the city where the VMT is below the regional average. The following types of projects could be screened out using this approach:
o Residential and office projects proposed in census tracts with residential VMT per capita below the City’s threshold of 85% of the SANDAG regional average. A significant impact would occur if the project generates VMT per resident or worker greater than 85 % of the regional average.

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In order to utilize this screening approach, the project must incorporate similar land use characteristics to other projects in the census tract. For mixed -use projects, this screening criteria should be applied to the residential and employment components separately to determine if any portions of the project screen out of a detailed VMT analysis. • Local-Serving Retail - Retail projects that have 50,000 square feet gross floor area or less can be presumed to have a less than-significant transportation impact and would not require a detailed VMT analysis. For a mixed-use project, this screening criteria should be applied to the retail/commercial component separately to determine if that portion of the project screens out of a detailed VMT analysis.

VMT Analysis
Residential Component
Per the City TIAG , a VMT analysis is not required as the p roject is located in a VMT efficient area (Residential projects proposed in census tracts with residential VMT per capita below the City’s threshold of exceeding 85 percent of the SANDAG regional average) based on the applicable location- based screening map produced by SANDAG. The San Diego average regional VMT/capita is 18.9 (and 15% below 18.9 would equate to 16.0) per SANDAG Series 14 (Year 2016) data.

Using the SANDAG screening map for residential projects under per capita measurements (Figure

3.11-1) the project is located in census tract 200.29 and would be expected to generate 12.5 VMT/capita. This equates to 66.1% of the regional average VMT/capita. Table 3.11–2 shows the VMT analysis results.

Table 3.11-2. Project Vehicle Miles Traveled Analysis
Geography VMT per Resident Exceeds
Threshold?
San Diego Region 18.9 -
Significance Threshold (85% of Regional Average
VMT) 16.0 -
Project Site 12.5 No
Source: LLG 2024b.

Therefore, based on the City’s TIAG, a VMT analysis is not required as the project is located in a VMT efficient area and VMT impacts are presumed to be less than significant.

Commercial Component
The project includes up to 5,600 square feet (s.f.) of retail/flex space. Per the City TIAG, local-serving retail projects that are 50,000 square feet gross floor area or less can be presumed to have a less - than-significant transportation impact and would not require a detailed VMT analysis. Retail can include shopping centers as well as standalone uses such as commercial shops, gas stations, and restaurants. Therefore, based on the City’s TIAG, a VMT analysis is not required as the proposed 5,600 s.f. of commercial use is far less than the screening criteria threshold for local-serving retail of 50,000 s.f.

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3.11.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to transportation, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to hazards. All of the cumulative projects identified in Table 2 -3 are considered in this cumulative analysis.

Cumulative Policy Impact
The related projects and other cumulative development in San Marcos would be subject to the same circulation-related programs, plans, ordinances, and policies as the proposed project. Cumulative projects would be required to demonstrate consistency with th e SANDAG 2021 Regional Plan, San Marcos General Plan, the City’s ATP , and San Marcos TIAG, which guide development of transportation systems and circulation in the city. The cumulative projects primarily propose medium- to high-density residential and mix ed-use development in areas with good transit connectivity and active transportation options, reducing dependence on automobiles and encouraging more active travel modes. As a result, cumulative impacts related to a conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities would be
less than significant.

Cumulative VMT Analysis
According to the City’s TIAG (San Marcos 2020) if a land use project (or a component of a mixed -use project) is screened out of requiring a detailed existing VMT analysis or if it falls below the existing VMT thresholds outlined in Table 2 of the TIAG , it would also result in a less than significant cumulative impact. Therefore, the proposed project’s cumulative VMT impact would be less than significant.

3.11.6 Mitigation Measures
Based upon the analysis presented in Sections 3.11.4 and 3.11.5, impacts were determined to be less than significant. No mitigation measures are required.

3.11.7 Conclusion
Based upon the analysis presented in Section 3.11.4, the project would not have an impact related to a conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The project would also have a less than significant impact related to VMT based on the City’s screening criteria.

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Figure 3.11-1. Project Location within SANDAG SB 743 VMT Map

Source: LLG 2024b.

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3.12 Tribal Cultural Resources
Introduction
This section analyzes the potential impacts of the proposed project on tribal cultural resources. As defined by Public Resources Code Section 21074, a tribal cultural resource is a site, feature, place, and or cultural landscape that is geographically defi ned in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is either on or eligible for the California Register of Historic Resources (CRHR) or a local historic register, or determined by the City, at its discretion to treat the resource as a tribal cultural resource.

Cultural resources (historical resources, archaeological resources and human remains) are analyzed separately in Section 3.4, Cultural Resources, of the Environmental Impact Report (EIR).

The analysis in this section is based upon the following information:
• Results of a June 2023 search of the Sacred Lands File by the California Native American Heritage Commission, requested by ASM Affiliates (July 2024). • Government-to-government tribal consultation between the City and California Native American Tribes pursuant to the procedures in Assembly Bill 52 and Senate Bill 18. • Archaeological Survey Report for Armorlite Lofts Project, San Marcos, CA prepared by ASM Affiliates (July 2024).

The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s web site.20 Table 3.12-1 summarizes the tribal cultural resources project- and cumulative- level impacts, by threshold.

3.12.1 Existing Conditions
A detailed description of the project site’s natural setting, archeological context, ethnographic context, records search information, and ASM’s informal tribal coordination and information gathering is presented in Section 3.4 (Cultural Resources). The following section provides information about tribal cultural resources and a summary of government -to-government tribal consultation efforts pursuant to AB 52 and SB 18. Although SB 18 is not a CEQA issue, the tribal consultation was simultaneous under both laws.

Table 3.12-1. Tribal Cultural Resources Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#1 – Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is Significant
Impact
Less Than
Significant
Impact
Less Than
Significant
Impact With
Mitigation

20 http://www.san-marcos.net/work/economic-development/general-plan

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Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).
#2 – Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less than
Significant
Impact
Less than
Significant
Impact
Less than
Significant
Impact

Tribal Consultation
In addition to ASM reaching out to Tribes as part of the archeological report preparation (see Section

3.4), the City provided notice to Tribes pursuant to AB 52 and SB 18 and consulted with Tribes.

Under AB 52, the City sent project notification letters on July 11, 2023 to the following California Native American tribes, which had previously submitted general notification requests in writing pursuant to 21080.3.1(d) of the Public Resources Code. Each recipient wa s provided a brief description of the project and its location, the lead agency contact information, and a notification that the tribe has 30 days to request consultation, pursuant to PRC Section 21080.3.1(d). The 30 -day response period concluded on August 12, 2023.
• Mesa Grande Band of Mission Indians
• Pechanga Band of Indians
• Rincon Band of Luiseño Indians
• San Luis Rey Band of Mission Indians
Under SB 18, on July 11, 2023, the City sent project notification letters to the following California Native American tribes named on the NAHC list. Each recipient was provided a brief description of the project and its location, the lead agency contact information, and a notification that the tribe has 90 days to request consultation, pursuant to Government Code Section 65352.3(a)(2). The 90 -day response period concluded on October 9, 2023.
• Barona Group of the Capitan Grande
• Campo Band of Diegueno Mission Indians
• Ewiiaapaayp Band of Kumeyaay Indians
• Iipay Nation of Santa Ysabel
• Inaja-Cosmit Band of Indians

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• Jamul Indian Village
• Kwaaymii Laguna Band of Mission Indians
• La Jolla Band of Luiseño Indians
• La Posta Band of Diegueño Mission Indians
• Manzanita Band of Kumeyaay Nation
• Mesa Grande Band of Mission Indians
• Pala Band of Mission Indians
• Pauma Band of Luiseño Indians
• Pechanga Band of Indians
• Rincon Band of Luiseño Indians
• San Luis Rey Band of Mission Indians
• San Pasqual Band of Diegueño Mission Indians
• Soboba Band of Luiseño Indians
• Sycuan Band of the Kumeyaay Nation
• Viejas Band of Kumeyaay Indians
As a result of the initial notification letters, the City received the following responses, and engaged in consultation with these tribes as summarized below.

San Luis Rey Band of Mission Indians
The tribe responded on July 19, 2023 to request consultation under AB 52 and separately responded to request consultation under SB 18 . The City initiated consultation on July 31, 2023, at which time the City began discussing the project with the tribe during monthly consultation meetings . Tribal representative Cami Mojado recommended that an area be set aside for sage scrub found on the property, and forwarded to the City an email from the Tribal Historic Preservation Officer of the Jamul Indian Village of California that they are deferring consultation on this project to the San Luis Rey Band of Mission Indians. On December 21, 2023, Cami Mojado requested a site visit.

On January 18, 2024, she indicated that she would send a comment letter that recommends a large enough reburial area for unanticipated discoveries and previous collections, preservation of a confidential feature on the property, and planting of a sage shru b garden. On April 10, 2024, Cami Mojado performed a site visit. On June 26, 2024, the City transmitted draft proposed mitigation measures and the grading plan to the tribe for comment.

On October 17, 2024, Cami Mojado provided a letter to the City stating the tribe’s agreement with the mitigation measures proposed by the City. Therefore, in accordance with PRC Sections 21080.3.2(b)(1) and 21082.3(d)(1), the City concluded consultation un der AB 52. The information provided to the City, including confidential information that cannot be disseminated publicly, was taken into account in the project impact analysis further below.

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Rincon Band of Luiseño Indians
The tribe responded on July 31, 2023 to request consultation under SB 18, and responded on August 1, 2023 to request consultation under AB 52. The City initiated consultation on August 1, 2023 when transmitting the technical report to the tribe.

On August 15, 2023, the City discussed the project during a regular monthly consultation meeting.

Tribal representative Cheryl Madrigal acknowledged receipt of the information but had not had an opportunity to review the information yet. Additional informa tion was sent to the tribe by the City on September 6 and September 11, 2023.

During a subsequent meeting with the tribe on December 19, 2023, Cheryl Madrigal indicated that she would send the City a letter with comments. On January 11, 2024, the tribe sent a comment letter to the City that included a request for a field meeting and four initial recommendations. On January 25, 2024, the City attended a field visit and hosted an office meeting with the tribe to discuss the tribe’s comments. The tribe sent another letter on February 6, 2024 to state its concerns regarding impacts to a tribal cultural resource inside the project area. The letter included two additional recommendations beyond what was stated in the January 11, 2024 letter.

During a subsequent meeting on February 20, 2024, the City requested permission to share the comments with the applicant, which was denied by the tribe. The City and tribe discussed the project in detail, including a robust discussion about whether or not avoidance and preservation in place is feasible. The tribe requested an alternatives analysis in advance of the preparation of the EIR to assist in determining whether or not it is feasible to avoid. The City requested an alternatives analysis from the applicant, and the report of the analysis was provided to the tribe on March 28, 2024 along with a response to the tribe’s February 6, 2024 letter. The City explained to the tribe which mitigation measures are feasible and which ones are not, and proposed a s uite of eight measures to reduce impacts to less than significant.

In April 2024, the City again met with the tribe, and Cheryl Madrigal indicated that they are still reviewing the City’s letter and the alternatives analysis and that a written response from the tribe would be forthcoming in the next couple of weeks. On May 21, 2024, the City met with the tribe again.

Cheryl Madrigal reported that the tribal staff and elders were reviewing and discussing the project. She stated that the tribe is not planning to obstruct the project’s approval and that mitigation is possible to resolve impacts to the site, and that a letter is still forthcoming. On June 3, 2024, the tribe sent the response letter to the tribe, clarifying the tribe’s position on its suggested mitigation.

The City continued to meet with Rincon in July, August, and September 2024 over the language of mitigation measures. In September, the tribe asked for a restriction on the export of soil from the property or an over -excavation and reburial of soil on site. The City discussed the request with the Applicant team and determined that t he over -excavation of soil would require blasting due to the presence of dense soils and rock on the property. That location of the rock throughout a significant majority of the p arcel is a driving factor for the location of the building and grading plan. The engineering plan accounted for those constraints (inability to penetrate the bedrock) by utilizing the natural contours and grades to the extent possible to lessen the amount of blasting and earthwork required to create a usable pad. The limited amount of ability to grade combined with the amount of rock material onsite would preclude the project from burying the cultural soil in a deep pit as even the standard grading for the project will be very challenging. If the project were to attempt to bury the material it would significantly increase earthwork operations, leading to higher greenhouse gas emissions and potentially triggering the need for new environmental permits. Theref ore, excavating

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the material, stockpiling the excavated soil on-site, and reburial of the material is not feasible due to the limited space on the site and grading conditions. As a result, the City could not come to agreement on this measure.

The City and Tribe also consulted extensively on the scope and content of ethnographic documentation for the project. The City ultimately concluded that for mitigating impacts to a tribal cultural resource, the City cannot require a regional landscape stud y and must take into account the nexus and rough proportionality of the project’s impacts. The City, however, agreed to require a project -specific ethnography as mitigation.

In July, August, and September 2024, the City continued to seek agreement with Rincon over the impacts and mitigation measures required to reduce the impact to less than significant. Ultimately, although Rincon did not provide written concurrence with the mitigation measures, the City determined that, after a good faith and reasonable effort, further consultation on the project would not be fruitful and that meaningful consultation on the project has been exhausted. As a result, the City considers consultation with the Rincon Band of Luiseño Indians complete without agreement in accordance with Section 21080.3.2(b)(2) of the Public Resources Code. Although consultation concluded without written agreement from the Rincon Band, the mitigation measures presented herein were developed in close coordinati on with tribal representatives from the Rincon Band over a 16 -month period.

Ultimately, the City exercised its agency discretion and will require these mitigation measures. The information provided to the City to date, including confidential information that cannot be disseminated publicly, was taken into account in the project impact analysis further below.

Pechanga Band of Indians
The tribe responded on August 9, 2023 to request consultation under AB 52. This followed a discussion on July 24, 2023 between the City and tribe during one of the regular consultation meetings. At that time, Pechanga representative Paul Macarro explained the tribe’s perspectives on sensitivity of the property and urged the City to adopt the standard conditions, to which the City agreed.

The tribe requested information on the prior studies and grading plans. On May 14, 2024, the City again met with the trib e to discuss the project and the scope of the proposed mitigation measures.

The city explained the proposed measures, which were neither supported nor opposed by the tribe during the meeting. The city sent the mitigation measures and the grading plans with a potential reburial location to the tribe immediately following the meeting. After no response, the City followed up with the tribe on June 3 and July 1, 2024 and received no response.

Although multiple attempts during June and July 2024 by the City to obtain a concurrence letter from the tribe prior to release of the EIR were unsuccessful, and there was the appearance that the tribe failed to engage after requesting consultation, enough consultation occurred that the City considers consultation with the Pechanga Band of Indians complete and in substantial agreement in accordance with Sections 21080.3.2(b)(1) and 21082.3(d)(1) of the Public Resources Code. The information provided to the City to date, including confidential information that cannot be disseminated publicly, was taken into account in the project impact analysis further below.

Other Tribes
The balance of the tribes did not request consultation under either AB 52 or SB 18.

Because the City initiated consultation with all tribes that requested it, the threshold for release of the CEQA document for public review in PRC Section 21080.3.1(b) has been met. The City considers consultation with all consulting tribes concluded in good faith, as required by PRC Section 21082.3(d).

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3.12.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to tribal cultural resources. The analysis of tribal cultural resources is a State requirement under CEQA, as required by AB 52, described below. The City also has goals and policies in the General Plan Conservation and Open Space Element related to cultural resources, as described below.

State
Senate Bill 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 confidence any information about the specific identity, location, character, or use of these resources.

In 2005, the 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 Native American Heritage Commission maintains a list of California Native American Tribes with whom cities and counties must consult pursuant to SB 18.

Assembly Bill 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 N ative American Tribe, lead agencies must consult prior to the release of a Negative Declaration, Mitigated Negative Declaration or Draft EIR.

Health and Safety Code 8010-8011
This code is intended to provide consistent state policy to ensure that all California Native American 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.

Assembly Bill 2461
The section provides procedures for private land owners to follow upon discovering Native American human remains. Land owners are encouraged to consider culturally appropriate measures if they discover Native American human remains as set forth in California PRC 5097.98.

Local
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:
• 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.

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• 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.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As detailed in Table 3.7-7, the project is consistent with the applicable General Plan goals and policies pertaining to cultural resources.

San Marcos Archaeological and Historical Resources Consultant Guidelines The City of San Marcos published guidelines for archaeological and historical resources consultants in January 2024. The guidelines are generally meant to aid third party consultants who prepare archaeological or architectural history inventories, surveys, evaluations, and other technical documents. These guidelines include information pertaining to the minimum qualifications, records searches, tribal outreach, pedestrian surveys, reporting, research design, findings, discussion and evaluations, management conclusions, references, and appendices of inventories, surveys, evaluations, and other technical documents (City San Marcos 2024). ASM prepared the archaeological resources inventory report in accordance with these guidelines.

3.12.3 Thresholds of Significance
The determination of significance for tribal cultural resources is based on CEQA Guidelines Appendix G. Impacts to tribal cultural resources would be significant if the proposed project would:
• Threshold #1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object of cultural value to a California Native American tr ibe and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k); or • Threshold #2: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object of cultural value to a California Native American tr ibe and that is a resource determined by a lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to the criteria set forth in subdivision (c) of the Public Resources Code Section 5024.1.

3.12.4 Project Impact Analysis
CA-SDI-5633
Tribal consultation under AB 52 and SB 18 identified CA -SDI-5633 as a tribal cultural resource. As described in Section 3.4, Cultural Resources, of this EIR, SDI -5633 was originally recorded by the Museum of Man as W-1573 and rerecorded in 1977 as SDI-5633. Information about the location and character of this resource is restricted from public distri bution and is only generally summarized

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herein; however, the specific information that led to the impact assessment in this EIR was taken into account by the City.

The entire project site would be graded to prepare the site for future development. Grading depths are anticipated to range from 3 to 7 feet depending on the area of the project site. Ground disturbing activities can result in impacts to buried tribal cultural resources if they are present on the project site.

As part of the project design, an area would be set aside on the project site for repatriation of cultural resources. This area would be subject to a conservation easement and would be protected by a deed restriction.

Mitigation measures have been identified in Section 3.4, Cultural Resources, to reduce the potential for impacts to archaeological resources to below a level of significance (MM CR -1a, MM-CR-1b and MM-CR-2). The following analysis discusses the potential for the project to have on tribal cultural resources.

Threshold #1: Cause a substantial adverse change in the significance of a tribal cultural resource , defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object of cultural value to a California Native American tr ibe and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).

SDI-5633 is considered eligible for listing in the National Register of Historic Places (Gallegos & Associates 2002) and is eligible for listing in the California Register of Historical Resources (ASM 2023). The City does not maintain a local register of historical resources.

Tribal consultation between the City and consulting tribes identified site SDI-5633 as a tribal cultural resource, as defined in Public Resources Code Section 21074(a)(1)(A). Although site SDI -5633 has been subjected to archaeological data recovery excavat ion to mitigate impacts to the site by development of the parcel in 2002 (Gallagos & Associates 2002), the site retains importance as a place of value to California Native American tribes.

The alternatives analysis prepared for tribal cultural resources concluded that avoidance and preservation in place would not result in a project that is compliant with state law and consistent with the local, regional, and state housing and environmental goals, given the project area’s location within a VMT efficient area and within a SANDAG Smart Growth Area. The analysis also noted a high level of disturbances on the site, including agricultural use, bioturbation, and adjacent construction activity.

After reviewing the results of the alternatives analysis, the City has determined that avoidance and preservation in place are not feasible for the project. A No Project/No Development Alternative and No Project/Reduced Development Footprint alternative are analyzed in Section 4.0 of this document.

As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource that is eligible for inclusion in the California Register of Historical Resources. This represents a significant impact (Impact
TCR-1) and mitigation is required.
• Impact TCR-1 As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource that is eligible for inclusion in the California Register of Historical Resources.

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Threshold #2: Cause a substantial adverse change in the significance of a tribal cultural resource , defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object of cultural value to a California Native American tribe and that is a resource determined by a lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to the criteria set forth in subdivision (c) of the Public Resources Code Section 5024.1?21 The City received written comments from one tribe regarding the significance of the site as a tribal cultural resource that transcends site -specific archaeological significance. The nature of the comments and the specific information provided is confidenti al and cannot be disseminated to the public; however, this information was reviewed in detail by the City. Ultimately, the City determined that the information did not rise to the level of substantial evidence as defined in state law. The project would result in a
less than significant impact on a tribal cultural resource based on the substantial evidence threshold and no mitigation under Threshold #2 is required. Regardless, site SDI -5633 is eligible for the California Register of Historical Resources and is a tribal cultural resource, as addressed under Threshold #1 and identified in impact TCR-1.

3.12.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to tribal cultural resources, the cumulative analysis is based upon a regional approach.

The proposed project will have a significant impact on a tribal cultural resource. Other development projects in the City that are subject to CEQA would require consultation with local tribes. Tribal consultation may provide information on whether tribal c ultural resources are present on a given project site. Depending on the information provided, these sites may be determined to be a tribal cultural resource and how a given project may impact them. If projects are determined to have a significant impact on tribal cultural resources, mitigation would be required to reduce potential impact.

The date, all projects in t he City have reduced potential tribal cultural resources impacts to below a level a significance.

Information provided by one consulting tribe included statements about the cumulative effect on tribal cultural resources in the City as well as the cumulative effect on the tribal cultural resource caused by past mitigation efforts. The City considered this information in light of the substantial evidence and significant nexus thresholds, the development of property in other parts of t he City, and the existing laws that require tribal consultation as described above. The City has determined that the projec t would result in a less than significant cumulative impact on tribal cultural resources. No mitigation is required.

21 In applying this criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resources to a California Native American tribe

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3.12.6 Mitigation Measures
Tribal Cultural Resources (Impact TCR-1)
The City has determined, in consultation with Tribes, that the proposed project would result in a significant impact to a tribal cultural resource. The following mitigation measures , which implement Section 21084.3(b)(2)(B, C) and (b)(3) of the Public Resources Code, shall be required.

MM-TCR-1 Monitoring Agreement : Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall extend the invitation to enter into a Monitoring Agreement with the Rincon Band of Luiseño Indians and the San Luis Rey Band of Luiseño Indians (Tribes). The purpose of the Monitoring Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the Tribes for the monitoring for Native American human remains, funerary objects, cultural and/or religi ous 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 addit ional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities. In the event that either or both tribes choose not to enter into an agreement or fail to respond to the offer, the City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

Any project -specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the Tribal requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation. The land owner 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 Tribes for proper treatment and disposition per the Monitoring 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 Monitoring Agreement. Additionally, all non-tribal artifacts collected by the archaeologist shall also be subject to curation.

MM TCR-2 Controlled Grading. The area illustrated on the confidential exhibit attached to the grading plans shall be subject to controlled grading. Under the observation of a tribal monitor and qualified archaeologist, the contractor shall use either a small piece of equipment or obse rve the removal of soil by a backhoe equipped with a flat-edge bucket to excavate soil using shallow cuts made in approximately one - foot lifts. The grading equipment will push the shallow cuts of soil to the outside of the cultural deposit area and random samples may be screened to ensure adequate detection of any cultural materials that may be present. In the event that cultural materials or human remains are exposed, the procedures for unanticipated discoveries in mitigation measure MM-TCR-4 shall apply. Controlled grading shall continue to a depth of 30 centimeters below the depth of any recorded artifacts, suggesting an end to the potential for cultural deposits, or when restrictive layers or non-cultural formational soils are encountered that predate any human occupation of this location, as determined by the qualified professional

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archaeologist, in consultation with the tribal monitor. Once the identified depth has been reached, the controlled grading process will be terminated and mass grading may proceed, subject to review and approval by the City.

MM-TCR-3 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 the Rincon Band and San Luis Rey Band have been retained at the Applicant/Owner or Grading Contractor’s expense to implement the construction monitoring program, as described in the Monitoring Agreement.

Native American monitoring shall include one monitor from the Rincon Band of Luiseño Indians and one monitor from the San Luis Rey Band of Luiseño Indians simultaneously. In the event that either tribe chooses not to enter into an agreement or fails to respond to the offer, the City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

The monitors shall be provided at least 72 hours’ notice of the initiation of construction and be kept reasonably apprised of changes to the construction schedule. In the event that a monitor is not present at the scheduled time, work can continue without the monitor present, as long as the notice was given and documented.

Native American monitors 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 Native American monitors 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 r esources. In areas of artificial paving, the Native American monitors shall be present on-site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb the original pre - project ground surface to iden tify any evidence of potential tribal cultural resources. No monitoring of fill material, existing or imported, will 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) are from private or other non-commercial sources that have been determined to be absent of tribal cultural resources by the Native American monitors.

The Qualified Archaeologist (mitigation measure MM-CR-1a) and Native American monitors 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 notice to the Planning Division and the Tribes, preferably through e-mail, of the start and end of all ground disturbing activities.

MM-TCR-4 Unanticipated Discovery Procedures: Native American monitors may temporarily halt or divert ground disturbing activities if previously unknown tribal cultural

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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. If the re source is determined to be not associated with Native American culture, it will be subject to mitigation measure MM-CR-1b. Native American tribal cultural resources discovered during construction shall follow the procedures below. If a discovery of a previ ously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture (subject to mitigation measure MM-CR-1b), then the Qualified Archaeologist, Tribes, monitors, and City shall coordinate on appropriate treatment.

All unearthed tribal cultural resources will be collected, temporarily stored in a secure location, and repatriated according to the consulting tribes, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

If a determination is made that the tribal cultural resources are considered potentially significant by the Tribe and the Native American monitor, then the City and the Tribe shall determine, in consultation with the Applicant/Owner, the culturally appropriate treatment of those resources.

All sacred sites and significant tribal cultural 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 (as defined by the California Environmental Quality Act [CEQA]) , then the City shall require additional culturally appropriate mitigation to address the negative impact to the resource. The Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation. Any cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site and repatriated according to the terms of the Monitoring 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 Native American monitor. Any testing, taking of photos or 3D prints are prohibited, unless all monitoring tribes give prior written approval.

MM-TCR-5 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. The procedures in mitigation measure MM-CR-2 shall apply.

MM-TCR-6 Reburial: Prior to the approval of grading plans, the Applicant shall designate a reburial location onsite and note the location as excluded from construction - related activity on grading plans. The reburial location shall be used to rebury any cultural materials enc ountered during monitoring, and to rebury existing collections from the previous data recovery effort. Following the completion of all ground disturbing activity and reburial of all materials and before the issuance of a Certificate of Occupancy, the Applicant shall file a deed restriction on the parcel

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that protects the reburial location from future disturbance and provide a copy to the City. The exhibit for the deed restriction and purpose of it shall be kept confidential and out of the public record.

MM-TCR-7 Access Agreement and Management Plan: Prior to the issuance of a Certificate of Occupancy, the Applicant shall extend a written offer to each consulting tribe to enter into an access agreement, which is binding on successors and heirs to the property, that allows for legal access to visit the reburial location after construction is completed. If more than one tribe elects to enter into an access agreement, each tribe shall have its own agreement. In the event that one (1) or more consulting tribe does not respond to the offer within 30 days of receipt, then the City will deem this mitigation measure satisfied provided that the offer was extended and documented in accordance with this measure. Management of the reburial area is to include the development of a revegetation plan in consultation wit h the consulting tribes, including notification process for proposed maintenance of the reburial area.

MM -TCR-8 Native Vegetation: Prior to clearing and grubbing of vegetation in the project area, a qualified professional botanist shall flag the presence of white sage for transplanting into the landscaping or offsite. In the event that transplanting is determined infeasible by the bot anist, in their professional judgement, the Applicant shall ensure that native white sage is included in the landscaping plan for the project.

MM-TCR-9 Land Acknowledgement Statement: The project applicant Applicant/Owner shall develop and post a Land Acknowledgement Statement inside a common area of the development. The statement shall be developed in coordination with Tr ibes and address the acknowledgement that the project is on the ancestral lands of culturally affiliated tribes that have been the original and ongoing stewards of the land. In the event that consulting tribes do not respond to the offer within 30 days of receipt, then the City w ill deem this mitigation measure satisfied provided that the offer was extended and documented in accordance with this measure. The location of the Land Acknowledgement Statement shall be noted on elevation and/or plan view drawings for the common area of the development.

MM-TCR-10 Project-Specific Ethnographic Synthesis: The Applicant shall fund the preparation of a project-specific ethnographic synthesis, not to exceed what is described in the confidential proposal provided by the Rincon Band of Luiseño Indians dated August 27, 2024. No later than 30 days after the final p roject approval, the Applicant/Owner shall extend a written offer to the Rincon Band of Luiseño Indians to enter into an agreement with their ethnographer to conduct and prepare the ethnographic synthesis in accordance with the aforementioned proposal . In the event of a dispute between the parties in entering into the agreement for the ethnographic synthesis, and after a good faith and reasonable effort, the City shall serve as the final arbiter. The City will determine the scope and content of an ethnographic synthesis in that event.

The synthesis will draw from oral histories, elder knowledge, and other sources of confidential Indigenous knowledge that relate to the tribal cultural resource affected by the proposed project. The ethnographer shall be afforded up to 90 days

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following funding of the ethnography to carry out any field visits with appropriate tribal representatives. After 90 days, or sooner if the ethnographer completed its field studies, the Applicant /Owner shall be permitted to proceed with ground disturbing activities and construction of the project while non -field-based data gathering, such as ethnographic interviews of informants and review of tribal documents, is being carried out. Upon completion, a pu blic (redacted) version of the ethnographic synthesis shall be submitted to the California Historical Resources Information System and the City. The final non -redacted study shall belong to the Rincon Band of Luiseño Indians.

3.12.7 Conclusion
The City has determined, in consultation with Tribes, that the proposed project would result in a significant impact to a tribal cultural resource under Threshold #1 . Mitigation measures MM -TCR-1 through MM-TCR-10 shall be required to reduce the level of impact to less than significant.

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3.13 Utilities and Service Systems
Introduction
This section identifies the existing service providers for utilities and service systems, including water, wastewater, stormwater drainage, electric power, natural gas, and telecommunications facilities and analyzes the ability of these providers to serve the proposed project based upon current utility infrastructure. A detailed energy consumption analysis is included in Section 3.5, Energy, of the EIR.

The analysis in this section relies on the following document, which is included as Appendix S of the EIR:22
• Armorlite Lofts Water and Sewer Study, Final Technical Memorandum, prepared by Vallecitos Water District, December 12, 2023.

The Water and Sewer Study, prepared by the Vallecitos Water District (VWD) considered water demand and sewage generation increases due to the proposed General Plan Amendment and development of the proposed project. The Water and Sewer Study also analyzed the ability of VWD’s infrastructure to serve the proposed project.

Table 3.13-1 summarizes the utilities and service system analysis, by threshold.

Table 3.13-1. Utilities and Service Systems Summary of Impacts Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
#1 - Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#2 - Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry, and
multiple dry years?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#3 - Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#4 – Generate solid waste in excess of
State or local standards, or in excess of
the capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation

22 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.

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Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
#5 – Comply with federal, state, and local
management and reduction statues and
regulations related to solid waste?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation

3.13.1 Existing Conditions
The following provides background information about the water, wastewater, solid waste, and other utility service providers that would serve the proposed project.

Water Service Area
The proposed project lies within VWD for both water and wastewater services. VWD provides water, wastewater, and reclamation services to a population of more than 108,000 within its 45-square-mile boundary including: San Marcos, the community of Lake San Marcos, parts of Carlsbad, Escondido and Vista and other unincorporated areas in north San Diego County. VWD also wholesales recycled water to the City of Carlsbad and the Olivenhain Municipal Water District.

The project site lies completely within VWD’s 855 Pressure Zone. The project site is currently undeveloped. Potable water is delivered to the project area by an existing 8-inch water main in Armorlite Drive at the main entry to the project site.

Water Supply
VWD is a member of the San Diego County Water Authority (SDCWA), thus eligible to purchase water transported into San Diego County via the massive aqueducts of SDCWA and its wholesaler, Metropolitan Water District (MWD) of Southern California. To understand water supply availability for the proposed project, it is important to begin with MWD and follow the water supply through these agencies.

MWD was formed in 1928 to develop, store, and distribute supplemental water to southern California for domestic and municipal purposes. MWD consists of 26-member agencies and has a service area covering six counties, 5,200 square miles, and 19 million peop le. MWD obtains water from local sources as well as the Colorado River (via the Colorado River Aqueduct) and the Sacramento -San Joaquin Delta (via the State Water Project). MWD’s Urban Water Management Plan (UWMP) documents the availability of these supplies to meet future demands. With a projected annual water demand of 5,374,000 acre-feet per year for 2045, the MWD UWMP concludes that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2045 under normal, single dry, and multiple dry water years (MWD 2021).

The MWD water demands through normal, single dry year, and multiple dry years are shown in Table

3.13-2.

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Table 3.13-2. Metropolitan Water District Total Water Demands in Acre Feet Per Year Year 2025 2030 2035 2040 2045
Average Year 4,925,000 5,032,000 5,156,000 5,261,000 5,374,000 Single Dry Year 4,929,000 5,037,000 5,156,000 5,265,000 5,374,000 Multiple Dry Years 4,877,000 5,064,000 5,182,000 5,299,000 5,410,000 Source: MWD 2020 Urban Water Management Plan (MWD 2021).

SDCWA is the largest member agency of MWD and supplies 75 to 95 percent of the water needs in San Diego County. The population within the SDCWA’s service area was approximately 3.3 million people in 2020 and is projected to increase to roughly 3.8 million people by 2045. The County of San Diego is expected to develop an additional 130,000 acres between 2020 and 2050, with the majority (125,000 acres) of development dedicated to residential land uses. These regional growth projections are based on the San Diego Association of Governments Series 14 Regional Growth Forecast, developed for its 2019 Federal Regional Transportation Plan adopted by San Diego Association of Governments’ Board of Directors on October 25, 2019. In fiscal year 2020, total water demand in the SDCWA’s service area was 463,128 acre-feet, of which 92% was for municipal and industrial use and 8% was for agricultural water use. By 2045, the SDCWA’s annual water demands are projected to reach 630,771 acre- feet. This projection accounts for planned future water conservation savings (SDCWA 2021).

SDCWA is historically the largest purchaser of MWD water; however, as SDCWA and its member agencies have increased their locally controlled water resources and investments in water use efficiency, SDCWA purchases have declined. In fiscal year 2020, SDCWA purchased 62,852 acre-feet, or about 6% of all the water MWD sold. SDCWA’s UWMP assessed water reliability from 2025 through 2045 and determined that there are sufficient supplies to meet projected demands under Single Dry- Year and Multiple Dry-Year conditions (SDCWA 2021).

According to the VWD Master Plan Report, VWD imports about 75% of its water supply from SDCWA.

The rest of VWD’s water supply is provided by the recently completed Carlsbad seawater desalination plant as well as up to 2,200 acre -feet per year of supply fro m the Olivenhain MWD. Currently, VWD delivers water through 356 miles of pipeline and operates 10 pump stations and 19 potable water storage reservoirs ranging in size from 350,000 gallons to 40 million gallons (MG). VWD’s total operational storage capacity is 121.6 MG. During Fiscal Year 2013- 2014, VWD provided an average of 14.8 million gallons per day (MGD) to approximately 21,900 meters serving residential, commercial, light industrial, institutional, construction, landscape irrigation and agricultural uses (VWD 2018).

Wastewater Service Area
VWD provides wastewater and reclamation services to a 23 -square mile area serving approximately 93,000 people as well as commercial, light industrial, institutional, construction, landscape irrigation, and agricultural customers. Their service area include s the City of San Marcos, parts of the cities of Carlsbad, Escondido, and Vista, and unincorporated areas within the County of San Diego. In addition, VWD wholesales recycled water to the City of Carlsbad and the Olivenhain MWD. Within its service area, there are some rural areas that still use septic systems for sewage disposal, thus VWD’s current 23-square mile sewer service area is much smaller in size than its water service area, although VWD’s

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sphere of influence is equal in size for both. VWD has over 20,000 sewer service connections with 4 lift stations and approximately 250 miles of pipeline (VWD 2018).

VWD would provide the proposed project’s wastewater service. The project site is completely within VWD sewer shed 22C (VWD 2023). The project site is currently undeveloped. Sewer service is provided to the project area by an existing 8-inch sewer mainline in Armorlite Drive.

Wastewater Flows
The VWD 2018 Master Plan includes a wastewater system analysis assessing existing and projected wastewater flows, existing and projected capacity and needed capital improvements.

Table 3.13-3 presents the existing and projected future average wastewater flows for VWD’s service area at 5-year increments from the base year of 2014 to 2035 and ultimate buildout conditions. These interim flow projections were estimated based upon SANDAG’s growth fo recasts for the region that were available at the time of the Master Plan’s preparation (VWD 2018). As shown in Table 3.13-3, VWD’s 2014 average daily wastewater flow was 7.5 MGD. The average annual flow projection for the ultimate condition is 14.4 MGD. This total represents the maximum potential flow based on allowable land uses and existing flows. While the ultimate flow is potentially higher, continued conservation and water use efficiency would delay reaching ultimate conditions (VWD 2018).

Table 3.13-3. Projected Wastewater Flows within VWD Service Area Year Average Annual Flows
(MGD)
Peak Dry Weather Flows
(MGD) (1)
Peak Wet Weather Flows
(MGD) (1)
Existing 2014 7.5 11.7 17.5
2020 8.7 13.2 20.0
2025 9.5 14.2 21.6
2030 9.6 14.4 21.9
2035 9.6 14.4 22.0
Ultimate 14.4 20.2 31.7
Ultimate w/ NTA (2) 15.2 21.2 33.4
Source: VWD 2018 Master Plan, page 7-19.

Notes: (1) Peak flows were estimated by applying District Peaking Curves as presented in Chapter 6 of the 2018 Master Plan.
(2) NTA is the Northern Tributary Area, a separate drainage basin located in the northern part of VWD’s service area that drains away from the wastewater collection system. NTA flows were estimated and would need further evaluation if this area is to be connected into VWD/s sewer system.

Wastewater Infrastructure and Capacity
VWD’s sewer service area is divided between two principal drainage basins which are named based on the treatment facility which serves it. The treatment facilities used by VWD are the Meadowlark Water Reclamation Facility (MRF) and the Encina Water Pollution Control Facility (EWPCF). The existing wastewater collection system includes treatment facilities, major conveyance facilities, gravity mains, trunk sewers, lift stations, siphons, and force mains. VWD is able to recycle up to 74% of the wastewater generated in the service area.

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Solids Treatment Capacity
The EWPCF is a regional treatment facility located in the City of Carlsbad with a treatment capacity of up to 40.51 MGD. VWD currently owns 10.47 MGD of solids treatment capacity at EWPCF. MRF does not have solids treatment capacity and therefore all solids are treated at the EWPCF. As shown in Table

3.13-3, VWD’s 2014 average daily wastewater flo w was 7.5 MGD. The ultimate average wastewater flow identified in the 2018 VWD Master Plan is 14.4 MGD, resulting in a projected solids treatment capacity deficiency of 3.93 MGD (VWD 2023).

Liquids Treatment Facility
VWD currently has a total of 12.67 MGD liquids treatment capacity between EWPCF and MRF. VWD owns 7.67 MGD of liquids treatment capacity at the EWPCF. MRF has a liquid treatment capacity of

5.0 MGD, with a peak wet weather capacity of 8.0 MGD. The ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected liquids treatment capacity deficiency of 1.73 MGD (VWD 2023).

Ocean Disposal Capacity
EWPCF’s ocean outfall consists of approximately 1,000 feet on land and extends approximately 7,900 feet into the Pacific Ocean. The EWPCF employs peak flow management procedures and has constructed facilities to manage peak flows, including storage tanks and pump stations. Per the 2018 Master Plan, the plant has provisions to incrementally increase capacity by adding two more 8 MG basins in the future, for a maximum storage capacity of 24 MG. The member agencies’ ability to manage inflow and infiltration into the sewer system is a major factor in deferring additional peak flow facilities or future outfall upgrades at the EWPCF (VWD 2018).

VWD currently owns 10.47 MGD of ocean disposal capacity at the EWPCF. The ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected liquids treatment capacity deficiency of 3.93 MGD (VWD 2023).

Land Outfall Capacity
A majority of VWD’s wastewater is conveyed to the EWPCF using VWD’s maintained Land Outfall. The Land Outfall is approximately 8 miles long and conveys flow by gravity as well as pressure through siphon sections. VWD maintains the entire pipeline from Lift Station No. 1 to the EWPCF. From Lift Station No. 1 to El Camino Real, VWD is the sole user of this pipeline. Total capacity of the land outfall is 20.85 MGD and the land outfall capacity controlled by VWD is 12.10 MGD (VWD 2023).

As stated above, the MRF has a capacity of 5.0 MGD with a peak wet weather capacity of 8.0 MGD.

Combined with the 12.10 MGD capacity of the land outfall controlled by VWD, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD (12. 10 MGD + 8.0 MGD). According to the VWD’s 2018 Master Plan, average daily wastewater flow through the land outfall was approximately 7.5 MGD in 2014. This corresponds to a peak wet weather flow of 17.5 MGD, which falls within VWD’s combined peak wet weathe r collection capacity. However, the 2018 Master Plan estimated that, under approved land uses, VWD has an ultimate build-out average flow of 14.4 MGD.

This corresponds to a peak wet weather flow of 31.7 MGD, which exceeds VWD’s combined peak wet weather collection capacity. To accommodate additional wastewater flows from planned development, the 2018 Master Plan recommended conveyance of peak flows to the EWPCF through a parallel land outfall (VWD 2023).

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VWD Planned System-wide Water Wastewater Facility Improvements VWD’s 2018 Master Plan analyzed the existing water and wastewater system to determine size of pipeline replacements and extensions utilizing a hydraulic model developed by collecting the system’s physical data, estimating existing water and wastewater flows, and calibrating the model using actual meter data. The 2018 Master Plan does not include development s that were not approved prior to June 30, 2014. As development projects are proposed, the project proponents will be required to prepare a study that will, at a minimum, define the location and size of the water and sewer facilities required to serve the development, including the necessary regional collection, transfer, and treatment infrastructure (VWD 2018).

Solid Waste
Solid waste disposal in the City is provided by a private franchise hauler, EDCO Waste and Recycling (EDCO), a private waste collection and recycling company which handles all residential, commercial, and industrial collections within the city. Waste collected by EDCO is hauled to the Escondido Transfer Station where it is then transported to the Sycamore Sanitary Landfill in Santee. Recyclable materials are processed at the Escondido Resource Recovery Transfer Station. The project site would be serviced by EDCO. The Escondido Transfer Station has a permitted daily tonnage of 3,223 tons per day (CalRecycle 2019a). Solid waste is consolidated here and then trucked to a landfill for disposal.

The County of San Diego prepared a Five -Year Review Report of its Integrated Waste Management Plan (2022) to plan for the next 15 years of countywide landfill disposal capacity and to determine the adequacy of the region’s planning documents based on updated demographic trends and regulations.

The report used an average of the past 15 years in -county disposal data (2005 -2020) to project disposal for the next 15 years (2022-2037). Though in- county disposal may both increase and decrease over the next 15 year s, a conservative projection is that disposal will remain near the average. The 15-year disposal average is 3,206,009 in-county tons annually (County of San Diego 2022).

The report included a second disposal projection scenario, which anticipates organic materials being diverted from the landfills at a greater rate to align with the statewide organics legislation and goals (AB 32, AB 1826, AB 1594, and SB 1383). When the 75% organics diversion rate was applied to the County’s baseline disposal, organics waste disposal projections were reduced to 288,541 tons for the year 2025. Considering the additional organics diversion scenario, the projected disposal by 2037 would be 2,282,678 tons annually, nearly a million tons (923,330 tons) less than the average disposal projection of 3,206,009 tons (County of San Diego 2022).

The second component of determining disposal capacity is the permitted daily capacities allowed by the Local Enforcement Agencies including any projected maximum disposal limits. The maximum annual allowable permitted capacity for all San Diego County land fills was 6,967,600 tons in 2021 and will be 4,134,600 tons in 2032. Landfill operators project that Otay Landfill will close in 2030 and Miramar Landfill will close in 2031. Sycamore Landfill is anticipated to receive additional waste flows at that time. The County’s report projections assumed that Sycamore Landfill will apply for three expansions to their daily permitted capacity. Sycamore Landfill has completed the California Environmental Quality Act ( CEQA) documentation for these landfill expansions; however, there has been no application to the Local Enforcement Agency to revise the Solid Waste Facility Permit. For the purposes of projection, the County assumed that the first expansion at Sycamore Landfill is estimated to occur in 2025 and daily permit ted capacity is projected to increase permitted capacity from its current 5,000 tons per day to 7,000 tons per day. The second expansion is estimated to occur in 2027

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and permitted capacity is projected to increase to 9,000 tons per day followed by a third expansion estimated to occur in 2030 to increase permitted capacity to 11,000 tons per day. The County’s report indicated that there would be adequate landfill capaci ty to serve the County for the next 15 years.

Specifically at Sycamore Landfill, the report estimated that there was 105,064,991 cubic yards (or 86,153,293 tons) remaining based on aerial survey/calculations occurring in February 2021.

Estimated closure date is listed as 2042, though the permit is anticipated to be revised and extended to 2054 (County of San Diego 2022).

Electricity and Natural Gas
SDG&E provides energy service to an estimated 3. 7 million consumers through 1.49 million electric meters and 905,000 natural gas meters in San Diego County and southern Orange County ( SDG&E 2024). Electrical facilities throughout the city include a combination of aboveground and belowground electrical distribution lines and utilities structures. The city’s fiber-optic network is facilitated by a 72- strand fiber-optic line that runs in various streets throughout the city. All major arterials in the city have implemented fiber optics. The design for the dry utilities’ connection is still under preparation, however the proposed project proposes to connect to existing underground electricity and natural gas infrastructure within Armorlite Drive. This work would take place within existing right-or-way and would not disturb any vegetation.

Telecommunications
Telecommunications services to the project site may be provided by various distributors. Existing telecommunication lines from AT&T, Cox and other independent cable companies telecommunication lines are available in the project vicinity.

3.13.2 Regulatory Setting
Existing federal, state, and local regulations related to water, wastewater, and solid waste that are applicable to the proposed project are summarized below.

Federal
Clean Water Act
The federal Clean Water Act (CWA) establishes regulatory requirements for potable water supplies including raw and treated water quality criteria. The City of San Marcos is required to monitor water quality and conform to regulatory requirements of the CWA.

Resource Recovery and Conservation Act
The Resource Recovery and Conservation Act Subtitle D focuses on state and local governments as the primary planning, regulating, and implementing entities for the management of non- hazardous solid waste, such as household solid waste and nonhazardous indu strial solid waste. Subtitle D provides regulations for the generation, transportation, treatment, storage, and disposal of hazardous waste.

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State
California Green Building Standards Code (CCR, Title 24, Part 11 – CALGreen) In 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24 of the California Code of Regulations) is commonly referred to as CALGreen and esta blishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and inte rior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low-rise residential and state-owned buildings and schools and hospitals.

The CALGreen 2022 building standards code became effective on January 1, 2023. The mandatory standards require the following measures that relate to utilities and service systems (24 CCR Part 11):
• Mandatory reduction in indoor water usage through compliance with specified flow rates for plumbing fixtures and fittings and faucets and fountains. • Mandatory reduction in outdoor water usage through compliance with a local water efficient landscaping ordinance or the California Department of Water Resources’ Model Water Efficient Landscape Ordinance.
• 65% of construction and demolition waste must be diverted from landfills. • Mandatory inspections of energy systems to ensure optimal working efficiency. • Inclusion of electric vehicle charging stations or designated spaces capable of supporting future charging stations.

The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and implemented at the discretion of local agencies and applicants. CALGreen’s Tier 1 standards call for a 15% improvement in energy requirements, str icter water conservation, 65% diversion of construction and demolition waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar -reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30% improvement in energy requirements, stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs.

Urban Water Management Plans
Urban water purveyors are required to prepare and update an UWMP every 5 years. The UWMPs address water supply, treatment, reclamation, and water conservation, and contain a water shortage contingency plan. Local UWMPs and those of other water districts ar e supplemental to the regional plans prepared by MWD. The Water Conservation Bill of 2009 (SBX7 -7) requires each urban retail water supplier to develop an urban water use target and an interim urban water use target. Notably, SBX7-7 authorizes urban retail water suppliers to determine and report progress toward achieving these targets on an individual agency basis or pursuant to a regional alliance as provided in California Water Code (CWC) Section 10608.28(a). In accordance with this regulation, the MWD pr epared and their Board of Directors adopted its 2020 UWMP in 2021. MWD’s UWMP includes estimated future water demands until 2045, using updated population projections and a conservative assumption that, in the absence of mandatory water conservation measures, per-capita consumption could rebound to

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its 2020 target value (MWD 2021). Demands provided in MWD’s UWMP have been coordinated with SDWCA, VWD’s wholesale supplier.

Assembly Bill 939 and 341
In 1989, Assembly Bill (AB) 939, known as the Integrated Waste Management Act (California Public Resources Code, Section 40000 et seq.), was passed because of the increase in waste stream and the decrease in landfill capacity. The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by the year 2000.

AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle has conducted multiple workshops and published documents that identify priority strategies that CalRecycle believes would assist the state in reaching the 75% goal by 2020.

Senate Bill 1374
Signed in 2002, the Construction and Demolition Waste Materials Diversion Requirements (SB 1374) were codified in Public Resources Code Section 42919. SB 1374 requires that jurisdictions include in their annual AB 939 report a summary of the progress made in diverting construction and demolition waste. The legislation also required that CalRecycle adopt a model ordinance for diverting 50 to 75 percent of all construction and demolition waste from landfills. The model ordinance was adopted by CalRecycle on March 16, 2004.

Assembly Bill 1826
AB 1826 requires jurisdictions to implement an organic waste recycling program for businesses, including outreach, education, and monitoring of affected businesses. Additionally, each jurisdiction is to identify a multitude of information, including barriers to organic waste recycling facilities, as well as closed or abandoned sites that might be available for new organic waste recycling facilities. AB 1826 defines “organic waste” as food waste, green waste, landscape and pruning waste, nonhazardous wood wa ste, and food -soiled paper waste that is mixed in with food waste. It also defines a “business” as a commercial or public entity, including, but not limited to, a firm, partnership, proprietorship, joint stock company, corporation, or association that is organized as a for -profit or nonprofit entity, or a multi-family residential dwelling consisting of five or more units. As of January 1, 2017, businesses that generate 4 cubic yards or more of organic waste per week are subject to this requirement. Commenci ng January 1, 2019, businesses that generate 4 cubic yards or more of commercial solid waste per week are also required to arrange for organic waste recycling services. In September 2020, CalRecycle reduced this threshold to 2 cubic yards of solid waste (i.e., total of trash, recycling, and organics) per week generated by covered businesses (CalRecycle 2024).

Senate Bill 1383
SB 1383 establishes statewide organic waste diversion rate goal of 75 percent by 2025. Beginning in 2022, SB 1383 required every jurisdiction to provide organic waste collection services to all residents and businesses, including food, green material, land scaping waste, organic textiles, lumber, paper

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products, manure, biosolids, digestate, and sludges. Jurisdictions are also required to educate residents and businesses about the collection requirements.

Local
San Diego County Integrated Waste Management Plan
Pursuant to the Integrated Waste Management Plan, the Countywide Integrated Waste Management Plan for San Diego County describes the goals, policies, and objectives of the county for coordinating efforts to divert, market, and dispose of solid waste during the planning period through the year 2017 (County of San Diego 2005). A Five-Year Review Report was prepared in 2022 to plan for 15 years of countywide landfill disposal capacity and to determine the adequacy of the region’s planning documents based on updated demographic trends and regulations. The report identified reduced landfill disposal rates compared to the high in 2005. The plan presumes waste disposal tonnages will not reach the 2005 level again due to increased State and local recycli ng programs. Another reason for reduced landfill disposal rates is increased conservation and recycling activities, expansion of compost and construction and demolition facilities, and implementation of mandatory recycling ordinances by jurisdictions. Average disposal quantities and landfill capacities are discussed above in Section 3.13.1 (County of San Diego 2022).

Countywide policies for reducing waste and implementing the programs identified in the individual jurisdiction Source Reduction and Recycling Elements and Household Hazardous Waste Elements, which are intended to reduce costs, streamline administration of programs, and encourage a coordinated and planned approach to integrated waste management.

To avoid duplication of effort, all jurisdictions in the county participate in the San Diego County Integrated Waste Management Local Task Force. The Local Task Force coordinates mandated planning, oversees implementation of new or countywide integrated wa ste management programs, and carries out an active legislative program. Regulatory reform, changes to state diversion requirements, and reduction of the costs of compliance are considered by the Local Task Force, as well as other solid waste issues of regional or countywide concern.

City of San Marcos Municipal Code
Title 8, Health and Sanitation
San Marcos Municipal Code Title 8 contains regulations and provisions on sewers and sewage disposal plants, sewer connections, septic tanks, waste matter, garbage and refuse collection, and other matters concerning sanitation. Chapter 14.15 contains regula tions concerning storm water management and discharge control. Chapter 14.24 contains regulations concerning underground utility facilities. Title 19 regulates subdivision requirements, including the installation of utility facilities and connections and payment or fees for such installations.

Title 20, Chapter 20.330 Water Efficient Landscaping Ordinance The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.

Title 20, Section 20.330, details the City’s Water Efficient Landscape (WELO). In accordance with State law, Chapter 20.330 establishes specific standards for landscape and irrigation design and installation to ensure beneficial, efficient, and responsible use of water resources within the city.

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City of San Marcos General Plan
The General Plan Conservation and Open Space Element includes two goals and one policy that are applicable to the proposed project (related to water supply and solid waste):
• Goal COS -5: Reduce water consumption and ensure reliable water supply through water efficiency, conservation, capture, and reuse.
• Goal COS -10: Establish and maintain an innovative, sustainable solid waste collection, recycling, and disposal delivery system for present and future generations. o Policy COS-10.1: Promote the curbside recycling program to divert residential refuse from the landfills.

The General Plan Land Use and Community Design Element identifies the following goals and policies regarding utilities and services systems that are applicable to the proposed project:
• Goal LU -8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU -8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities. • Goal LU-13: Water Service and Supply: Manage and conserve domestic water resources by reducing water usage and waste on a per capita basis, to ensure an adequate water supply for existing and future residents.
o Policy LU-13.1: Work closely with local and regional water providers to ensure high quality water supplies are available for the community.
o Policy LU-13.2: Actively promote water conservation programs aimed at reducing demand. o Policy LU -13.3: Encourage exploration and use of deep underground wells to reduce reliance on treatable water.
• Goal LU -14: Wastewater: Ensure an adequate wastewater system for existing and future development.
• Policy LU-14.1: Work closely with local service providers to ensure an adequate wastewater system for existing and future development is in place. o Policy LU -14.2: Ensure development approval is directly tied to commitments for the construction or improvement of primary water, wastewater, and circulation systems. • Goal LU-16: Solid waste: reduce the amount of waste material entering regional landfills with an efficient and innovative waste management program.
o Policy LU-16.1: Work closely with local service providers to ensure adequate solid waste disposal, collection, and recycling services.
o Policy LU-16.2: Increase recycling, composting, source reduction, and education efforts throughout the city to reduce the amount of solid waste requiring disposal at landfills. • Goal LU-17: Utilities and Communications: Encourage provision of power and communication systems that provide reliable, effective, and efficient service for San Marcos.

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o Policy LU-17.2: Require all new development and redevelopment to provide the technology to support multiple telecommunications facilities and providers such as multi -media products, wireless technologies, and satellite communications. o Policy LU-17.3: The City shall prohibit above ground utility equipment within any of the pedestrian pathways and street frontage areas. All above ground utilities shall be placed either within; “wet closets” within the buildings, underground vaults, or beh ind buildings where they are not visible. The developer shall be responsible to contact the applicable utility agencies in advance to coordinate utilities prior to approval of the final street improvement plans for both public and private street frontages and prior to submittal of building permits.
o Policy LU-17.4: Require utility location to be shown on all site development plans at the time of development/project application.

The proposed project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning of this EIR. As detailed in Table 3.7 -7 in Section 3.7, the project is consistent with the applicable utilities-related goals and policies.

3.13.3 Thresholds of Significance
The determination of significance for utilities and service systems is based on Appendix G of the CEQA Guidelines. Utilities and services system impacts would be significant if the proposed project meets any of the following thresholds:
• Threshold #1: Require or result in the relocation o r construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
• Threshold #2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? • Threshold #3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
• Threshold #4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
• Threshold #5: Comply with federal, state, and local management and reduction statues and regulations related to solid waste?

3.13.4 Project Impact Analysis
The proposed project would connect to the existing 8 -inch water main in Armorlite Drive for potable water and fire protection. Three water connections are proposed for the project site. One potable water connection and one connection for the fire service line will occur at the southwestern corner of the project site with Armorlite Drive. A landscaping irrigation connection is also proposed approximately at the center of the project’s southern property line along Armorlite Drive. The project proposes to upsize approximately 223 feet of the existing 8-inch water main in Armorlite Drive to 10-inch diameter (Pipe Segment P-7-55).

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For sewer service, the proposed project would connect to the existing 8- inch sewer main in Armorlite Drive. The project proposes to upsize approximately 539 feet of the existing 8-inch sewer main in Armorlite Drive to 10-inch diameter main (Pipe Segments AL-1 through AL-3).

Additionally, as a project design feature (Table 2 -1), the project applicant would pay the applicable Water and Wastewater Capital Facility Fees in effect at the time service is committed in accordance with VWD rules and regulations. Proof of payment would be provided to the City’s Planning Division Director.

The design for the dry utility connection is still under preparation, however the project proposes to connect to existing infrastructure within Armorlite Drive. This work would take place within existing right-or-way and would not disturb any vegetation.

Threshold #1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Water
As the project site lies within VWD’s water service area, VWD would provide potable water service for commercial uses, residential uses and fire protection. VWD has confirmed their ability to serve the proposed project and has prepared a Technical Memorandum which includes a Water System Analysis.

The memorandum analyzes water demand, water distribution, water storage capacity and water pump station capacity (VWD 2023, Appendix S).

Water Demand
The City of San Marcos’ approved land use designation for the project site is Public/Institutional (PI).

The project is proposing 165 residential apartments with 5, 600 square feet (s.f.) of commercial use.

Table 3.13-4 provides the average water demand generated both under the density planned for the VWD 2018 Master Plan and for the proposed project. As shown, the proposed project would increase the projected average water demand from the 2018 Master Plan land use by 36,172 gallons per day (GPD) (VWD 2023).

Water Distribution System Analysis
VWD prepared a water distribution system analysis to identify potential system impacts that may be created by the proposed water demand, and to recommend any improvements required to provide service to the project. Modeling focused on the infrastructure in the direct vicinity of the project site.

Per the 2018 Master Plan, maximum day demands for the proposed project are 300% those of average day demands, and peak hour demands are 620% those of average day demands (VWD 2023).

Pipeline design criteria states that to avoid excessive velocity and head loss within the distribution system, the maximum allowable velocity is 7 feet per second. The model found that the proposed project would not create any distribution system deficiencies under an average day demand scenario but would create system deficiencies under maximum day plus fire flow demand conditions in the existing 8-inch water main in Armorlite Drive. As discussed above, the project design includes upsizing approximately 223 feet of the existing 8-inch water main in Armorlite Drive to 10 -inch diameter (Pipe Segment P-7-55).

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Table 3.13-4. Estimated Water Demands for Proposed Project Land Use Type Area
(Acres) Residential Units Duty Factor
(GPD/DU)
Duty Factor
(GPD/acre)
Water Demand
(GPD)
2018 Master Plan Land Use Demand
Open Space(1) 2.44 0 - 200 488
Total 2.44 488
Proposed Project Demand
Residential/Mixed
Use (68 du/ac)(2) 2.44 165 200 33,000
Commercial/Mixed
Use 2.44 0 - 1,500 3,660
Total 2.44 36,660
Water Demand
Increase 36,172
Source: VWD 2023.

Notes: (1) The 2018 Water Master Plan assumed an Open Space land use designation for the project site instead of the current Public/ Institutional designation.

Notes: (2) VWD’s Master Plan down not have a unit water demand for density of 68 du/ac. The demand for this density was determined by converting VWD’s highest density residential land use category (Residential 40 -50 du/acre) from dwelling units per acre to gallons per day per unit: 9,000 gpd/ac / 45 du/ac = 200 gpd/du GPD/DU= Gallons per Day per Dwelling Unit
As shown in Table 3.13-5, an upsized pipe diameter of ten inches would reduce the velocity to 6.04 feet per second, which is below the maximum allowable velocity of 7 feet per second . Improvements would occur within an existing paved road so no additional environmental impacts would occur.

Table 3.13-5. Potable Water Pipeline Results under Maximum Day Demand plus Fire Flow Conditions Pipe ID
Number Length (ft)
Existing
Pipe
Diameter
(in)
Velocity under
Average Day
Demand (ft/s) (1)
Velocity under
Maximum Day +
Fire Flow (ft/s) (1)
Upsized
Pipe
Diameter
(in)
Velocity under
Maximum Day +
Fire Flow w/
Upsized Pipe
(ft/s) (1)
P-755 223 8 0.19 8.79 10 6.04
Source: VWD 2023.

Notes: (1) Maximum allowable velocity: 7 feet per second. ft= feet
in= inches
ft/s= feet per second
Water Storage Analysis
The 2018 Master Plan outlines VWD’s potable water storage reservoirs for each pressure zone. The proposed project is located entirely within the VWD 855 pressure zone. Water storage for this zone is located within the 920 zone and 1028 Twin Oaks pressure zones. Table 3.13-6 shows the required storage in the 855, 920, and 1028 Twin Oaks pressure zones for existing and ultimate build -out conditions relative to the existing storage provided within each zone. As shown in Table 3.13-6, there is sufficient existing storage available to meet existing demand. The proposed project would increase the projected average water demand by approximately 36,172 GPD. The amount of additional

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reservoir storage required is 500% of the project’s average day demand, which is 180,860 gallons GPD (36,172 gallons X 500%). VWD’s analysis found that water storage capacity is currently available to serve the project’s increased storage requirements. Because the proposed project would increase the ultimate water demand planned in the 2018 Master Plan, it would contribute to the existing deficiency identified for ultimate storage requirements. However, per VWD, future projects identified in the 2018 Master Plan would address and accommodate the ultimate build-out storage deficiency.

As a project design feature (Table 2 -1), the project applicant would pay Water Capital Facility Fees which would be used for the increase in storage necessitated by the project’s demand (VWD 2023).

Table 3.13-6. Existing Reservoir Storage Capacity and Requirements Pressure Zone
Existing
Average Day
Demand (MGD)
Existing Storage
Requirement
(MG)
Ultimate
Average Day
Demand (MGD)
Ultimate
Storage
Requirement
(MG)
Existing
Storage
Available (MG)
855 3.74

50.05 6.79

101.25
0 920 5.61 10.40 18
1028 Twin Oaks 0.66 3.06 73
Totals 10.01 50.05 20.25 101.25 91
Source: VWD 2023.

Notes: MGD= Million Gallons per Day
MG= Million Gallons
Water Pump Station Analysis
Since the proposed project is located in a pressure zone that is not served by pumping, there would be no impacts to existing or proposed pump stations (VWD 2023).

Summary
The project proposes to upsize approximately 223 feet of the existing 8-inch water main in Armorlite Drive to 10 -inch diameter (Pipe Segment P -7-55), which would avoid creating system deficiencies under maximum day plus fire flow demand conditions. An 8-inch fire main would parallel the potable water line for fire service to the site and a 6-inch line for fire sprinkler service would also be provided to meet fire flow requirements. These improvements would occur within the project site or within an existing paved road and would not result in any additional significant environmental impacts.

While the proposed project would increase water demand by 36,172 GPD above what the 2018 Water Master Plan identified , VWD’s analysis determined that with the water main improvements and payment of the required Water Capital Facility Fees (included as a design feature in Table 2 -1), the proposed project would have less than significant impacts related to water distribution, water storage, or water pumping (VWD 2023). The proposed project would not require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to the construction or relocation of new or expanded water collection facilities would be less than significant.

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Wastewater
The proposed project lies completely within VWD sewer shed 22C. The analysis of wastewater infrastructure is based upon the Water and Sewer Study, prepared by VWD (VWD 2023). The Water and Sewer Study is included in Appendix S of this EIR.

As described above, the proposed project would include development of 165 apartments and 5, 600 s.f. of commercial use. The current General Plan designation for the project site is Public/Institutional (PI). VWD’s 2018 Master Plan incorrectly based its ultimate wastewater generation planning on a land use of open space and assumed the project site would not generate any wastewater flow. The project is proposing a General Plan Amendment to change the site designation to SPA (Specific Plan Area) with proposed residential development (68 du/acre) and commercial use. VWD’s Master Plan does not have a unit wastewater demand for a density of 68 du/ acre; therefore, the demand for this density was determined by converting VWD’s highest density residential land use category (Residential 40-50 du/acre) from dwelling units per acre to gallons per day per unit (8,100 GPD/ac divided by 45 du/ac equals 180 GPD/du. Based on this (180 GPD /du x 165 du), the Water and Sewer Study estimated that the proposed project would generate approximately 32,628 GPD of wastewater. This is an increase in the projected average wastewater generation of 32,628 GPD (VWD 2023).

Wastewater Collection System Analysis Model Results
VWD modeled several wastewater scenarios to identify system impacts that may be created by the proposed sewer generation, and to recommend any improvements required to provide service to the proposed project. Modeling focused not only on the sewer collection infrastructure in the direct vicinity of the project site, but also on all downstream infrastructure from the development to Lift Station No. 1 on San Marcos Boulevard that would be receiving proj ect flows. The modeling results showed no deficiencies have been identified under the 2018 Master Plan land use density. The modeling results also showed the proposed project resulted in new deficiencies under peak wet weather flows during ultimate build-out conditions in the existing 8 -inch sewer line in Armorlite Drive. As discussed above, the project design includes upsizing approximately 539 feet of 8-inch pipe diameter sewer main in Armorlite Drive to 10 -inch diameter main (Pipe Segments AL -1 through AL -3). VWD modeling shows that the replacement diameter of 10 inches would sufficiently address deficiencies under peak wet weather flows. Improvements would occur within an existing paved road so no additional environmental impacts would occur.

Wastewater Lift Station Analysis
Since the proposed project is not located in a sewer shed that is served by a lift station, no lift station upgrades would be required, and no impacts would occur (VWD 2023).

Parallel Land Outfall Analysis.

VWD’s existing land outfall is approximately 8 miles in length and consists of four gravity pipeline sections and three siphon sections varying in diameter from 20 inches to 54 inches. Total land outfall capacity is 20.85 MGD, and VWD controls 12.10 MGD. The MRF has a capacity of 5.0 MGD with a peak wet weather capacity of 8.0 MGD. Therefore, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD (12.10 MGD + 8.0MGD). VWD’s 2014 average daily wastewater flow through the land outfall was 7.5 MGD, which falls within VWD’s combined peak wet weather collection capacity (VWD 2023).

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The 2018 Master Plan estimated that, under approved land uses, VWD has an ultimate build- out average dry weather flow of 14.4 MGD. This corresponds to a peak wet weather flow of 31.7 MGD, which exceeds VWD’s combined peak wet weather collection capacity. To accommodate additional wastewater flows from planned development, the 2018 Water Plan recommended conveyance of peak flows to the EWPCF through a parallel land outfall (VWD 2023).

The proposed project would generate 32,628 GPD of additional average wastewater flow that was not accounted for in the Land Outfall’s capacity studied in the 2018 Master Plan. However, per the Water and Sewer Study, prepared for the proposed project, VWD finds that outfall capacity is currently available to serve the proposed project’s expected wastewater generation. As a project design feature (Table 2-1), the project applicant would pay Wastewater Capital Facility Fees . These fees would be used toward design and construction of a parallel land outfall to be sized to accommodate ultimate build-out wastewater flows (VWD 2023).

Wastewater Treatment Facility Analysis
Because VWD utilizes both MRF and EWPCF for wastewater treatment, wastewater generated by the proposed project would be treated at either facility. MRF has liquids treatment capacity of up to 5 MGD with a peak wet weather capacity of 8 MGD. MRF does not ha ve solids treatment capacity, and therefore all solids are treated at the EWPCF. The EWPCF is a regional facility with treatment capacity of up to 40.51 MGD (VWD 2023).

Solids Treatment Capacity
VWD currently owns 10.47 MGD of solids treatment capacity at EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concluded that adequate solids treatment capacity exists at this time to serve the project. However, the ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected solids treatment capacity deficiency of 3.93 MGD. Wastewater flows from the proposed project would contribute to that deficiency. As a project design feature (Table 2-1), the project applicant would pay Wastewater Capital Facility Fees which would be used towards the deficiency to accommodate the solid treatment capacity wastewater flows (VWD 2023).

Liquid Treatment Capacity
VWD currently owns 7.67 MGD of liquids treatment capacity at the EWPCF in addition to the liquids treatment capacity of 5.0 MGD at MRF, for a total of 12.67 MGD of liquids treatment capacity. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concludes that adequate solids treatment capacity exists at this time to serve the proposed project. However, the ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected liquids treatment capacity defi ciency of 1.73 MGD. Wastewater flows from the proposed project would contribute to that deficiency. As a project design feature (Table 2 -1), the project applicant would pay Wastewater Capital Facility Fees , which would be used towards the deficiency to accommodate the ultimate average wastewater flow (VWD 2023).

Ocean Disposal Capacity
VWD currently owns 10.47 MGD of ocean disposal capacity at the EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concludes that adequate ocean disposal capacity exists at this time to serve the project. The ultimate average wastew ater flow identified in the 2018 Master Plan is 14.4 MGD resulting in an ocean disposal deficiency of 3.93 MGD. Wastewater flows

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from the proposed project would contribute to that deficiency. As a project design feature (Table 2-1), the project applicant would pay Wastewater Capital Facility Fees , which would be used towards the deficiency to accommodate the ocean disposal wastewater flow (VWD 2023).

Wastewater Summary
The project proposes to upsize approximately 539 feet of the existing 8-inch sewer main in Armorlite Drive to 10-inch diameter main (Pipe Segments AL-1 through AL-3), which would avoid creating system deficiencies under peak wet weather flows. These improvements would occur within an existing paved road and would not result in any additional significant environmental impacts.

While, the proposed project would increase wastewater flows by 32,628 GPD above what the 2018 Water Master Plan identified, VWD’s analysis determined that with the sewer line improvements and payment of all applicable Wastewater Capital Facility Fees in effect at the time service is committed in accordance with District rules and regulations (included as a project design feature in Table 2-1), the proposed project would have less than significant impacts related to wastewater collection, parallel land outfall capacity, wastewater treatment or ocean disposal capacity (VWD 2023 ). The proposed project would not require or result in the relocation or construction of new or expanded wastewater treatment facilities the construction or relocation of which would cause significant environmental effects. Therefore, impacts related to the construction or relocation of new or expanded sewer facilities would be
less than significant.

Stormwater Drainage
As discussed in Section 5.6, Hydrology and Water Quality, the proposed project has been designed to carefully handle runoff and to meet regulatory requirements to ensure that post -development runoff quantities and rates are similar to or less than the pre-development condition. Although the proposed project would include new storm water infrastructure (proprietary treatment facilit ies and an underground storage vault) to support project facilities within the project site , the proposed infrastructure has been accounted for and analy zed throughout this EIR. The project would also construct storm drain improvements within Armorlite Drive to connect the project to the existing storm drain system in Armorlite Drive. This includes the installation of approximately 175 feet of 12-inch reinforced concrete storm drain. This work would take place within the Armorlite Drive right-of-way and full pavement restoration would be required once the work is completed. All storm water quality and drainage facilities would be required with final engineering submittals in conformance with the 2023 City of San Marcos Best Management Practices Design Manual, and the project’s Storm Water Quality Management Plan and Drainage Study. These improvements would occur within an existing paved road and would not result in any additional significant environmental impacts.

The proposed project would not contribute a substantial amount of new stormwater runoff relative to existing conditions and the project would not require or result in the relocation or construction of new or expanded stormwater facilities, the construction or relocation of which could cause significant environmental effects. Therefore, impacts related to the construction or relation of new or expanded stormwater facilities are determined to be
less than significant. Please refer to Section 5.6, Hydrology and Water Quality, for additional discussion related to drainage.

Electric Power/ Natural Gas
The proposed project would be served by SDG&E for electricity and natural gas services and would be required to implement, as applicable, the City’s Climate Action Plan Consistency Checklist measures that would reduce operation al electricity consumption. The project would be required to include

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various on-site features and measures to reduce the project’s energy consumption, which includes electric vehicle charging stations, electric or solar water heaters, solar panels, a transportation demand management plan, reduced landscaping water use, and the planting of 49 trees. The proposed project would also be built under the most current Title 24 standards which are designed to reduce energy. In accordance with the current Building Code, dwelling units would include energy conservation features such as spray foam insulation, thermal breaks, low -e windows, advanced thermostats, Energy Star qualified appliances, and sealed insulated ducts.

The design for the dry utilities’ connection is still under preparation. Final utility equipment design will be coordinated with a utility consultant, the City, and SDG&E. Any proposed above-ground transformers and electrical facilities that solely service the Specific Plan area will be placed on -site and not within the City’s right-of-way. Additionally, General Plan Land Use Policy LU-17.3 prohibits above-ground utility equipment within any of the pedestrian pathway and street frontage areas.

SDG&E maintains a gas distribution system within Armorlite Drive. If the project utilizes gas utilities, the gas lines will be extended to the developable area within the Specific Plan Area through the same joint trench alignment as electric, cable, and telephone facilities. It is likely that either a three-inch or four-inch pipeline would be utilized to deliver gas to the project site. These improvements would take place within existing right -of-way, would not disturb any vegetation , and have been accounte d for in this EIR. Aside from these improvements, the proposed project would not require the relocation or construction of new or expanded electrical power, or natural gas facilities, the construction or relocation of which could cause significant environmental effects. Impacts would be less than significant.

Telecommunications
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. Existing telecommunications infrastructure in the vicinity of the project site would be available to serve the pro posed project. No specific systems upgrades are proposed or would be required to serve the proposed project. Thus, the proposed project would not result in physical impacts associated with the construction or relocation of telecommunications systems. Impacts would be less than significant.

Threshold #2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As discussed in response to Threshold #1, the proposed project would be served by VWD. Per the Water and Sewer Memorandum (Appendix S of the EIR) , the proposed project is anticipated to generate an additional 36,172 GPD of water demand over the ultimate demand projected in the 2018 Master Plan. This equates to approximately 40.15 acre-feet per year.

As discussed above, MWD’s UWMP shows water supplies would be available to meet current and future demands of the region. With a projected annual water demand of 5,374,000 acre-feet per year in 2045, the MWD UWMP demonstrates that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2045 under normal, single dry, and multiple dry water years (MWD 2021). Additionally, SDCWA’s UWMP assessed water reliability from 2025 through 2045 and d etermined that there are sufficient supplies to meet projected demands under Single Dry-Year and Multiple Dry-Year conditions (SDCWA 2021). The additional 40.15 acre-feet per year of water demand generated by the proposed project represents 0.00074% of

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projected regional demand (5,374,000 acre- feet per year) in 2045. This represents a less than significant increase in water demand relative to the annual water demand projected by the MWD’s UWMP.

Further, the project site would be developed in compliance with CALGreen, which implements water efficiency standards for appliances and fixtures. Compliance with CALGreen would further reduce project water usage in combination with VWD and MWD’s ongoing w ater conservation practices.

Compliance with these regulations and conservation measures would ensure sufficient water supplies are available to service the proposed project. Therefore, impacts to water supply would be less than
significant.

Threshold #3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
As discussed under Threshold #1, above, the project site is within VWD’s service area and VWD would provide service to the proposed project. The proposed project is expected to increase wastewater flows by 32,628 GPD over what was assumed in the 2018 Master Plan. This would lead to an increase of 32,628 GPD in solids handling, liquids handling and ocean disposal capacity requirements at the EWPCF and in the parallel land outfall’s capacity requirement. VWD has determined that with sewer line improvements included in the project design (upsizing the 8-inch sewer main in Armorlite Road to 10 inches), there would be adequate wastewater collection infrastructure to serve the project.

In the Water and Sewer Study prepared for the proposed project, VWD concluded that adequate collection, treatment (solids and liquids) and disposal capacity exists at this time to serve the project (VWD 2023). The 2018 Master Plan identified ultimate average wastewater flows that would result in a projected collection, treatment and ocean disposal capacity deficiency. The project’s increased wastewater flows would contribute to those deficiencies. However, . as discussed in the Water and Sewer Study (Appendix S), and as a project design feature (Table 2-1), the project applicant would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations. These fees would be used toward design and construction of a parallel land outfall and used to accommodate the projected deficiencies in solids and liquids treatment capacity and ocean disposal capacity. Because the proposed project would not exceed current capacities of the wastewater treatment system and would contribute Wastewater Capital Facility fees that would be used towards improvements, impacts to water treatment collection and capacity would be
less than significant.

Threshold #4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Construction of the proposed project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, packing materials, and plastics. The City works with EDCO to promote its construction and demolition material waste removal and recycling program. A minimum of 65% of non -hazardous construction and demolition waste would be recycled pursuant to the requirements of CalGreen Tier 1 Standards, and construction would not impair the attainment of solid waste reduction goals.

Operation of the proposed project would result in increased generation of solid waste. The anticipated solid waste generation from the proposed project was estimated using CalRecycle Estimated Solid Waste Generation Rates (CalRecycle 2019b). It is estimated that the residential portion of the project

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(165 units) would generate approximately 2,018 pounds of solid waste per day (12.23 pounds per household). The 5,600 s.f. of commercial portion of the project is estimated to generate 258 pounds per day (0.046 pounds per s.f.), for a total of 2,276 pounds or 1.14 tons per day. This does not consider any waste diversion through recycling.

AB 939 mandated a reduction of waste being disposed of where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by the year 2000. AB 341 amended AB 939 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source -reduced, recycled, or composted by the year 2020, and annually thereafter. According to CalRecycle, the C ity has a disposal rate target of 8.9 pounds per person per day and 19 pounds per employee per day. If the City meets this target, the City is considered in compliance with requirements of AB 939. The most recent data (2022) from CalRecycle identifies the annual per capita disposal rate as 5. 3 pounds per person per day and 12.5 per employee per day (CalRecycle 202 2). Thus, the City is exceeding their targets for diversion and is therefore in compliance with state mandates aimed toward the attainment of solid waste reduction goals. The project would be required to adhere to the City’s disposal, recycling and organics composting requirements that contribute toward meeting these solid waste reduction goals.

Solid waste generated by the proposed project would be collected and transported to the Sycamore Sanitary Landfill by EDCO. The facility currently has a daily permitted capacity of 5,000 tons per day for solid waste but is projected to increase to 7,000 tons per day in 2025 and 9,000 tons per day in 2027. Sycamore landfill’s estimated closure date is listed as 2042, though the permit is anticipated to be revised and extended to 2054 (County of San Diego 2022). Solid waste generated by the proposed project would contribute a minimal amount of solid waste to Sycamore Sanitary Landfill’s daily permitted capacity. As such, the proposed project’s solid waste generation can be accommodated at the landfill. The project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Therefore, impacts would be less than significant.

Threshold #5: Comply with federal, state, and local management and reduction statues and regulations related to solid waste?
The proposed project would comply with all federal, state, and local statues and regulations regarding solid waste. The project would include trash enclosures with clearly marked, source-sorted receptacles for disposing of solid waste, recyclables, and org anic waste to facilitate compliance with the requirements of AB 341, AB 939, AB 1826, SB 1383, and CALGreen Code. Additionally, all solid waste facilities, including landfills, require solid waste facility permits to operate. In San Diego County, Public Resources Code (Sections 44001- 44018) and California Code of Regulations Title 27, Division 2, Subdivision 1, Chapter 4 (Section 21440 et seq.) authorizes the County Department of Environmental Health, Local Enforcement Agency to issue solid waste facility permits. Sycamore Sanitary Landfill is a permitted facility and EDCO is a licensed hauler. As such, the proposed project would comply with existing regulations related to solid waste disposal and would not violate federal, state, or local management and re duction statutes and regulations related to solid waste. Impacts would be less
than significant.

3.13.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA

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Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future projects producing relat ed impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to utilities and services systems, the cumulative analysis is based upon a combined list and plan project approach.

Water
All of the cumulative projects included in Table 2 -3 are within VWD’s service area for potable water service and would contribute to the cumulative demand for water supply and water infrastructure.

However, MWD anticipates the demand of future development through their master planning process.

According to MWD’s UWMP, no water shortages are anticipated within MWD’s service area in single or multiple dry years through 2045.

As described in Section 3.13.4, Threshold #2, above, the project would generate an additional 40.15 acre-feet per year of water demand that wasn’t included in MWD’s projections. However, that increase represents 0.00074% of projected regional demand (5,374,000 acre- feet per year) in 2045, which would result in less than significant impacts to water supply services. As discussed in Section 3.13.1, MWD has determined that with supplies provided by SDCWA and compliance with the Water Conservation Bill of 2009, no water shortages would occur in a normal year through 2045 (MWD 2021). Other cumulative projects that are consistent with the land use assumptions made in MWD’s UWMP would have already been accounted for in demand projections. Projects that are inconsis tent with the land use assumptions made in MWD’s UWMP would also be subject to CEQA and required to include water supply analysis to demonstrate adequate supply for development. Further, related projects would be required to show that adequate infrastructu re exists to serve the related projects and mitigate any potential impacts to water infrastructure caused by those projects. All projects would be required to pay applicable Capital Facility Fees to VWD or the applicable water service provider, which are required to go towards infrastructure improvements. Thus, cumulative impacts to water services would be
less than significant.

Wastewater
Cumulative projects that are within the VWD service area for wastewater services would contribute to the cumulative demand for wastewater services. VWD anticipates the demand of future development through their master planning process. Cumulative projects that are consistent with the land use assumptions made in VWD’s Master Plan would have already had their demand accounted for.

As discussed in Section 3.13.4, above, VWD has sufficient capacity at this time to account for the proposed project’s estimated increase in wastewater generation. However, VWD identified existing system deficiencies in capacity for solids handling, liquids handling, ocean disposal and parallel land outfall’s capacity for ultimate build -out wastewater flows. The cumulative projects that result in an increase in density or development over what was accounted for in VWD’s Master Plan would further exacerbate these deficiencies. Per VWD, payment of Wastewater Capital Facility fees would go toward projects identified in their 2018 Master Plan including upsizing applicable pipelines and design and construction of a parallel land outfall (VWD 2023). The project applicant for the proposed project and for cumulative projects would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations, which would be utilized to fund the identified projects in the 2018 Master Plan. Thus, with payment of all applicable

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Wastewater Capital Facility fees to VWD, cumulative impacts to wastewater treatment facilities would be less than significant.

Electrical Power and Natural Gas
Potential cumulative impacts related to electricity and natural gas infrastructure would result if the project, in combination with past, present, and future projects, would require or result in the relocation or construction of new or expanded electricity or natural gas facilities, the construction or relocation of which could cause significant environmental effects.

As described in Section 3.13.4 above, the proposed project would have a less than significant impact related to electricity and natural gas. Each of the cumulative projects identified in Table 2-3 would be within the service area of SDG&E. Each of the cumulative projects would be required to analyze their potential for impacts related to the provision of electricity and natural gas services, including the need for new or expanded utility infrastructure, and would be required to mitigated potential impacts f rom expanded infrastructure to below a level of significance. Cumulative projects are also required to comply with the state’s energy efficiency standards and local regulations. Additionally, SDG&E regularly undertakes upgrades and expansions, as needed, throughout their service area to continue provide reliable electricity and natural service. SDG&E conducts their own CEQA review on these projects. In conclusion, cumulative impacts related to the provision of electrical power and natural gas would be
less than significant.

Solid Waste
Future development projects would generate solid waste to be disposed of at the Sycamore Sanitary Landfill. The facility has a daily permitted capacity of 5,000 tons/day for solid waste (expected to increase to 7,000 tons per day in 2025, and 9,000 tons per day in 2027). As of February 2021, remaining capacity was 105,064,991 cubic yards or approximately 86 million tons with an anticipated closure date of 2042, likely to be revised and extended to 2054 (County of San Diego 2022). Further, there are five other landfills in the County. This includes Borrego Landfill, with a remaining capacity of 88,750 cy and a closure date of 2046; Miramar Landfill, with a remaining capacity of 11,080,871 cy and a closure date of 2031); Otay Landfill, with a remaining capacit y of 11,122,997 cy and closure date of 2030, and two U .S. Marine Corps landfills – Las Pulgas and San Onofre, with remaining capacities of 5,657,717 and 1,057,605 cy and 2060 and 2031 closure dates respectively (County of San Diego 2022).

Combined, t he proposed project and cumulative projects include 4,143 residential units, approximately 852,473 s.f. of commercial/industrial/office and 122 hotel rooms. When the CalRecycle Estimated Solid Waste Generation Rates (CalRecycle 2019b) are applied to the proposed project and the cumulative projects, the total solid waste anticipated to be generated is 65,270 pounds per day or 32.6 tons/day. This is prior to any diversion from mandatory recycling and green waste/organics programs. If a 75% diversion rate set by AB 341 is met by all the cumulative projects, the net solid waste generation c ould be reduced to approximately 8.16 tons/day. The Sycamore Sanitary Landfill has a daily permitted capacity of 5,000 tons/day, which is expected to increase to 7,000 tons/day in 2025 and 9,000 tons/day in 2027 (County of San Diego 2022) . The cumulative projects would result in an incremental contribution (8.16 to 32.6 tons/day) to the landfill capacity (5,000 to 9,000 tons/day) ; however, even without considering di version, the impact would be less than significant.

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3.13.6 Mitigation Measures
Impacts would be less than significant, so no mitigation measures are required.

3.13.7 Conclusion
Development of the proposed project would result in an incremental increase in the need for water, wastewater, stormwater, energy, and solid waste services. However, as outlined in the project impact analysis above, it was determined that water, wastewater, stormwater, energy, and solid waste services would be adequate and the proposed project would not result in the relocation or construction of new or expanded facilities, the construction or relocation of which could cause significant environmental effects. Therefore,
project- and cumulative-level impacts would be less than significant.

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4.0 Alternatives

4.0 Introduction to Alternatives
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that an Environmental Impact Report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.”
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6(a) of the CEQA Guidelines).

In developing the alternatives to be addressed in the EIR, the potential alternatives were evaluated in terms of their ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the project identified in Section 3.0, Environmental Analysis, of the EIR.

In determining what alternatives should be considered in an EIR, it is important to acknowledge the objectives of the project, the project’s significant effects, and unique project considerations. These factors are important to the development of alternati ves that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs must contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether an alternative is feasible or infeasible is made by the lead agency’s decision‐making body, the San Marcos City Council (see Public Resources Code Section 21081[a] [3]).

4.1 Project Objectives
The following project objectives describe the purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in the EIR:
• Maximize housing opportunities close to major transit facilities, education facilities, shopping and employment opportunities, and trails to optimize land use with transit use and active modes of transportation, reduce reliance on automobiles, and potentially reduce greenhouse gas emissions.
• To the extent possible, given site constraints, maximize the opportunity to provide transit - oriented housing for the City of San Marcos up to 67 dwelling units per acre. • Develop high-quality market-rate for rent housing which meets the housing needs of the City of San Marcos and the region.
• Provide an affordable dwelling unit component that satisfies the State of California qualifying affordable housing income category of very -low income (30 to 50% of area median income [AMI]), through development onsite.
• Facilitate connections to the Armorlite Drive complete street circulation system and provide pedestrian friendly architecture and landscaping to promote walkability and connect ivity for people to surrounding transit and places.

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• Design a vehicular circulation system that adequately accommodates traffic and minimizes traffic impacts in and around the project area.
• Establish development standards and design guidelines that ensure distinctive architecture, landscaping and recreational amenities that complement and enhance the existing surrounding neighborhood while providing a desirable living environment for resident s within the Specific Plan area.
• Provide flexible “flex” Commercial space that is capable of adapting to future market conditions and designed to support potential future retail needs. • Institute a program for the long-term maintenance of the community to ensure all facilities are adequately maintained to City standards.
• Finance or contribute a fair share of funding to all community services and infrastructure needed to support development proposed by the Specific Plan to promote economic stability.

4.2 Project Alternatives Considered in This EIR

4.2.1 Description of Alternative
The following alternatives are under consideration for this project:
• No Project/No Development Alternative (Section 4.3.3) • No Project/ Existing Plan Alternative (Section 4.3.4) • Reduced Development Footprint Alternative (Section 4.3.5) • Reduced Intensity Alternative (Section 4.3.6)
Alternatives considered and removed from further consideration are summarized in Section 4.4.

4.2.2 Summary of Impacts
Project- and cumulative-level impacts associated with implementation of the proposed project are evaluated in Sections 3.1, Aesthetics, through 3.13, Utilities and Service Systems, of the EIR. As identified in Table 1 -1, in Chapter 1, Executive Summary, co nstruction and/or operation of the proposed project would have the potential to cause the following significant but mitigable environmental impacts:
• Impact BIO-1: There is p otential to impact avian species protected under the Migratory Bird Treaty Act and California Fish and Game Code 3503.5 and other wildlife and if tree removal, vegetation removal, or other construction activities occur during the nesting season. • Impact BIO -2: Potential for indirect impacts to sensitive species due to dust, trash, and accidental transport of non -native plant species into the project site, and invasive plant species, and noise and lighting effects.
• Impact BIO-3: Impact to 2.13 acres of Diegan coastal sage scrub and 0.12 acres of non-native grassland-broadleaf dominated for a total of 2.25 acres of impact • Impact CR -1: Due to grading and ground disturbing activities, the proposed project may uncover previously unidentified archeological resources associated with SDI -5633 or may

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result in previously unknown archaeological resources associated with other time periods or cultures.
• Impact CR -2: There is a potential for project construction activities to disturb previously unidentified human remains on the project site.
• Impact N-1: Noise level during rock drilling and blasting. • Impact N-2: Noise levels during rock crushing.
• Impact TCR-1: As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource that is eligible for inclusion in the California Register of Historical Resources.

All project impacts would be mitigated to below a level of significance.

4.2.3 No Project/No Development Alternative
Under the No Project/No Development Alternative, the proposed project would not be implemented, and the project site would remain undeveloped and in its current condition. No grading or construction would occur on the project site under this alternative. T he project site is currently undeveloped and supports Diegan coastal sage scrub, non-native grassland, and disturbed habitat.

4.2.3.1 Comparison of the Effects of the No Project/No Development Alternative to the Proposed Project
Aesthetics
Under this alternative, the project site would remain in its current condition and the visual character of the site would not change. This alternative would not add additional sources of lighting to the project site and vicinity. The project site is generally flat with elevations ranging from 575 above mean sea level (amsl) in the central knoll on the site to approximately 562 feet amsl along Armorlite Drive. The project site is currently undeveloped, vacant land and supports Diegan coastal sage scrub, non-native grassland, and disturbed habitat. As discussed in Section 3.1, Aesthetics, the proposed project’s aesthetics impacts were determined to be l ess than significant. Compared to the proposed project, this alternative would reduce aesthetics impacts since no development would occur and no visual change would occur . No aesthetics impacts would occur under the No Project/No Development Alternative.

Air Quality
Under the No Project/No Development Alternative, air emissions associated with project construction including emissions associated with grading, site preparation, potential blasting and rock crushing, site finishing and building finishing would not occur. Implementation of this alternative would not introduce any uses that could generate operational air emissions. Therefore, this alternative would not result in any construction or operational air pollutant emissions. As discussed in Section 3.2, Air Quality, the proposed project’s air quality impacts were determined to be less than significant, and no mitigation was identified. Compared to the proposed project, this alternative would reduce air pollutant emissions. No air quality impacts would occur under the No Project/No Development Alternative.

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Biological Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.

Therefore, this alternative would avoid potential impacts to nesting birds (Impact BIO-1) since no trees or vegetation would be removed. This alternative would also avoid the direct impacts to 2.13 acres of Diegan coastal sage scrub and 0.12 acres of non-native grassland (Impact BIO-3) since no vegetation would be removed. This alternative would also avoid the potential for indirect impacts to sensitive species due to dust, trash, accidental transport of non -native plant species into the project site, and invasive plant species, and noise and lighting effects (Impact BIO-2). As discussed in Section 3. 3, Biological Resources, the proposed project’s impacts to biological resources were determined to be mitigated to less than significant. Compared to the proposed project, this alternative would eliminate the potential biological resources impacts and would not require mitigation measures . No biological resources impacts would occur under the No Project/No Development Alternative.

Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.

Therefore, there would be no potential for the project to uncover previously unidentified archeological resources associated with SDI -5633 or to uncover previously unknown archaeological resources associated with other time periods or cultures (Impact CR -1). Further, there would be no potential to disturb previously unidentified human remains that may be present on the project site (Impact CR-2).

As such, mitigatio n measures MM -CR-1a, MM -CR-1b and MM -CR-2 would not be implemented or required. As discussed in Section 3.4, Cultural Resources, the proposed project’s impacts to cultural resources were determined to be mitigated to less than significant. Compared to the proposed project, this alternative would eliminate the potential cultural resources impacts and would not require mitigation. However, under this alternative, there would not be any protection or repatriation afforded to the existing cultural resources on the site , and they could be subject to future disturbance from those who may access the site without authorization. No cultural resources impacts would occur under the No Project/No Development Alternative.

Energy
Under the No Project/No Development Alternative, there would be no energy use associated with construction and operation since no development would occur. As discussed in Section 3.5, Energy, the proposed project’s energy -related impacts were determined to be less than significant, and no mitigation was identified. Compared to the proposed project, th is alternative would eliminate the energy use identified for the project . No energy impacts would occur under the No Project/No Development Alternative.

Greenhouse Gas Emissions
Under the No Project/No Development Alternative, greenhouse gas (GHG) emissions associated with construction and operational activities would not occur , since no development would occur. As discussed in Section 3. 6, Greenhouse Gas Emissions, the proposed project’s GHG impacts were determined to be less than significant, and no mitigation was identified. Compared to the proposed project, this alternative would reduce GHG emissions . No GHG impacts would occur under the No Project/No Development Alternative.

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Land Use and Planning
Under the No Project/No Development Alternative, the project site would remain undeveloped and none of the discretionary approvals identified for the project would be required. The General Plan Amendment to change the designations of the site from PI (Public Institutional) to Specific Plan Ar ea (SPA) and a rezone to change the existing Public-Institutional (P -I) to Specific Plan Area (S PA) would not be required. As discussed in Section 3.7, Land Use, the proposed project’s land use and planning impacts were determined to be less than significant, and no mitigation was identified. Compared to the proposed project, this alternative would further minimize potential impacts related to land use and planning. No land use and planning impact would occur under the No Project/ No Development Alternative.

Noise
The project site is currently vacant and does not generate any noise. Under the No Project/No Development Alternative, the project site would remain undeveloped and would not create any new sources of construction or operational noise. Therefore, this alternative would avoid the potential noise impacts associated with rock drilling and blasting (Impact N -1) and rock crushing (Impact N -2). As discussed in Section 3.8, Noise, the proposed project’s noise impacts were determined to be mitigated to less than si gnificant. Compared to the proposed project, this alternative would eliminate the potential noise impacts and would not require mitigation measures. No noise impacts would occur under the No Project/No Development Alternative.

Population and Housing
The project site is currently vacant and located adjacent to commercial and residential uses. The No Project/No Development Alternative would not induce population growth in the area, as no development would occur. As described in Section 3.9, Population and Housing, the proposed project would add an additional 512 people on site through the proposed residential use and up to six employees associated with the commercial use. This was not considered a substantial impact to population growth in the area and a less than significant impact was identified. Unlike the proposed project, no housing would be added to the site under the No Project/No Development Alternative, so this alternative would not contribute to meeting regional housing demands, including the provision of affordable units. However, compared to the proposed project because this alternative does not result in the addition of people on site, impacts would be reduced. No population and housing impacts would occur under the No Project/No Development Alternative.

Public Services
The No Project/No Development Alternative would not result in an increase in demand for public services, since no residential or commercial uses would be developed and there would be no increase in the City’s population. Specifically, the No Project/No Dev elopment Alternative would not increase the demand for police and fire protection services, nor would this alternative increase demand for park, school, and library services. As discussed in Section 3.10, Public Services, the proposed project’s public serv ices impacts were determined to be l ess than significant. Compared to the proposed project, s ince this alternative would not result in additional residents on site, impacts on public services would be eliminated. No public services impacts would occur under the No Project/No Development Alternative.

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Transportation
The No Project/No Development Alternative would not result in the generation of vehicular average daily trips (ADT) or vehicle miles traveled (VMT). As discussed in Section 3.11, Transportation, the proposed project was determined to have no impact related to conflicts with any applicable plans or polices that address the circulation system, and a less than significant impact related to VMT.

Compared to the proposed project, since this alternative would not generate any additional vehicle trips or vehicle m iles traveled, impacts related to transportation would be eliminated. No transportation impacts would occur under the No Project/No Development Alternative.

Tribal Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.

Therefore, there would be no potential for construction activities to cause a substantial adverse change to a tribal cultural resource that is eligible for inclus ion in the California Register of Historical Resources (Impact TCR-1). As such, mitigation measures MM-TCR-1 through MM-TCR-9 would not be implemented or required. As discussed in Section 3.12, Tribal Cultural Resources, the proposed project’s impacts to tribal cultural resources were determined to be mitigated to less than significant.

Compared to the proposed project, this alternative would eliminate the potential tribal cultural resources impacts and would not require mitigation. However, under this alternative, there would not be any protection or repatriation afforded to the existing tribal cultural resources on the site and they could be subject to future disturbance from those who may access the site without authorization. No tribal cultural resources impacts would occur under the No Project/No Development Alternative.

Utilities and Service Systems
No development would occur under the No Project/No Development Alternative. As such, there would be no increase in demand for water service, wastewater service, stormwater capacity, energy, and solid waste handling services. As discussed in Section 3.13, Util ities and Service Systems, the proposed project’s impacts related to utilities and services systems were determined to be less than significant. Compared to the proposed project, because no development would occur under this alternative, impacts on utiliti es and services would be eliminated. No utilities and service system impacts would occur for the No Project/No Development Alternative.

Conclusion
Since the No Project/No Development Alternative would not develop any residential or commercial uses on the project site, overall impacts would be less than those of the proposed project or eliminated entirely. There are some benefits of the project that w ould not be realized under this alternative, including providing additional housing units, including affordable units, which helps the City meet its Regional Housing Need Allocation numbers. Under this alternative, off -site water, sewer, and stormwater infrastructure improvements would not be realized. Also, under this alternative there would not be any payment of the City’s public facility fees ( PFF), which goes toward supporting a variety of services and improvements in the City, including but not limited to Circulation Streets, State Route 78 Interchanges, National Pollutant Discharge Elimination System, Tech Improvements, Parks, and Habitat Conservation. Payment of these fees provides improvements that benefit all residents of the city. Similarly, this a lternative would not contribute any school fees. Finally, there would not be any protection or repatriation afforded to the existing cultural resources and tribal cultural resources on the site and they could be subject to future disturbance from those who may access the site without

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authorization. The No Project/ No Development Alternative would not meet any of the project objectives (Table 4-1).

4.2.4 No Project/Existing Plan Alternative
Under the No Project/Existing Plan Alternative, the project site would be developed consistent with the site’s existing land use designation. The project site has an existing General Plan Land Use designation of Public/Institutional (PI) which has a maximu m floor area ratio (FAR) of 3.0. According to Table 2 -3 of the Land Use Element of the City’s G eneral Plan, this designation is for “facilities built and maintained for public use such as academic facilities, institutional uses, community service facilities, water and sewer facilities, detention and drainage facilities, cemeteries, police and fire stations, and other government buildings and properties. This designation may include privately owned facilities built and maintained for public use” (City of San Marcos 2012).

One development scenario that would meet the P -I (Public/Institutional) zoning requirements would be a three story, 160,000 square foot (s.f.) telecommunications building that would be used as a data center. This is similar to the existing use of the adjacent AT&T facility and since AT&T was the previous owner of the project site, a data center would be a logical alternative use. Overall, the development footprint would stay the same as the proposed project.

4.2.4.1 Comparison of the Effects of the No Project/Existing Plan Alternative to the Proposed Project Aesthetics
The No Project/Existing Plan Alternative would develop a three-story, 160,000 s.f. telecommunications building. This building would be smaller in height and bulk that the proposed residential building since the project proposes five stories. Similar to the proposed project, architectural treatments would be incorporated into the design of this alternative to provide for visual interest and to break up the bulk and scale of the development. Additionally, this alternative would incorporate light ing for safety, security and way finding. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. As with the proposed project, a landscape concept plan would also be implemented. As discussed in Section 3.1, Aesthetics, the proposed project’s aesthetics impacts were determined to be less than significant. Compared to the proposed project, this alternative would have a similar level of aesthetics impacts. Additionally, unlike the proposed project, PRC 21099(d) would not be applicable. A esthetics impacts would be less than significant under the No Project/ Existing Plan Alternative.

Air Quality
Under the No Project/Existing Plan Alternative, air pollutant emissions associated with project construction including emissions associated with grading, site preparation, site finishing and building finishing would still occur. Construction is assumed to be similar in terms of schedule and equipment to the proposed project so construction emissions for the No project/ Existing Plan Alternative are anticipated to be similar compared to the proposed project.

Emissions from vehicles going to and from the project site typically account for the largest portion of operational air quality emissions. It is anticipated that this alternative could generate approximately 161 ADT per day, which is 1,053 fewer ADT than the proposed project (1,214 ADT). However, data centers are recognized as very high consumers of electrical energy. This alternative would require at

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least 257,600 megawatt hours (MWH) of electricity annually, which is about 285 times more electricity than the proposed project (907 MWH). The significantly increased electricity use would contribute to higher operational emissions when compared to the proposed project.

Additionally, data centers are not typically considered to be sources of odors. Similar to the proposed project, impacts related to odors would be less than significant under this alternative.

In summary, as discussed in Section 3.2, Air Quality, construction, and operation emissions were determined to be less than significant. The potential for odor impacts was also found to be less than significant. Compared to the proposed project, impacts related to odor and construction emissions for the No project/ Existing Plan Alternative are anticipated to be reduced compared to the proposed project due to a smaller building size, and would be less than significant. Compared to the proposed project, the No Project/ Existing Plan Alternative would generate higher levels of operational emissions due to increased energy use, but emissions would likely still be less than significant. Air Quality impacts would be less than significant under the No Project/Existing Plan Alternative.

Biological Resources
The No Project/Existing Plan Alternative would have a similar footprint of disturbance as the proposed project. Therefore, this alternative would also result in the potential for impacts to nesting birds (Impact BIO-1), Diegan coastal sage scrub and non -native grassland (Impact BIO -3), and indirect impacts to sensitive species (Impact BIO -2). As discussed in Section 3. 3, Biological Resources, the proposed project’s impacts on biological resources were determined to be mitigated to less than significant.

Biological resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -BIO-1a through MM -BIO-3) and would reduce impacts to below a level of significance. Compared to the proposed project, this alternative would have a similar level of impact. Biological resources impacts would be mitigated to less than significant under the No Project/No Development Alternative.

Cultural Resources
The No Project/Existing Plan Alternative would have a similar footprint of disturbance as the proposed project. Therefore, the potential to uncover previously unidentified archeological resources associated with SDI-5633 or may result in previously unknown archaeological resources associated with other time periods or cultures could still occur under this alternative (Impact CR -1). Similarly, there is a potential to impact unidentified human remains (Impact CR-2) under this alternative. As discussed in Section 3.4, Cultural Resources, the proposed project’s impacts to cultural resources were determined to be mitigated to less than significant. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1a, MM-CR-1b and MM-CR-2) and would reduce the impacts to below a level of significance. The No Project/Existing Plan Alternative would have a similar level of cultural resources impacts as the proposed project.

Energy
Construction of the No Project/Existing Plan Alternative is assumed to be less in terms of schedule and equipment since the building would be smaller in heights and size. This translate to a reduction in construction -related energy compared to the proposed project . Operationally, data centers are recognized as very high consumers of electrical energy. This alternative would require at least 257,600 MWH of electricity annually , which is 285 times more electricity than would be required for the proposed project (907 MWH). Data centers typically do not require natural gas so this alternative would

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require 1,192,176 kBTU less natural gas than the proposed project. Additionally, this alternative is anticipated to generate fewer ADT than the proposed project (161 compared to 1,214) which would reduce petroleum use.

As discussed in Section 3.5, Energy, the proposed project’s energy-related impacts were determined to be less than significant, and no mitigation was identified. Compared to the proposed project, less natural gas and petroleum would be used under this alternative but substantially more electricity would be required. Nonetheless, similar to the proposed project, this alternative would incorporate energy conservation features consistent with the requirements of Title 24 and the City’s Climate Action Plan and would not result in the wasteful or inefficient use of energy or a conflict with a state or local plan for energy efficiency. While this alternative would use more electricity than the proposed project, energy impacts would be less than significant under the No Project/Existing Plan Alternative Greenhouse Gas Emissions
Construction of the No Project/Existing Plan Alternative is assumed to shorter in duration due to a smaller buildings being constructed compared to the proposed project. Therefore, construction-related GHG emissions would be lower under this alternative compared to the proposed project. Operationally, data centers are recognized as very high consumers of electrical energy. The No Project/ Existing Plan Alternative would require at least 257,600 MW H of electricity annually , which is 285 times more electricity than would be required for the proposed project (907 MWH) . Based on the City’s Climate Action Plan, a building of 16 0,000 s.f. would be required to install 0.322 Megawatt direct current (MWdc) (2 watts dc per s.f. * 160,000 s.f. / (1 million watts per megawatt) ) of solar which would generate 553 MWH of electricity per year. The data center would consume 257,600 MWH annually so the solar photovoltaic (PV) system would provide less than one percent of the total energy required.

Based on CalEEMod, the data center would generate 5,505 MT CO2e just from electrical consumption alone (see Attachment B of the GHG report, which is Appendix E of this EIR). Therefore, the required solar PV system would not reduce emissions sufficiently to reduce emissions to less than what would be expected by the proposed project. In addition to emissions from energy use, this alternative would also generate emissions from vehicular trips, area sources such as landscaping, and waste management, which were not included in the 5,505 MT CO 2e estimate. The proposed project was estimated to generate 1,300.61 MT CO2e. The No Project/ Existing Plan Alternative would therefore have a 77% more intense carbon footprint than the proposed project.

In summary, as discussed in Section 3. 6, Greenhouse Gas Emissions, the proposed project’s GHG related impacts were determined to be less than significant, and no mitigation was identified.

Compared to the proposed project, the No Project/ Existing Plan Alternative would generate substantially more GHG emissions due to increased electricity use. Nonetheless, since this alternative is consistent with the City’s General Plan, its GHG emissions would have been accounted for the in the City’s Climate Action Plan. Therefore, with compliance with the City’s Climate Action Plan and Title 24 requirements, the No Project/ Existing Plan Alternative would not generate GHG emissions that would have a significant impact on the environment and would not conflict with any a pplicable plan, policy, or regulation adopted for the purpose of reducing GHGs. GHG generation under this alternative would be greater compared to the proposed project. However, GHG impacts would still be less than significant under the No Project/Existing Plan Alternative.

Land Use and Planning
Under the No Project/Existing Plan Alternative, a General Plan Amendment and Rezone would not be required as the development would be consistent with the General Plan and zoning designation

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assigned to the project site. Development under this alternative would generate fewer ADT than the proposed project (161 compared to 1,214). Similar to the proposed project, it is anticipated that adequate level of service performance would still occur on area roadways and intersections.

Development under this alternative would still be required to participate in Community Facility District:

CFD2011-01 (Congestion Management).

As discussed in Section 3.7, Land Use, the proposed project’s land use and planning impacts were determined to be less than significant, and no mitigation was identified. Compared to the proposed project, this alternative would further minimize potential impacts related to land use and planning. No land use and planning impact would occur under the No Project/ No Development Alternative.

Noise
Construction-related noise under the No Project/Existing Plan Alternative would be similar to the proposed project, since grading activities would still be required, and similar types of equipment would be used , however the duration of construction would be shorter under this alternative. Due to temporary rock drilling and blasting activities during construction, this alternative has the potential to create noise levels in excess of the City’s 75 dBA standard if rock drilling equipment is staged closer than 160 feet to an occupied noise sensitive land use (Impact N-1). Similarly, the No Project/Existing Plan Alternative would likely include a Conditional Use Permit to allow for the use of a temporary rock crusher, the use of which has the potential to create noise levels in excess of City standards, depending on the rock crusher’s location in relation to sensitive uses (Impact N-2). Additionally, since construction equipment would be the same as the proposed project, vibration resulting from that equipment would be similar.

The No Project/Existing Plan Alternative would generate operational noise from data center activities as well as vehicle trips generated by the project. Development under this alternative would generate fewer ADT than the proposed project (1 61 compared to 1,214). Therefore, offsite noise generation would be lower under this alternative than the proposed project. A large data center building would typically require larger heating, ventilation, and air conditioning (HVAC) equipment, which can result in more noise compared to predominantly residential buildings. However, HVAC equipment is typically shielded with rooftop parapets or other barriers which help to minimize noise. Since the No Project/ Existing Plan Alternative would not include residential uses, there would be no need for design features in the form of noise barriers to shield outdoor areas (balconies) from cumulative roadway and train noise like would be needed under the proposed project.

In summary, a s discussed in Section 3. 8, Noise, the proposed project’s construction noise impacts were determined to be mitigated to less than significant. This alternative would have a similar level of construction-related noise as the proposed project. Noise mitigation measures identified for the proposed project (mitigation measures MM -N-1 through MM -N-2) would be applicable to this alternative and would reduce the impacts to below a level of significance. The proposed project’ s operational noise impacts from ADT and operational noise such as HVAC equipment were found to be less than significant. While noise generated from project traffic under No Project/Existing Plan Alternative would be less than the proposed project, noise from operational uses, such as HVAC equipment would be higher. Similar to the proposed project, the No Project/Existing Plan Alternative would result in less than significant operational noise impacts. In summary, noise impacts would be mitigated to less than significant under the No Project/Existing Plan Alternative.

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Population and Housing
The No Project/Existing Plan Alternative would develop the site in a manner that is consistent with the City’s General Plan and would, therefore, have been considered in the City’s growth assumptions. The No Project/Existing Plan Alternative would not dire ctly increase the City’s population because no residential uses are included. As described in Section 3.9, Population and Housing, the proposed project would add an additional 512 people on site, but this was not considered a substantial impact to population growth in the area and a less than significant impact was identified. Unlike the proposed project, the No Project/Existing Plan Alternative would not create transit -oriented housing or market rate for rent housing, nor would it create affordable housing units on the project site, which is needed by the City to meet its Regional Housing Needs Allocation goals. However, because this alternative does not result in the addition of people on site, compared to the proposed project, population and housing impacts would be reduced . No population and housing impacts would occur under the No Project/No Development Alternative.

Public Services
Similar to the proposed project, the No Project/Existing Plan Alternative would result in an increase in demand for public services, due to the construction of a large data center. Specifically, this alternative would increase the demand for police and fire protection services over existing conditions. Residential uses are the primary driver for demand for park, library, and school services. Since no residences would be constructed under this alternative, there would be no increase in demand for school, par k, and library services. Development under this alternative would still be required to pay applicable PFF and school fees, though the school fees would be at a reduced rate compared to the proposed project, since no residential uses are proposed. As discus sed in Section 3.10, Public Services, the proposed project’s public services impacts were determined to be less than significant. Compared to the proposed project, this alternative would result in similar demand for fire and police services and decreased demand for park, library, and school services. Overall, impacts to public services would be less than significant.

Transportation
The No Project/Existing Plan Alternative would generate fewer ADT than the proposed project (161 compared to 1,214). With regard to VMT, based upon San Diego Association of Governments (SANDAG) screening maps, the regional mean VMT for employees is 27.2 VMT per employee. For the census tract where the project site is located, the VMT per employee would be 24.8, which is approximately 89.4% of the regional mean (SANDAG 2024). This means that mitigation would be required to reduce the VMT to 23.12, which woul d be 85% of the regional mean and below the VMT significance threshold. It is expected that a 4% reduction could be achieved through a mix of mitigation measures such as employer carpool/vanpool programs, employer transit subsidies, and telecommute/alternative work schedules. Even with these reductions, development under the No Project/Existing Plan Alternative would result in more VMT compared to the project. This alternative would have increased VMT impacts compared to the proposed project, and impacts would be less than significant with mitigation.

As discussed in Section 3.11, Transportation, the proposed project was determined to have no impact related to conflicts with any applicable plans or polices that address the circulation system, and a less than significant impact related to VMT because the project would not meet the threshold requiring a full VMT analysis. Similar to the proposed project, it is anticipated that this alternative would not have any impacts related to conflict with applicable plans and policies related to transportation. Furth er,

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compared to the proposed project, this alternative would generate fewer ADT but greater VMT. It is possible that additional reductions could be applied to reduce the No Project/Existing Plan Alternative’s VMT impacts to below a level of significance. Compared to the proposed project, this alternative would have a similar level of transportation impacts and fewer ADT. It is anticipated that transportation impacts would be mitigated to less than significant under the No Project/ Existing Plan Alternative.

Tribal Cultural Resources
The No Project/Existing Plan Alternative would have a similar footprint of disturbance as the proposed project. Therefore, construction of this alternative has the potential to cause a substantial adverse change to a tribal cultural resource that is eligible for inclusion in the California Register of Historical Resources. As discussed in Section 3.12, Tribal Cultural Resources, the proposed project’s impacts to tribal cultural resources were determined to be mitigated to less than significant. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM-TCR-1 through MM-TCR-9) and would reduce the impacts to below a level of significance. The No Project/Existing Plan Alternative w ould have a similar level of tribal cultural resources impacts as the proposed project.

Utilities and Service Systems
The No Project/Existing Plan Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service over existing conditions through the development of a 160,000 s.f. data center. Storm water infrastructure demands are anticipated to be similar to the proposed project as a similar amount of impervious surface would be created. VWD’s water/sewer technical memorandum ( Appendix S) noted that even though the City’s approved land use designation for the proposed project is Public/Institutional, the 2018 Master Plan based its ultimate water demand planning for the project site as Open Space. VWD’s memo indicates that water demand based on land uses assumed in the 2018 Master Plan would be 36,172 gallons per day (GPD) less than the proposed project (488 GPD compared to 36,660 GPD ).

VWD’s memo also identified that the sewer demand based on land uses assumed in the 2018 Master Plan would be 32,628 GPD (0 GPD compared to 32,628 GPD) less than the proposed project.

However, a large data center would have greater water and sewer demand than open space.

Nonetheless, it is expected that the demand for water and sewer services would be decreased under No Project/ Existing Plan Alternative compared to the proposed project. Additionally, the water and sewer line upgrades identified for the proposed project in the VWD memo may also be required for this alternative.

Using CalRecycle Estimated Solid Waste Generation Rates, the No Project/ Existing Plan Alternative would generate approximately 800 pounds or 0.4 tons per day (5 pounds/1,000 s.f./day), which is 1,476 pounds fewer than the 2,276 pounds (1.14 tons) anticipated for the proposed project.

As discussed under Greenhouse Gas Emissions and Energy sections above, natural gas demand would be reduced to zero under this alternative, but electricity demand would be significantly higher than the proposed project. This alternative would require at least 257,600 MW H of electricity annually, which is 285 times more electricity than would be required for the proposed project (907 MWH). Even with the provision of required (per City’s Climate Action Plan) solar -generated electricity, the solar would provide less than one percent of the total needed electricity requirement. Therefore, this alternative would have substantially higher demand for electricity from SDG&E than the proposed project would.

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As discussed in Section 3.13, Utilities and Service Systems, the proposed project’s impacts related to utilities and services systems were determined to be less than significant. Compared to the proposed project, impacts on utilities and services would be reduced, with the exception of electricity . Utilities and service system impacts would be less than significant under the No Project/No Development Alternative.

Conclusion
The No Project/Existing Plan Alternative would result in fewer ADT but would require 285 times more electricity than the proposed project which results in a corresponding proportional increase in air pollutant and GHG emissions.

Footprint-specific impacts, such as those related to biological resources, cultural , and tribal cultural resources, would be similar as the proposed project, as the same amount of site area would be disturbed.

This alternative would not generate any students for SMUSD and would reduce demand for parks, libraries, natural gas, solid waste, water, and sewer services compared to the proposed project. This alternative would result in a VMT impact and would require m itigation to reduce VMT to 85% of the regional mean for employees. It should be noted that the project site was sold by AT&T after they determined it was not necessary for their infrastructure operations, and no other utility companies purchased the proper ty for development of their own infrastructure under the existing designation Finally, this alternative does not meet any of the project objectives, as shown in Table 4-1.

4.2.5 Reduced Development Footprint Alternative
Under the Reduced Development Footprint Alternative, the project site would be developed with 14 live/work rowhomes and associated infrastructure. The units would be three stories high and would be a for-sale product. No affordable housing would be proposed under this alternative. Two-car garages would be included on the ground level of each unit and five additional open parking spaces would be provided for a total of 33 space s. This alternative would have a density of 5.83 du/acre and would include seven 3 bed/2.5 bath units (1,600 s.f.) and seven 4 bed/2.5 bath units (1,800 s.f.). Access would be via Armorlite Drive and a drive aisle adjacent to the western project boundary would provide access to some of the townhomes. Private and common open space would be provided consistent with the City’s Outdoor Space Standards (Section 20.255.120 of the San Marcos Municipal Code).

Architectural treatments would be incorporated into the design of this alternative to provide for visual interest and to break up the bulk and scale of the development.

Overall, the development footprint and area of disturbance would be reduced compared to the proposed project, as only 41% of the project site would be disturbed. This results in a corresponding decrease in the amount of grading that would be required for the project.

4.3.5.1 Comparison of the Effects of the Reduced Development Footprint Alternative to the Proposed Project
Aesthetics
Development under the Reduced Development Footprint Alternative would include 14 three-story live/work rowhomes occupying 41% of the project site. Compared to the proposed project, there would be less overall development intensity on the project site and rather than one five-story building, there would be 14 three-story live/work rowhomes. Additionally, 1.4 acres of the site would remain

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undeveloped. Similar to the proposed project, architectural treatments would be incorporated into the design of this alternative to provide for visual interest and to break up the bulk and scale of the development. Additionally, this alternative would inco rporate lighting for safety, security and way finding. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. As with the pro posed project, a landscape concept plan would also be implemented. As discussed in Section 3.1, Aesthetics, the proposed project’s aesthetics impacts were determined to be less than significant. Compared to the proposed project, this alternative would have a reduced level of aesthetics impacts. Aesthetics impacts would be less than significant under the Reduced Development Footprint Alternative.

Air Quality
Under the Reduced Development Footprint Alternative, air pollutant emissions associated with construction, including emissions associated with grading, site preparation, site finishing and building finishing would still occur . However, due to the reduced footprint of disturbance, construction emissions would be reduced compared to the proposed project.

Operational emissions under this alternative would also be reduced compared to the proposed project as fewer residential units would be constructed (14 units compared to 165 units). Emissions from vehicles going to and from the project site typically account for the largest portion of operational air quality emissions. It is anticipated that this alternative could generate approximately 112 ADT, which is 1, 102 fewer ADT than the proposed project ’s 1,214 trips, representing an approximate 90% reduction in ADT. As such, because this alternative would result in a decrease of development intensity and associated ADT, operational air pollutant emissions would be reduced when compared to the proposed project. Because residential uses would still be proposed, the low potential for sources of odor would be the same as the proposed project.

In summary, as discussed in Section 3.2, Air Quality, construction, and operation emissions were determined to be less than significant for the proposed project. The potential for odor impacts was also found to be less than significant. Compared to the pro posed project, impacts related to odor for the Reduced Development Footprint Alternative are anticipated to be similar and would be less than significant. The Reduced Development Footprint Alternative would generate reduced levels of construction emissions , due to the smaller footprint, and operation emissions due to the lesser development intensity. Air Quality impacts would be less than significant under the Reduced Development Footprint Alternative.

Biological Resources
The Reduced Development Footprint Alternative would occupy only 41% of the project site leaving 1.4 acres of the site undisturbed, including a large portion of the Diegan coastal sage scrub vegetation community and all of the non-native grassland vegetation community. Similar to the proposed project, this alternative would also result in the potential for impacts to nesting birds (Impact BIO-1), to Diegan coastal sage scrub (Impact BIO-3), and indirect impacts to sensitive species (Impact BIO-2). However, this alternative would avoid impacts to 0.12 acres of non -native grassland. As discussed in Section

3.3, Biological Resources, the proposed project’s impacts on biological resources were determined to be mitigated to less than significant. Biological resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measure MM-BIO-1, the portion of MM-BIO-3 related to Diegan coastal sage scrub , and MM -BIO2a – MM-BIO-2c) and would reduce impacts to below a level of significance. Compared to the proposed project, this alternative would have

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a reduced level of impact. Biological resources impacts would be mitigated to less than significant under the Reduced Development Footprint Alternative.

Cultural Resources
The Reduced Development Footprint Alternative would occupy only 41% of the project site leaving 1.4 acres of the site undisturbed. Similar to the proposed project, the potential to impact unknown archaeological resources potentially located within the proj ect site (Impact CR -1) as well as unidentified human remains (Impact CR -2) would still occur under this alternative. However, due to the smaller footprint of disturbance, the potential for discovery is reduced. As discussed in Section

3.4, Cultural Resources, the proposed project’s impacts to cultural resources were determined to be mitigated to less than significant. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM-CR-1 through MM-CR-4) and would reduce the impacts to below a level of significance. Compared to the proposed project , this alternative would have a reduced level of impact. Cultural resources impacts would be mitigated to less than significant under the Reduced Development Footprint Alternative.