Energy
Construction of the Reduced Development Footprint Alternative would require energy; however, due to the reduced footprint of disturbance, energy use during construction would be reduced compared to the proposed project. Electricity and natural gas required during operation of this alternative would also be reduced compared to the proposed project as fewer residential units would be constructed (14 units compared to 165 units). Petroleum use would be decreased as this alternative w ould 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 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 electricity, natural gas, and petroleum would be used under this alternative, so energy impacts would be reduced. Energy impacts would be less than significant under the Reduced Development Footprint Alternative.
Greenhouse Gas Emissions
Under the Reduced Development Footprint Alternative, GHG emissions associated with project construction would still occur but would be reduced compared to the proposed project due to the reduced footprint of disturbance. Operational GHG emissions under this alternative would also be reduced compared to the proposed project as fewer residential units (14 units compared to 165 units).
In particular, GHG emissions associated with vehicular trips under the Reduced Development Footprint Alternative would be lowe r than the proposed project. 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, operations-related GHG emissions would be reduced when compared to the proposed project.
As discussed in Section 3.6, Greenhouse Gas Emissions, construction and operational GHG emissions were determined to be less than significant for the proposed project. Compared to the proposed project, the Reduced Development Footprint Alternative would generate reduced levels of construction emissions, due to the smaller footprint, and reduced levels of operational emissions due to the smaller
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development intensity. GHG impacts would be less than significant under the Reduced Development Footprint Alternative.
Land Use and Planning
Under the Reduced Development Footprint Alternative, a Specific Plan, General Plan Amendment and Rezone would still be required. Development under this alternative would generate fewer ADT than the proposed project (112 compared to 1,214). Similar to the p roposed 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 (Conges tion 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. Land use and planning impacts would be similar to the proposed project under Reduced Development Footprint Alternative and would be less than significant.
Noise
Construction-related noise under the Reduced Development Footprint Alternative is expected to result in a similar maximum level of noise and vibration levels as the proposed project, since grading activities would still be required, and similar types of equipment would be used. However, construction may be of a shorter duration since less development and a smaller footprint is proposed. Construction would also occur further from the sensitive land uses to the east of the site but still close to the sensitive receptors to the south. As with the proposed project, 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 Reduced Development Footprint Alternative may include a conditional use permit to allow for the use of a temporary rock crusher, the use of which has the p otential to create noise levels in excess of City standards, depending on the rock crusher’s location in relation to sensitive uses (Impact N-2).
The Reduced Development Footprint Alternative would generate operational noise from 14 live/work row homes as well as vehicle trips generated by the project. Development under this alternative would generate fewer ADT than the proposed project (11 2 compared to 1,214). Therefore, offsite noise generation would be lower under this alternative than the proposed project. Operational noise from the rowhomes would be similar in type to the proposed project, but there would be substantially fewer units (14 compared to 165). Since this alternative proposes two row homes in the northwest corner of the site with direct line of site to Mission Road and Las Posas Road, a similar design feature in the form of noise barriers to shield outdoor areas (balconies) from cumulative roadway and train noise would be needed, similar to the proposed project.
As discussed in Section 3. 8, Noise, the proposed project’s construction noise impacts were determined to be mitigated to less than significant . Construction-related noise under the Reduced Development Footprint Alternative is expected to result in a similar maximum level of noise and vibration levels 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. This Since this alternative would result in a decrease of development intensity and associated ADT compared to the proposed project, operations-related noise would be reduced when compared to the
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proposed project. Noise impacts would be mitigated to less than significant under the No Project/Existing Plan Alternative.
Population and Housing
The Reduced Development Footprint Alternative would result in an increase in the population of the City by approximately 44 residents, whereas the proposed project would increase the population by approximately 512 residents (3.1 persons per dwelling unit). As described in Section 3.9, Population and Housing, the proposed project’s population increase would not be considered a substantial impact to population growth in the area and a less than significant impact was identified. Unlike the proposed project, the Reduced Development Footprint Alternative would not create as much 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 Need s Allocation goals. However, because this alternative results in the addition of fewer people on site, compared to the proposed project, population and housing impacts would be reduced. A less than significant impact related to population and housing would occur under the Reduced Development Footprint Alternative.
Public Services
Similar to the proposed project, the Reduced Development Footprint Alternative would result in an increase in demand for public services due to the construction of residential uses on the project site.
Specifically, this alternative would increase the demand for pol ice and fire protection, school, park, and library services over existing conditions. Development under this alternative would still be required to pay applicable PFF and school fees, which would help offset demand for public services. Compared to the proposed project, fewer residents (44 compared to 512) and fewer students (5 compared to 39) would be generated since fewer residential units (14 compared to 165) would be constructed, and demand for public services would be reduced. As discussed 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 decreased demand for public services. Impacts to public services would be less than significant under the Reduced Development Footprint Alternative.
Transportation
The Reduced Development Footprint Alternative would generate fewer ADT than the proposed project (112 compared to 1,214). Similar to the proposed project, development under this scenario would screen out of a VMT assessment through the use of SANDAG maps. As discussed in Section 3.11, Transportation, the project site is located within a census tract with a resident VMT of 12.5 VMT/Capita, which is 66% of the regional average and below the VMT significance threshold.
Compared to the proposed project, this alternative would generate fewer VMT overall, since fewer units would be constructed.
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 . Because this alternative would generate fewer ADT and less VMT, transportation impacts would be reduced. There would be no impact associated with consistency with policies in the Mobility Element of the General Plan that addresses LOS and a less than significant impact related to VMT under the Reduced Development Footprint Alternative.
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Tribal 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, there would still be a potential for construction activities to cause a substantial adverse change to a tribal cultural resource that is eligible for inclusion in the California Register of Historical Resources (Impact TCR -1). However, due to the smaller footprint of disturbance, the potential for discovery is reduced. Mitigation measures MM-TCR- 1 through MM-TCR-9 would still be required to be implemented. Compared to the proposed project, this alternative would reduce the potential for tribal cultural resources impacts.
Utilities and Service Systems
The Reduced Development Footprint Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service through the development of 14 live/work row homes. However, compared to the project, this alternative would decrease the overall demand since fewer residences (14 compared to 165) would be constructed. Development under this alternative would still be required to pay all applicable water and sewer fees. and he sewer and water line upgrades identified for the project may also be applicable to this alternative. Storm water infrastructure demand may also be reduced as less impervious surface area would be created due to the reduced footprint of disturbance. Using CalRecycle Estimated Solid Waste Generation Rates (12.23 pounds per household) , the Reduced Development Footprint Alternative would generate approximately 171 pounds (0.09 tons) per day, which is 2,105 pounds fewer than the 2,276 pounds anticipated for the proposed project.
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. Utilities and service system impacts would be less than significant under the Reduced Development Footprint Alternative.
Conclusion
The Reduced Development Footprint Alternative would reduce the number of residential units constructed on the project site (14 compared to 165). This results in a corresponding decrease in vehicular trips by approximately 90% and a corresponding decrease in air pollutant emissions, GHG emissions and noise from offsite traffic compared to the proposed project. Public services, utilities and service systems, and energy demands would also be pr oportionally decreased. Footprint specific impacts, such as those related to biological resources, cultural resources, and tribal cultural resources, would also be reduced as this alternative would only impact 41 % of the project site. This alternative would contribute less PFF and school fees since fewer residential units would be constructed. As detailed in Table 4-1, this alternative would meet one of the project objectives, and partially meet one objective, though could be designed in a manner that would meet or partially meet six more objectives.
4.2.6 Reduced Intensity Alternative
Under the Reduced Intensity Alternative, the project site would be developed under a Specific Plan with 80 residential apartments and 5,600 s.f. of commercial use for a density of approximately 32 du/acre. The project proposes a density of 67 du/acre. A General Plan Amendment and Rezone would be required for this alternative to change the site from PI (Public Institutional) to Specific Plan. Overall, the development footprint and area of disturbance would be similar to that of the proposed project, but with less density of residential units. The building would range from two to three stories high,
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depending on how large the units would be. 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.
4.3.5.1 Comparison of the Effects of the Reduced Intensity Alternative to the Proposed Project Aesthetics
Development under the Reduced Intensity Alternative would include 80 residential units and 5,600 s.f. of commercial use. Compared to the proposed project, there would be less overall development intensity on the project site, and the overall building height would be reduced. 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. Similar to the proposed project, this alternative would incorporate 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. The Reduced Intensity Alternative would have a similar level of aesthetics impacts as the proposed project and impacts would be less than significant. Similar to the proposed project, PRC 21099(d) would be applicable and aesthetics impacts would not be considered a significant environmental impact.
Air Quality
Under the Reduced Intensity Alternative, air pollutant emissions associated with construction including emissions associated with grading, site preparation, site finishing and building finishing would still occur and would be reduced compared to the proposed project due to the reduced development.
Operational emissions under this alternative would also be reduced compared to the proposed project as fewer residential units would be constructed. Vehicular trips under the Reduced Intensity Alternative would be lower than the proposed project. This alternative would generate 704 ADT. Compared to the proposed project, which would generate 1,214 ADT, this alternative would reduce ADT by 42%. 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 and impacts would be less than significant.
Biological Resources
The Reduced Intensity Alternative would have a similar level of biological resources impacts as the proposed project, since it would have a similar footprint of disturbance. This includes the potential for impact bird species protected by the Migratory Bir d Treaty Act, impact to Diegan coastal sage scrub, non-native grassland, and the potential for indirect impact to sensitive species. Biological resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM-BIO-1 through MM-BIO-3) and would reduce the potential impact to below a level of significance. The Reduced Intensity Alternative would have a similar level of biological resources impacts as the proposed project, and impacts would be less than significant with mitigation.
Cultural Resources
The Reduced Intensity 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
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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 Reduced Intensity Alternative would have a similar level of cultural resources impact as the proposed project.
Greenhouse Gas Emissions
Under the Reduced Intensity Alternative, GHG emissions associated with project construction would be reduced compared to the proposed project due to the reduced density and construction activities required. Operational GHG emissions under this alternative would also be reduced due to the reduction in residential units. In particular, GHG emissions associated with vehicular trips under the Reduced Intensity Alternative would be lower than the proposed project. This alternative would generate 704 ADT. Compared to the proposed project, which generates 1,214 ADT, this alternative would reduce ADT by 42%. As such, because this alternative would result in a decrease of ADT, vehicular-related GHG would be reduced when compared to the proposed project. GHG emissions would be reduced compared to the proposed project, and impacts would be less than significant.
Land Use and Planning
Under the Reduced Intensity Alternative, a Specific Plan, General Plan Amendment and Rezone would still be required. This alternative would generate 704 ADT. Compared to the proposed project, which generates 1,214 ADT, this alternative would reduce ADT by 42%. The proposed project did not require any improvements to maintain adequate LOS on area roadways and intersections. Since the Reduced Intensity Alternative would generate less ADT, a similar conclusion would be made for this alternative and there would be no inconsistencies with the Mobility Element of the General Plan. The proposed project would also be consistent with the other applicable policies and goals of the General Plan, as it would include similar uses and features as the proposed project. This alternative would have a similar level of land use and planning impact as the proposed project and impacts would be less than significant.
Noise
Construction-related noise under the Reduced Intensity 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 reduced since the building would be smaller. Therefore, due to temporary rock drilling and blasting activities during construction, this alternative has the potential to create noise levels in excess of the C ity’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 Reduced Intensity 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 n oise 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
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fewer ADT than the proposed project ( 704 compared to 1,214). Therefore, offsite noise generation would be lower under this alternative than 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. 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. Ope rational noise under this alternative would be reduced compared to the proposed project. Similar to the proposed project, the Reduced Intensity Alternative would result in less than significant operational noise impacts. In summary, noise impacts would be mitigated to less than significant under the Reduced Intensity Alternative.
Population and Housing
The Reduced Intensity Alternative would result in an increase in the population of the City by approximately 248 residents, whereas the proposed project would increase the population by approximately 512 residents. However, increased population associated with the pro posed project was determined to be less than significant. Compared to the proposed project, this alternative would have a reduced level of impact related to unplanned population growth and impacts would be less than significant.
Public Services
Similar to the proposed project, the Reduced Intensity Alternative would result in an increase in demand for public services due to the construction of residential uses on the project site. Specifically, this alternative would increase the demand for police and fire protection, school, park, and library services over existing conditions. Compared to the proposed project, fewer residents and students would be generated since fewer residential units would be constructed, and demand for public services would b e reduced. Development under this alternative would still be required to pay applicable PFF and school fees, which would help offset demand for public services. Similar to the proposed project, impacts would be less than significant.
Transportation
Under the Reduced Intensity Alternative, no impact associated with consistency with policies in the Mobility Element of the General Plan that address LOS is expected. Development under this scenario would screen out of a VMT assessment through the use of SANDAG maps. As discussed in Section
3.11, Transportation, the project site is located within a census tract with a resident VMT of 12.5 VMT/Capita, which is 66.1% of t he regional average and below the VMT significance threshold .
Compared to the proposed project, this alternative would generate less VMT overall, since fewer units would be constructed, and impacts would be less than significant.
Tribal Cultural Resources
The Reduced Intensity 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
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(mitigation measures MM-TCR-1 through MM-TCR-9) and would reduce the impacts to below a level of significance. The Reduced Intensity Alternative would have a similar level of tribal cultural resources impacts as the proposed project.
Utilities and Service Systems
The Reduced Intensity Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service through the development of 80 residential units and 5,600 s.f. of commercial. However, compared to the project, this alternative would decrease the overall demand since fewer residences would be constructed.
Development under this alternative would still be required to pay all applicable water and sewer fees and the sewer a nd water line upgrades identified for the project may also be applicable to this alternative. Storm water infrastructure demand is anticipated to be similar to the proposed project as a similar amount of impervious surface would be created. Solid waste generated would be reduced under this alternative. Utilities a nd service system impacts would be less than significant under the Reduced Intensity Alternative, and would be reduced compared to the proposed project.
Conclusion
The Reduced Intensity Alternative would reduce the number of residential units constructed on the project site. This results in a corresponding decrease in vehicular trips by approximately 42% and a corresponding decrease in air pollutant and GHG emissions and noise from offsite traffic compared to the proposed project. Public services, utilities and service systems, and energy demands would also be proportionally decreased. Footprint-specific impacts, such as those related to biological resources, cultural and tribal cultural resources, would be similar as the proposed project since a similar area of disturbance would occur under this alternative. This alternative would contribute less PFF and school fees since fewer residential units would be constructed. This alternative would meet the majority of the project objectives as detailed in Table 4-1.
4.3 Alternatives Considered But Rejected
CEQA Guidelines Section 15126.6(c) provides guidance in selecting a range of reasonable alternatives for the project. An EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. CEQA Guidelines Section 15126.6(c) provides the following guidance in selecting a range of reasonable alternatives for the project. There are many factors that may be taken into account when addressing the feasibility of range of potential alternatives for the project, such as site suitability, economic viability, availability of infrastructure, general plan consistency, othe r plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by the proponent). The alternatives discussion shall include those that could feasibly accomplish most of the basic obje ctives of the project and could avoid or substantially lessen one or more of the significant effects. An EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency's determination.
The EIR need not discuss every alternative to the project. A range of alternatives that are “reasonable” for analysis have been evaluated and are discussed above in Section 4.3, Project Alternatives
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Considered in this EIR. The following describes other alternatives considered by the City but dismissed from further evaluation in this EIR, and a brief description of the reasons for their rejection.
4.3.1 Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations to the project. There are sites within the city of an approximately equivalent size to the project site that could be redeveloped with a residential project; however, the project applicant does not control another site within the city of comparable land area that is available for development of the proposed project. One of the factors for feasibility of an alternative is “whether the propone nt can reasonably acquire, control or otherwise have access to the alternative site.” Because the city is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is not considered feasible. It should also be noted that the project site is surrounded by development and located adjacent to an established transportation network, existing transit (SPRINTER and Palomar College Transit Center) and utility infrastructure. As such, an alternative location was ultimately rejected from further analysis in the EIR.
4.4 Environmentally Superior Alternative
Table 4 -2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project. As shown in Tables 4-1 and 4-2, the No Project/No Development Alternative would eliminate all of the potentially significant impacts identified for the project. However, the No Project/No Development Alternative would not meet any of the project objectives. Additionally, there is no certainty that the project site would remain undeveloped in perpetuity. CEQA Guidelines Section 15126.6(e)(2) states that i f the No Project alternative is identified as the environmentally superior alternative, then an environmentally superior alternative should be identified among the other alternatives.
Among the other alternatives, not including the proposed project, the Reduced Development Footprint Alternative is the environmentally superior alternative because it would provide a reduced level of impact in some environmental analysis areas including air quality, cultural resources, GHG, noise, public services, recreation, tribal cultural resources, and utilities/service systems. Mitigation measures would still be required to mitigate impacts to biological resources, cultural resources, noise, tribal cultural resources.
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Table 4-1. Summary of Alternatives and Project Objectives Objective Proposed Project No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Development
Footprint
Alternative
Reduced Intensity
Alternative
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.
Meets objective Does not meet
this objective
Does not meet
this objective
Partially meets
objective
Partially meets
this objective
To the extent possible, given site constraints,
maximize the opportunity to provide transit-
oriented housing for the City of San Marcos up to
67.6 dwelling units per acre.
Meets objective Does not meet
this objective
Does not meet
this objective
Partially meets
this objective
Partially meets
this objective
Develop high-quality market-rate for rent housing
which meets the housing needs of the City of
San Marcos and the region.
Meets objective Does not meet
this objective
Does not meet
this objective
Does not meet
this objective Meets objective
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)
through development onsite.
Meets objective Does not meet
this objective
Does not meet
this objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Facilitate connections to the Armorlite Drive
complete street circulation system and provide
pedestrian friendly architecture and landscaping
to promote walkability and connectivity for
people to surrounding transit and places.
Meets objective Does not meet
this objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be designed
in a manner that
meets this
objective
Design a vehicular circulation system that
adequately accommodates traffic and minimizes
traffic impacts in and around the project area.
Meets objective Does not meet
this objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be designed
in a manner that
meets this
objective
Establish development standards and design
guidelines that ensure distinctive architecture, Meets objective Does not meet this objective
Does not meet
this objective
Could be designed
in a manner that
Could be designed
in a manner that
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Objective Proposed Project No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Development
Footprint
Alternative
Reduced Intensity
Alternative
landscaping and recreational amenities that
complements and enhances the existing
surrounding neighborhood while providing a
desirable living environment for residents within
the Specific Plan area.
meets this
objective
meets this
objective
Provide flexible “flex” Commercial space to
support residents of the Specific Plan Area that
is also capable of adapting to future market
conditions and designed to support potential
future retail needs.
Meets objective Does not meet
this objective
Does not meet
this objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Institute a program for the long-term
maintenance of the community to ensure all
facilities are adequately maintained to City
standards.
Meets objective Does not meet
this objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be designed
in a manner that
meets this
objective
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.
Meets objective Does not meet
this objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be designed
in a manner that
meets this
objective
4.0 Alternatives
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Table 4-2. Comparison of Impacts of Proposed Project and Alternatives Environmental
Topic Proposed Project No Project/No
Development Alternative
No Project/Existing Plan
Alternative
Reduced Development
Footprint Alternative
Reduced Intensity
Alternative
Aesthetics LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Reduced)
LTS
(Same)
Air Quality LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
LTS
(Reduced)
Biological
Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Reduced)
LTSM
(Same)
Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Reduced)
LTSM
(Same)
Energy LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
LTS
(Reduced)
Greenhouse Gas
Emissions LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
LTS
(Reduced)
Land Use and
Planning LTS No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Noise LTSM No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Population and
Housing LTS No Impact
(Reduced)
No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Public Services LTS No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Transportation LTS No Impact
(Reduced)
LTSM
(Increased)
LTS
(Reduced)
LTS
(Reduced)
Tribal Cultural
Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Reduced)
LTSM
(Same)
Utilities and
Service Systems LTS No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Notes: Impact Status: LTS = Less than significant impact; LTSM = Less than significant with mitigation
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5.0 Environmental Effects Found not to be Significant
The City of San Marcos completed an Initial Study (IS) for the proposed project in accordance with Sections 21000-21189 of the Public Resources Code and Section 15063 of the California Environmental Quality Act (CEQA) Guidelines. A Notice of Preparation (N OP) was prepared by the City and mailed to applicable agencies, organizations, and neighboring property owners. The NOP is included in Appendix B.2 of this Environmental Impact Report (EIR). 23 As required by Section 15128 of the CEQA Guidelines, the following is a discussion of the environmental effects that were considered as a part of the IS but were determined to have “No Impact” or a “Less Than Significant Impact,” and, therefore, are not discussed in detail in this EIR.
In some i nstances, complete environmental issue areas were eliminated during the IS process, including agriculture/forestry resources, geology and soils, hazards/hazardous materials, hydrology and water quality, mineral resources, recreation, and wildfire. In other instances, some of the specific CEQA thresholds were eliminated during the IS process including aesthetics (scenic vistas, scenic resources within a state scenic highway), biological resources (federally protected wetlands, wildlife movement), land use and planning (physically divide an established community), noise (project vicinity to private airports or within and airport land use plan), population and housing (Displacement of existing housing or people), public services (parks), and transportation (hazardous design features).
5.0 Aesthetics
Threshold of Significance: Have a substantial adverse impact on a scenic vista.
The project site is located within the Business/Industrial District in the c ity. The City has a Ridgeline Protection and Management Overlay Zone to protect natural viewsheds and unique natural resources, minimize physical impacts to ridgelines, and to establish innovative sensitive architecture standards.
The project site is not located in the Ridgeline Protection and Management Overlay Zone. Further, the project site does not include any primary or secondary ridgelines, as identified in Figure 4 -5 of the Conservation and Open Space Element of the General Plan ( City of San Marcos 2012). Therefore, development of the project site would not have a substantial adverse effect on a scenic vista and no impact would occur.
Threshold of Significance: Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway.
The project site is located approximately 0.25 miles north of SR -78. A portion of SR-78 is recognized as a Scenic Highway by the California Department of Transportation (Caltrans); however, that portion is not in the project vicinity. The portion identified as a Scenic Highway is approximately 50 miles east of the project site near Anza Borrego (Caltrans 2019). At a local level, SR-78 is designated by the City of San Marcos as a view corridor. The highway corridor provides views of the Merriam Mountains, Mount Whitney in San Diego County, and Double Peak. There are no scenic resources on the project site. The project site is undeveloped and does not support any historic buildings (ASM 202 4). In
23 The Initial Study, NOP, and comment letters received on the NOP are included in Appendi ces B.1, B.2 and B.3 of this EIR.
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summary, the project would not damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. No impact would occur.
A discussion of additional aesthetics significance thresholds is provided in Section 3.1, Aesthetics.
5.1 Agriculture and Forestry Resources
Threshold of Significance : Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use.
The project site is not mapped as prime farmland, unique farmland, or farmland of statewide importance, as determined by the Farmland Mapping and Monitoring Program and as shown on Figure 4-4 (Agricultural Areas) in the San Marcos General Plan (San Marcos 2012). Therefore, the project would not result in the conversion of prime farmland, unique farmland, or farmland of statewide importance. No impact is identified for this issue area.
Threshold of Significance : Conflict with existing zoning for agricultural use, or a Williamson Act contract.
The project site has a General Plan designation of Public/Institutional (PI) and a zoning designation of Public-Institutional (P-I). The project site does not support zoning for agricultural use. The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space use. In return, landowners receive property tax assessments which are much lower than normal because they are based upon farming and open space uses as opposed to full market value. The project site is not located within a Williamson Act contract area. Therefore, the project would not conflict with existing zoning for agricultural use or a Williamson Act contract. No impact is identified.
Threshold of Significance: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)).
The project site has a General Plan designation of Public/Institutional (PI) and a zoning designation of Public-Institutional (P-I). The proposed project is not located in an area that is zoned for forest land, timber land or for timber production nor is it adjacent to lands that are zoned forest land, timber land or for timber production. Implementation of the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned timberland producti on. No impact is identified.
Threshold of Significance: Result in the loss of forest land or conversation of forest land to non-forest use.
The project site is undeveloped and does not support forests, nor is there any forest land adjacent to the project site. Therefore, the proposed project would not result in the loss of forest land or the conversion of forest land to non‐forest use. No impact is identified.
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Threshold of Significance: Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.
The project would not result in any other changes to the existing environment that would, due to their location or nature, result in the conversion of Farmland to non‐agricultural use or conversion of forest land to non‐forest use. There is no agricultural activity or forest land on the project site. No impact is identified.
5.2 Biological Resources
Threshold of Significance: Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
A project-specific biological resources report was prepared for the project (Dudek 2025 2024) and is included as Appendix D . No aquatic resources are present within the project site. San Diego fairy shrimp critical habitat, designated in 2007, encompasses nearly the entire project site. However, as discussed in the biology report ( Dudek 2025 2024), field study observations in 2023 show that the site does not support suitable ponding or vernal pool habitat for fairy shrimp. No impacts would occur.
Threshold of Significance: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Wildlife corridors are linear features that connect large patches of natural open space and provide avenues for the migration of animals. Wildlife corridors contribute to population viability by ensuring continual exchange of genes between populations, providing access to adjacent habitat areas for foraging and mating, and providing routes for recolonization of habitat after local extirpation or ecological catastrophes (e.g., fires).
Habitat linkages are small patches that join larger blocks of habitat and help reduce the adverse effects of habitat fragmentation. Habitat linkages provide a potential route for gene flow and long-term dispersal of plants and animals. They may also serve as primary habitat for smaller animals, such as reptiles and amphibians. Habitat linkages may be continuous habitat or discrete habitat islands that function as steppingstones for dispersal. To function effectively, a wildlife corridor must link two or more patches of habitat for which connectivity is d esired, and it must be suitable for the focal target species to achieve the desired demographic and genetic exchange between populations.
The project site is a predominantly undeveloped parcel surrounded by existing, high-density residential and mixed commercial development that likely does not provide large-scale regional wildlife movement or habitat connectivity value, but may provide small-scale, local value for small mammals, reptiles, and mesocarnivores. In addition, birds (especially those protected by the Migratory Bird Treaty Act that are using the Pacific Flyway) and bats may use the site as foraging habitat.
The project site is also fenced on all sides (with chain -linked fencing on three sides and open cable railing on a single side) which would preclude its use in facilitating large wildlife movement through the urban landscape. In addition, the site is not located within a Biological Core Linkage Area or Focused Planning Area under the Draft San Marcos Subarea Plan. As such, the isolated project site is
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not expected to provide for wildlife movement or serve as an important habitat linkage for wildlife traversing the region. Impacts would be less than significant.
A discussion of additional biological resources significance thresholds is provided in Section 3.3, Biological Resources.
5.3 Geology and Soils
A preliminary Geotechnical Evaluation was conducted, and report prepared by GeoTek in August 2023 (GeoTek 2023b). This report assessed the potential for the project to cause geotechnical related hazards and is included as Appendix H.
Threshold of Significance: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
The project site is located in the tectonically active Southern California area and would likely experience shaking effects from earthquakes. The type and severity of seismic hazards affecting the site are to a large degree dependent upon the distance to the causativ e fault, the intensity of the seismic event, and the underlying soil characteristics. Based upon the preliminary geotechnical report prepared for the project, no known active faults have been mapped at or near the project site (GeoTek 2023b). Therefore, the potential for surface rupture on the project site is low and a less than significant impact is identified.
Threshold of Significance: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Strong seismic ground shaking? Because the proposed project would be located in tectonically active Southern California, the project would be required to comply with the California Building Code, including recommendations for seismic safety. Impacts would be less than significant.
Threshold of Significance: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: seismic-related ground failure, including liquefaction? Liquefaction occurs when loose, saturated, generally fine sands and silts are subjected to strong ground shaking. The soils lose shear strength and become liquid; potentially resulting in large total and differential ground surface settlements as well as possible lateral spreading during an earthquake. Seismically induced settlement can occur in response to liquefaction of saturated loose granular soils, as well as the reorientation of soil particles during strong shaking of loose, unsaturated sands.
Based upon the geotechnical investigation for the project (GeoTek 2023 b), the liquefaction and seismic settlement potential on the project site is considered to be negligible due to the anticipated medium dense consistency and thickness of less than 10 feet of anticipated fills, shallow bedrock, and the absence of a shallow groundwater table. Therefore, impacts would be less than significant.
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Threshold of Significance : Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: landslides? 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. The project site is identified as having zero susceptibility for soil slip, surficial landslides, or liquefaction per Figure 6-1 of the Safety Element of the City’s General Plan (San Marcos 2012). Additionally, the geotechnical investigation for the project did not find evidence of ancient landslides or slope instability on the site. Thus, the potential for landslides is considered negligible (GeoTek 2023 b). Therefore, impacts would be less than significant.
Threshold of Significance: Result in substantial erosion or the loss of topsoil? The project would be under the State Water Resources Control Board (SWRCB) General Construction Permit, which prohibits sediment or pollutant release from the project site and requires preparation of a Stormwater Pollution Prevention Plan (SWPPP) and implementation of best management practices (BMPs) that would incorporate erosion and sediment control measures during and after grading operations to stabilize these areas. The project would not result in substantial soil erosion or the loss of topsoil. Therefore, impacts would be less than significant.
Threshold of Significance: Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Based upon the geotechnical report prepared for the project (GeoTek 2023 b), evidence of ancient landslides or slope instabilities at th e project site was not observed during the geotechnical investigation. Thus, the potential for landslides is considered negligible (GeoTek 2023b). Also, the project site is identified as having z ero susceptibility for soil slip, surficial landslides, or liquefaction per Figure 6 -1 of the Safety Element of the City’s General Plan (San Marcos 2012). Finally, the proposed project would incorporate techniques and recommendations from the geotechnical report (GeoTek 2023b) that would minimize the potential for unstable conditions that could result in on - or off-site, landslide, lateral spread, subsidence, liquefaction, or collapse. Therefore, i mpacts would be less than significant.
Threshold of Significance: Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Based upon the geotechnical report prepared for the project site, the surficial soils consist of colluvium and alluvium (undifferentiated) and tonalite (granitic) bedrock . Based upon GeoTek’s visual classification encountered onsite and the laboratory testing, soils near subgrade would be classified as “very low” expansive. The geotechnical report (GeoTek 2023b) includes design considerations in Section 5.3 which would be implemented as part of the project’s conditions of approval. Therefore, impacts would be less than significant.
Threshold of Significance: Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of wastewater.
Septic tanks and alternative wastewater disposal systems are not proposed as part of the project. The project would receive wastewater service from Vallecitos Water District (VWD) and would connect to
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existing sewer infrastructure in Armorlite Drive. Therefore, no impact is identified for this issue area, and this topic will not be further discussed in the EIR.
Threshold of Significance: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
According to the geotechnical study prepared for the project, the project site is in the Peninsular Ranges geomorphic province. Based on subsurface exploration conducted as part of the geotechnical evaluation, the project site is locally underlain by a layer of colluvium over Cretaceous age t onalite (granitic) bedrock (GeoTek 2023 b). Known fossil occurrences in the Peninsular Range region are extremely rare though some areas may have a high to moderate potential to contain paleontological resources (County of San Diego 2009). Given that the project site supports granitic bedrock and colluvium, it would not be characterized as having a high or moderate potential for paleontological resources. Therefore, impacts would be less than significant.
5.4 Hazards and Hazardous Materials
The following technical analyses were prepared to assess the potential for the project site to contain hazardous materials and are included as Appendix I, J.1, J.2, and J.3):
• Phase I Environmental Site Assessment, 225 North Las Posas Road, San Marcos, California.
February 1, 2021. Prepared by Stantec (Stantec 2021a, Appendix I) • Phase II Environmental Site Assessment. 225 North Las Posas Road, San Marcos, California, 92069. March 23, 2021. Prepared by Stantec (Stantec 2021b, Appendix J). • Due Diligence Environmental Review. A Portion of APN 219-162-57-00, 225 North Las Posas Road, San Marcos, California. January 26 , 2023 . Prepared by GeoTek (GeoTek 2023a, Appendix K).
• Statement of Clarification Regarding Suspected UST, A Portion of APN 219 -162-57-00, 225 North Las Posas Road, San Marcos, California. October 5, 2023. Prepared by GeoTek. (GeoTek 2023c, Appendix L)
Threshold of Significance: Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials? Hazardous materials include solids, liquids, or gaseous materials that, because of their quantity, concentration, or physical, chemical, or infectious characteristics could pose a threat to human health or the environment. Hazards include the risks associated with potential explosions, fires, or release of hazardous substances in the event of an accident or natural disaster, which may cause or contribute to an increase in mortality or serious illness or pose substantial harm to human health or the environment. The proposed project would involve the transport of fuels, lubricants, and various other liquids needed for operation of construction equipment at the site on an as-needed basis by equipment service trucks. Materials hazardous to humans, wildlife, and sensitive environments, including diesel fuel, gasoline, equipment fluids, concrete, cleaning soluti ons and solvents, lubricant oils, adhesives, human waste, and chemical toilets, would be present during project construction. The potential exists for direct impacts to human health from accidental spills of small amounts of hazardous materials from construction equipment; however, the proposed project would be required to comply with Federal, State, and City Municipal Code restrictions which regulate and control those materials handled onsite.
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Compliance with these restrictions and laws would ensure that potentially significant impacts would not occur during project construction.
In addition, as a mixed use residential project, the only hazardous materials anticipated for transport or disposal associated with the proposed project during operation are routinely used household products such as cleaners, paint, solvents, motor oil/ automotive products, batteries, and garden maintenance products. It is anticipated that the use, handling, and disposal of these products would be addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan of the County of San Diego and other Federal, State, and City Municipal Code regulations.
In summary, the project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impacts would be less than significant.
Threshold of Significance: Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The project site is vacant and undeveloped. A Phase I Environmental Site Assessment (Phase 1 ESA) was prepared for the project site and is included as
Appendix I (Stantec 2021a). The Phase 1 ESA
noted that the project site is listed in several databases and has historically generated and disposed of hazardous waste since at least 1981. In 2012, the project site received violations from San Diego County including missing evidence of financial responsibility, and failure to test secondary containment and alarms. In 2018, the project site received permit -related violations, which were returned to compliance. The Phase 1 ESA concluded that is no indication of a release and the project site was returned to compliance , these listings are not considered a Recognized Environmental Condition (REC) for the site
24. The Phase 1 ESA also noted that the project site is located in the vicinity of historical Leaking Underground Storage Tank (LUST) cleanup sites within 500 feet. However, due to case closure dates, remediation, and elevations from the project site, these do not constitute RECs for the project site (Stantec 2021a).
The only REC identified for the project site in the Phase 1 ESA was a 550-gallon diesel underground storage tank (UST) that was reportedly installed at the on the project site in 1972. The project site also reportedly had a 1,000-gallon UST containing diesel that was installed in 1980 and removed in 1994.
A third UST, which was a 5,000-gallon diesel UST, was reportedly installed in 1994. No leaks or spills associated with any of the USTs have been repor ted for the project site ; however, the presence (or historical presence, as the case may be) of USTs were determined to be a REC for the project site (Stantec 2021a). The Phase 1 ESA recommended performing a ground penetrating radar (GPR) survey to verify if the USTs still remained on the project and a soil and soil vapor assessment to evaluate the subsurface conditions beneath the project site (Stantec 2021a).
Based upon the results of the Phase 1 ESA, a Phase 2 ESA was prepared for the project site by Stantec in 2021. The Phase 2 ESA is included as Appendix J. Soil sampling and installation of soil vapor probes
24 A recognized environmental condition (REC) as defined in American Society for Testing and Materials (ASTM) 1527-13 means the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. The term includes hazardous substances or petroleum products under conditions in compliance with laws (e.g., permitted discharges).
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was performed between February 22 and March 4, 2021. Additionally, a ground penetrating radar survey was conducted to try to locate the 550-gallon UST.
Soil Sampling Results
Railroad spurs are located adjacent to the project site to the north. Herbicides are commonly applied to railroad alignments and heavy metals associated with herbicidal application can be found in such areas. Due to the presence of the spurs, subsurface investigation via soil sampling was conducted in 2021 at two locations (S-1 and S-2) near the project site’s northern boundary. Two soil vapor samples were also conducted (SV-1 and SV-2) near the location of the former 550-gallon UST in the northern portion of the project site. Soil sampling locations are detailed in Figure 2 of the Phase 2 ESA (Appendix J of this document)
The results of soil samples collected along the northern property line near the rail line were "non - detect" for arsenic and organochlorine pesticides (OCPs) except for a minor detection of Heptachlor at
0.0014 milligrams per kilogram (mg/kg), which is well below its screening levels for residential uses.
Lead was detected at 4.8 and 7.2 mg/kg in location S-1 and S-2, respectively. Because all detected metals concentrations are within typical California naturally occurring background concentration ranges, and do not exceed Department of Toxic Substances Control (DTSC) Human and Ecological Risk Office (HERO) Note 3 or Environmental Protection Agency (EPA) Regional Screening Levels (RSLs) for residential use, the adjacent railroad tracks do not represent a recognized environmental condition (REC) to the property and no further assessment appears warranted (Stantec 2021b).
Total Petroleum Hydrocarbons as vapor (TPHv) and various volatile organic compounds ( VOCs) were detected at low concentrations at location SV -1 and SV -2. These concentrations were all below the most conservative screening level between the U.S. Environmental Protection Agency (USEPA) Region 9 RSL and DTSC HERO Note 3 with an attenuation factor of 0.03, with the exception of benzene.
Benzene was detected at 5.7 micrograms per cubic meter (µg/m 3) i n SV-2 which is above the
regulatory screening level with an a ttenuation factor of 0.03 (3.2 µg/m 3), but below the regulatory screening level with an attenuation factor or 0.001 (97 µg/m 3). Given the concentration was only slightly above the regulatory screening level with an attenuation factor of 0.03 (which is not the official screening level and which has not been adopted by any state agency), and well below the risk -based screening level of 97 µg/m
3, this single detection is considered a de minimis condition and no further assessment appears warranted for soil vapor (Stantec 2021b).
Ground Penetrating Radar Results and Further Investigation The ground penetrating radar survey identified an anomaly which may be the 550 -gallon UST in the northwest portion of the property at approximately 2 to 4 -feet in depth. Phase 2 ESA recommended removing and disposing of the UST in accordance with all applicable laws. Based upon this recommendation, additional site work was conducted to attempt to locate the potential 550-gallon UST.
On December 14, 2022, Hal Hays Construction, Inc. was contracted by the property owner to evaluate the anomaly identified by Stantec’s Phase 2 ESA. A Professional Geologist and an Environmental Professional from GeoTek were on site during the field exploration. The excavation was performed with a conventional rubber-tired backhoe with a 24 -inch wide, smooth edge, bucket. The excavation was approximately six feet long and three feet wide. Shallow refusal by granitic rock ( tonalite) was encountered at an approximate depth of two to three feet below grade. A weathered core stone was encountered at the approximate location of the anomaly identified in Stantec’s Phase 2 ESA. A second core stone was encountered approximately six feet north of the recorded anomaly. To further evaluate
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a potential UST, the excavation was lengthened to the north and south for a total linear excavation length of approximately twelve feet. North and south of the excavation, core-stones extruded from the subsurface. The excavation encountered a thin layer of topsoil over weathered t onalite and encountered non-rippable rock at a depth three feet but became as shallow as one foot above the core-stones. Based on this, GeoTek concluded that evidence is not present to conclude the 550-gallon UST is present on the site and no further environmental investigation is necessary (GeoTek 2023a and 2023c). The documentation from GeoTek regarding the field exploration is included as Appendix K and L.
In conclusion, 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 which has the potential to create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Impacts would be less than significant.
Threshold of Significance: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The project site is not located within 0.25 miles of an existing or proposed school. The closest school is San Marcos Middle School which is located approximately 0.6 miles west of the project site. No impact is identified.
Threshold of Significance: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The provisions of Government Code Section 65962.5 are commonly referred to as the Cortese List.
The Cortese List is a planning document used by the state and local agencies to provide information about hazardous materials release sites. Government Code Sec tion 65962.5 requires California Environmental Protection Agency (CalEPA) to develop an updated Cortese List annually, at minimum.
California DTSC is responsible for a portion of the information contained in the Cortese List. Other California state and local government agencies are required to provide additional hazardous material release information for the Cortese List.
The Phase 1 ESA prepared for the project included a search of federal and state databases. The site was not identified as being on the Cortese List (Stantec 2021a). A subsequent review of the Cortese List in 2023 reconfirmed that the project site is not identified on a Cortese List (DTSC 2023). Therefore, the project would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and no impact is identified for this issue area.
Threshold of Significance: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The nearest airport is the McClellan -Palomar Airport in Carlsbad, which is located approximately 6.5 miles to the southwest of the project site. According to Figure 6-5 of the Safety Element of the City’s General Plan, the project site is located within Review Area 2 of the airport influence area. Review Area 2 limits the heights of structures in areas of high terrain. The project site is situated in a lower elevation area of the City. According to the Airport Land Use Compatibility Plan (ALUCP) for the McClellan -
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Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, the project would not result in a safety hazard of excessive noise for people residing or working in the project area. No impact is identified.
Threshold of Significance: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
According to the General Plan Safety Element, the San Marcos Emergency Operations Plan (EOP) governs the operations of the City during a disaster. This plan addresses response to moderate evacuation scenarios, including the identification of evacuation points and general routes (San Marcos 2012). The project would not result in any changes to the transportation network which could impair implementation of or physically interfere with an adopted emergency response plan. No impact would occur.
Threshold of Significance: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? The project site is located in a developed part of the City and is not located where wildlands are adjacent to urbanized areas, nor does the project propose residences mixed in with wildlands. The project site is located in a Local Responsibility Area, not a State Responsibility area (CAL FIRE 2022).
The project site is in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non- VHFHSZ) designation per California Department of Forestry and Fire Protection (CAL FIRE) 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 area are not identified as a San Marcos Fire Protection District ( SMFPD) Community Hazard Zone. Impacts would be less than significant.
5.5 Hydrology and Water Quality
Threshold of Significance: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? The applicant would be required to comply with the National Pollutant Discharge Elimination System (NPDES) permit. Regionally, this is achieved by preparing and implementing a Stormwater Quality Management Plan (SWQMP) based on the standards set forth in the 2023 City of San Marcos BMP Design Manual (City of San Marcos 2023) . The project would be required to comply with the City of San Marcos BMP Design Manual. The SWQMP would require implementation of water quality BMPs to ensure that water quality standards are met and that stormwater runoff from construction areas does not result in a degradation of water quality in receiving water bodies. Impacts would be less than significant.
Threshold of Significance: Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Implementation of the project would not use any groundwater. The project would be served by VWD for its water supply and would not require development of any new groundwater wells. The project site is not located within a sustainable groundwater management area and is not part of a significant
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groundwater recharge area. The geotechnical analysis (see Section 5.4) determined the project site is underlain by colluvium, alluvium and tonalite (granitic) bedrock (Geotek 2023b). The granitic bedrock creates a barrier to groundwater infiltration. Groundwater is not anticipated to be within 50 feet of the ground surface and would not be a factor in site development. An infiltration evaluation including percolation testing was performed and determined that the site’s average infiltration rates were 0.1 and 0.4 inches per hour (Geotek 2023b). The threshold for relying on infiltration is 0.5 inches per hour (or greater) according to Attachment I of the SWQMP (Latitude 33 2024b).
According to the SWQMP prepared for the project, 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 BMPs would collect water f rom all impervious areas before it is discharged off site. Flow -thru treatment is required to treat runoff from the proposed development (Latitude 33 2024b) . Without feasible inf iltration, the project site would not provide groundwater recharge and therefore implementation of the proposed project would not interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level, nor would it impede sustainable groundwater management of the basin. Impacts would be less than significant.
Threshold of Significance: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, through the addition of impervious surfaces, in a manner which would: result in substantial erosion or siltation on- or off-site? Threshold of Significance: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, through the addition of impervious surfaces, in a manner which would: substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
Threshold of Significance: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, through the addition of impervious surfaces, in a manner which would: create or contribute to runoff water which wo uld exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Threshold of Significance: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, through the addition of impervious surfaces, in a manner which would: Impede or redirect flood flows? The proposed project would increase the amount of impervious surface on the project site through the construction of rooftops, driveways, parking lots, and concrete walkways within the project site .
The project would be required to implement design features to ensure that changes to drainage patterns do not result in adverse impacts related to hydrology and water quality. The project design incorporates 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. These treatment facilities would be constructed in conformance with the City’s BMP Design Manual, which includes requirements for vector control. Per the BMP Design Manual (Pages 4 -1 and 4-2), onsite BMPs must be designed and implemented with measures to avoid the creation of nuisances or pollution associated with vectors (e.g., mosquitos, rodents, or flies). Projects will comply with this requirement by incorporating design, construction, and maintenance principles to drain retained water within 96 hours and minimize standing water. Design
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calculations will be provided to demonstrate the potential for standing water ponding at surface level and accessible to mosquitos has been addressed. For water retained in biofiltration facilities that are not accessible to mosquitoes this criteria is not applicable (i.e., water ponding in the gravel layer, water retained in the amended soil, etc.). (City of San Marcos 2023). The BMP Design Manual further states (Page 6-11), “This standard applies to, but is not limited to, detention basins, underground st orage vaults, and the above-ground storage portion of LID facilities. When this standard cannot be met due to large, stored runoff volumes with limited maximum release rates, a vector management plan may be an acceptable solution if approved by the City of San Marcos (City of San Marcos 2023).
Currently, there is a high point in the central to the site and drainage flows all directions and does not become concentrated on the project site. In the proposed condition, runoff would discharge to the existing storm drain system at one discharge point (POC1) on Armorlite Drive. Based upon the Drainage Study prepared for the project (Latitude 33 202 4a), the current runoff rate is 3.45 cubic feet per second (cfs). With installation of the two treatment facilities and underground storage vault, which are proposed as part of the project design, the runoff rate would be 1.58 cfs. This represents a decrease of 1.87 cfs in the proposed condition. Therefore, the project would not result in substantially altering the drainage pattern of the site or area that would result in substantial erosion on- or off-site, increase surface runoff resulting in flooding on - or off-site, provide substantial sources of polluted runoff, or impede or redirect flood flows. Impacts would be less than significant.
Threshold of Significance: In flood hazards, tsunami or seiche zones, risk release of pollutants due to project inundation.
Per the Federal Emergency Management Agency’s (FEMA’s) Flood Insurance Rate Map Number 06073C0789H, the project site is not located within a 100-year flood hazard area (FEMA 2012). The project site is approximately 8 miles inland from the Pacific Ocean and would not be subject to inundation by tsunami. Given that the project site is not located near a large standing body of water, inundation by seiche (or standing wave) is considered negligible. No impact would occur.
Threshold of Significance: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The project site is not located in a sustainable groundwater management plan area. The project site is located within the Carlsbad Management Area Water Quality Improvement Plan (WQIP). The project would be required to implement design features to ensure that changes to drainage patterns do not result in adverse impacts related to hydrology and water quality. The project design incorporates 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. Impacts would be less than significant.
Threshold of Significance: Result in significant alteration of receiving water quality during or following construction?
Potential construction-related impacts associated with receiving water quality would include siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site. During project operation, potential impacts associated with receiving water quality could include runoff associated with landscaping/outside pesticide use, pest control (indoor/structural), fire sprinkler test water, and runoff from parking areas and sidewalks. The project design incorporates two proprietary treatment facilities and an underground storage vault beneath the
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parking lot to regulate stormwater discharge rates and provide a water quality treatment benefit.
Impacts would be less than significant.
Threshold of Significance: Result in an increase in pollutant discharges to receiving waters? Consider water quality parameters such as temperature, dissolved oxygen, turbidity, and other typical storm water pollutants (e.g., heavy metals, pathogens, petroleum derivatives, synthetic organics, sediment, nutrients, oxygen-demanding substances, and trash).
The project site is in the Carlsbad hydrologic unit (904). Impaired water bodies in this watershed, as listed in the State Water Resources Control Board (SWRCB) 303(d) impaired waters list. San Marcos Creek is listed on the 2020-2022 Integrated Report (CWA Section 303(d)/305(b)) List of Impaired Water Segments as being impaired for Nutrients (nitrogen and phosphorus), Metals (Selenium), Total Toxics (toxicity), Other Causes (Benthic Community Effects), Pesticides (bifenthrin, dichlorodiphenyldichloroethylene [DDE] and pyrethroids), Pathogens (indicator bacteria), and Total Dissolved Solids. Further downstream, Batiquitos Lagoon is also listed as being impaired for toxicity.
Furthermore, San Marcos Lake was identified under Section 303(d) of the Clean Water Act as impaired due to nutrients (ammonia as nitrogen and phosphorous, and metals [copper ]) (SWRCB 2022). The project would be required to implement design features to ensure that changes to drainage patterns do not result in adverse impacts related to hydrology and water quality. The project design incorporates two proprietary treatment facilities and an underground sto rage vault beneath the parking lot to regulate stormwater discharge rates and provide a water quality treatment benefit. Impacts would be less than significant.
Threshold of Significance: Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pollutant for which the water body is already impaired?
Impaired water bodies in the Carlsbad watershed include San Marcos Creek , Batiquitos Lagoon and Lake San Marcos. The project design includes a comprehensive water quality approach including a storm drain system . The project design incorporates two proprietary treatment facilities and an underground storage vault beneath the parking lot to regulate stormwater discharge rates and provide a water quality treatment benefit. Impacts would be less than significant.
Threshold of Significance: Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.)? If so, can it exacerbate already existing sensitive conditions? The project site is located outside of the Biological Resource Conservation area for the Multiple Habitat Conservation Plan (MHCP). Runoff from the project site eventually flows to San Marcos Creek, Lake San Marcos and ultimately to Batiquitos Lagoon. The project design includes a comprehensive water quality approach including a storm drain system . The project design incorporates two proprietary treatment facilities and an underground storage vault beneath the parking lot to regulate stormwater discharge rates and provide a water quality treatment benefit. Impacts would be less than significant.
Threshold of Significance: Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters?
The project would generate pollutants both during construction and operation that could impact water quality. The project design includes a comprehensive water quality approach including a storm drain system. The project design incorporates proprietary treatment facilities and an underground storage
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vault beneath the parking lot to regulate stormwater discharge rates and provide a water quality treatment benefit. Impacts would be less than significant.
5.6 Land Use and Planning
Threshold of Significance: Physically divide an established community.
The project site is currently undeveloped. The project proposes residential and commercial uses in an area that is already developed with similar uses. The project would not physically divide an established community. No impact is identified for this issue area.
A discussion of additional land use and planning significance thresholds is provided in Section 3. 7 Land Use and Planning.
5.7 Mineral Resources
Threshold of Significance: Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
According to the City of San Marcos General Plan Conservation & Open Space Element, the City has land classified in all four Mineral Resource Zones (MRZ) (San Marcos 2012). California does not require that local governments protect land designated as MRZ-1, MRZ-3, or MRZ-4. However, the City is responsible for recognizing lands designated as MRZ-2 and protecting these areas from premature development incompatible with mining. The lands designated as MRZ -2 include small portions between Double Peak, Mt. Whit ney, and Franks Peak; and small portions in the northern Sphere of Influence within Twin Oaks Valley Neighborhood. These locations do not overlap with the proposed project site; therefore, no loss of known mineral resources would occur. No impact would occur.
Threshold of Significance: Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan The project site is not designated as a locally important mineral resource recovery site on any local general plan, specific plan, or other land use plan (City of San Marcos 2012). Due to the location and the nature of the proposed project, there would be no impact on mineral resources.
5.8 Noise
Threshold of Significance: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project are to excessive noise levels?
The proposed project is not located within the vicinity of a private airstrip. The public airport closest to the project site is the McClellan -Palomar Airport, located approximately 5 miles to the southwest.
According to the ALUCP for the McClellan -Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, people residing or working in the project area would not be exposed to substantia l airport noise.
A discussion of additional noise significance thresholds is provided in Section 3.8, Noise.
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5.9 Population and Housing
Threshold of Significance: Displace substantial numbers of existing housing or people, necessitating the construction of replacement housing elsewhere.
There is no existing housing on the project site. Therefore, the project would not remove existing housing. The project proposes 165 residential apartments 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 (30% to 50% of the average median income) . The project would add to the housing stock in the City. No impact is identified for this issue area.
A discussion of additional population and housing significance thresholds is provided in Section 3.9, Population and Housing.
5.10 Public Services
Threshold of Significance: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or need for new or physically altered governmental facilities, the construction of which could cause signi ficant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks?
The project proposes residential uses which can result in an increase in demand for neighborhood and regional parks. The project design proposes 36,944 s.f. of common outdoor open space. This includes passive areas, a dog park with dog washing station. a pool/spa area, outdoor lounge, game area, yoga area, courtyard, an indoor-outdoor lounge open to the pool area, and a roof deck. All common open space would be for the use of future residents and would be maintained by the property management company. The project also proposes 2,050 s.f. of common indoor space which includes a 1,200 s.f. fitness area and an 850 s.f. lounge.
Additionally, the project will pay Public Facility Fees (PFF), a portion of which goes toward funding a city-wide park and recreation facilities. Since the project provides on -site recreational amenities and will pay PFF, impacts would be less than significant.
5.11 Recreation
Threshold of Significance: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration of the facility would occur or be accelerated?
Threshold of Significance: Does the project include any recreational facilities or require the construction or expansion of recreation facilities which might have an adverse physical effect on the environment?
The project proposes residential uses which can result in an increase in demand for neighborhood and regional parks. However, the project has incorporated recreational amenities into their design. The project design proposes 36,944 s.f. of common outdoor open space. This includes passive areas , a dog park with dog washing station. a pool/spa area, outdoor lounge, game area, yoga area, courtyard, an indoor-outdoor lounge open to the pool area, and a roof deck. All common open space would be for the use of future residents and would be maintained by the property management company. The
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project also proposes 2,050 s.f. of common indoor space which includes a 1,200 s.f. fitness area and an 850 s.f. lounge. The proposed project will pay PFF, a portion of which goes toward funding a city - wide park and recreation facilities and would offset the future residents demand for such facilities .
Since the project provides on-site recreational amenities and will pay PFF, impacts would be less than significant.
5.12 Transportation
Threshold of Significance: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? The project does not propose any feature that would result in a substantial increase in hazards due to geometric design or incompatible use. Project access would be via a driveway on Armorlite Drive. The project’s entrance and circulation has been designed to meet City standards. No impact is identified.
Threshold of Significance: Result in inadequate emergency access? The California Fire Code, along with the San Marcos Fire Department, administers the rules and regulations on fire access design. The proposed project must present a design which affords fire and emergency responders suitable fire access roads in terms of dimensions and surfaces (Chapter 5, § 503.1 through 503.4 of the California Fire Code). The project proposes one primary entrance from Armorlite Drive. A secondary emergency-only access from Las Posas Road would be provided at the northwest corner of the project site through the adjacent AT&T parcel. Drive aisles within the project would be designed to accommodate San Marcos Fire Department standard tiller trucks and engines. Impacts would be less than significant.
5.13 Wildfire
Threshold of Significance: A significant wildfire would be identified if the project was located in or near a state responsibility area or lands classified as very high fire hazard severity zone and would:
• Substantially impair an adopted emergency response plan or emergency evacuation plan; • Due to slope, prevailing wind, and other factors exacerbate wildlife risk, and thereby, expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire;
• Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or • Expose people or structure to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability or drainage changes.
The project site is located in a Local Responsibility Area, not a State Responsibility area (CAL FIRE 2022). The project site is in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per California Department of Forestry and Fire Protection (CAL FIRE) San Marcos Fire Hazards Severity Zones Map (2009) and is surroun ded by areas identified as Non - VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. No impact is identified for this issue area.
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6.0 Other CEQA Considerations
6.0 Significant and Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines, Section 15126.2(b), requires that an Environmental Impact Report (EIR) describe any significant impacts that cannot be avoided, including those impacts that can be mitigated but not reduced to a less -than-significant level. Chapter 3, Environmental Analysis, of this EIR describes the potential environmental impacts of the proposed project and recommends mitigation measures to reduce impacts, where feasible. Based upon the analysis in Sections 3.1 through 3.13 of this EIR, the proposed project would not have any significant and unavoidable impacts. All impacts would be mitigated to below a level of significance through the incorporation of mitigation measures. These mitigation measures would be identifie d in a Mitigation Monitoring and Reporting Program that will be adopted as part of the project and would also be made a condition of approval of the project.
6.1 Growth Inducement
Section 15126.2(e) of the CEQA Guidelines mandates that the growth inducing nature of a proposed project be discussed. This CEQA Guideline states the growth-inducing analysis is intended to address the potential for the proposed project to “foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) also mandates that a CEQA document speak to the proposed project’s likelihood to induce substantial population growth in an area, either directly (e.g., by proposing new homes or businesses) or indirectly (e.g., through extension of roads or other infrastructure).
A project may be distinguished as either facilitating planned growth or inducing unplanned growth.
Facilitating growth is related to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing grow th is related to lowering or removing barriers to growth or by creating an amenity or facility that attracts new population/economic activity.
For purposes of this EIR analysis, a significant growth inducement impact would occur if the proposed project, and associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burden existing community services, the environment or cause a demand for General Plan Amendments. This section contains a discussion of the growth inducing factors related to the proposed project and as defined under CEQA Guidelines, Section 15126.2(e). A project is defined as growth inducing when it directly or indirectly:
• Fosters population growth;
• Includes the construction of additional housing in the surrounding environment; • Removes obstacles to population growth;
• Taxes existing community service facilities, requiring construction of new facilities that could cause significant environmental effects; and/or
• Encourages or facilitates other activities that could significantly affect the environments, either individually or cumulatively.
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It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
As discussed in Section 3.9.4, Population and Housing, the proposed project would directly induce growth through the development of 165 apartments on 2.44 acres. Based on the city’s population rate of 3.1 persons per dwelling unit, the proposed project would directly induce population growth to the area and would potentially add an estimated 512 people to the area. In addition, the proposed project would add 5,600 square feet (s.f.) of ground floor retail to the project site, w hich would provide employment opportunities. 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 the proposed project. The San Diego Ass ociation of Governments ( 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.
As discussed in Section 3.9, Population and Housing, 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 (SANDAG 2022).
The future commercial uses are anticipated to have appro ximately 6 employees. It is expected 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.
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 Regional Housing Needs 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.
6.2 Significant Irreversible Environmental Changes
CEQA Guidelines, Section 15126.2(d), requires that an EIR identify any significant irreversible environmental changes associated with the proposed project. Such changes include, for example, the intensification of land use or irreversible damage from envir onmental accidents associated with the proposed project.
The project proposes development of 165 apartments on 2.44 acres for proposed density of 67 dwelling units per acre. The project proposes a General Plan Amendment and Rezone. The General Plan Amendment would change the existing PI (Public/Institutional) designation to Mixed Use 2 (MU2) and the rezone would be required to change the existing Public-Institutional (P -I) zoning to Specific Plan Area (SPA).
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The proposed project’s change in land use would not be an intensification of land use over the existing Public-Institutional designation. As analyzed in Chapter 4, Alternatives, of this EIR, development under the existing land use and zoning designation would result in additional and more severe environmental impacts for many environmental topical areas in comparison to the development under the proposed project designations. Nevertheless, as analyzed throughout Chapter 3 of this EIR, the proposed project may result in potentially significant impacts to biological resources, cultural resources, noise, and tribal cultural resources (see Tables 1-1 in Chapter 1, Executive Summary, of this EIR). All potential impacts identified for the proposed project would be mitigated to below a level of significance.
Construction and/or operation of the proposed project would require the use of resources that include, but are not limited to, soils, gravel, concrete, and asphalt, lumber and other related forest products, petrochemical construction materials, steel, copp er, and other metals, water, fuels, and energy. As such, the proposed project would result in the short -term and long-term use of fossil fuels and other nonrenewable resources however this use would not result in any significant irreversible changes as a result of using nonrenewable resources.
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7.0 References
Project Description (Section 2.0)
City of San Marcos. 2012. City of San Marcos General Plan, Land Use and Community Design Element.
Adopted February 14. https://www.san -marcos.net/home/showpublisheddocument/8480/ 636570701878000000. Accessed August 8, 2024.
Dudek. 2025 2024. Biological Resources Technical Report for the Armorlite Lofts. March October.
GeoTek, Inc. 2023. Preliminary Geotechnical Evaluation for Eastern Portion of 225 N. Las Posas Road, San Marcos, California. August 10.
Latitude 33. 2024 . Drainage Study. Armorlite Lofts, Armorlite Drive, San Marcos, California 92069.
October 23.
Aesthetics (Section 3.1)
City of San Marcos. 202 4a. Zoning Ordinance, Section 20.300.080- Light and Glare Standards.
Adopted November 13, 2012, Last Supplemented March 31, 2021. https://library.municode. com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.300SIPLGEDEST_S20.30
0.080LIGLST. Accessed July 15, 2024.
City of San Marcos. 202 4b. Zoning Ordinance, Section 20.260 -Ridgeline Protection & Management Overlay Zone. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId =TIT20ZO. Accessed July 15, 2024.
Dudek. 2025 2024. Biological Resources Technical Report for the Armorlite Lofts. March October.
United States Census Bureau (USCB). 2023. Quick Facts Escondido City, San Marcos City, California, United States. https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia,sanmarcos citycalifornia,US/PST045219. Accessed July 15, 2024.
Air Quality (Section 3.2)
California Air Resources Board (CARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel -Fueled Engines and Vehicles. October 2000. https://ww2.arb. ca.gov//sites/default/files/classic/diesel/documents/rrpfinal.pdf. Accessed May 9, 2024.
California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. https://www.aqmd.gov/docs/default -source/ceqa/handbook/california-air-re sources-board-air-quality-and-land-use-handbook-a-community-health-perspective.pdf. Accessed May 9, 2024.
California Air Resources Board (CARB). 2016. Ambient Air Quality Standards. May 4. http://www.arb.ca.gov/research/aaqs/aaqs2.pdf. Accessed May 10, 2024.
LDN Consulting. 2024. Air Quality Assessment, Armorlite Lofts Residential Development GPA23-0002, R23-0001, SDP23-0003, CUP23-0002, City of San Marcos, CA. November 4.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
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Linscott Law & Greenspan ( LLG). 2024. Local Transportation Analysis: Armorlite Lofts, San Marcos California. November 7.
Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines. February.
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed November 4. 2024.
San Diego Air Pollution Control District (SDAPCD). 1976. Regulation IV; Rule 51: Public Nuisance. https://www.sdapcd.org/content/sdapcd/rules.html. Accessed May 9, 2024.
San Diego Air Pollution Control District ( SDAPCD). 2019. Rule 20.2: New Source Review Non- Major Stationary Sources. June 26. https://www.sdapcd.org/content/sdapcd/rules.html. Accessed May 9, 2024.
San Diego Air Pollution Control District (SDAPCD). 2020. 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County. October. https://ww2.arb.ca.gov/our- work/programs/california-state-implementation-plans/nonattainment-area-plans/san-diego-county-0 Accessed May 9, 2024.
San Diego Air Pollution Control District ( SDAPCD). 2023. Regulation XII; Rule 1210: Toxic Air Contaminant Health Risks - Public Notification and Risk Reduction. September 19. https://www. sdapcd.org/content/sdapcd/rules.html. Accessed May 9, 2024.
San Diego Air Pollution Control District (SDAPCD). 2024. Attainment Status. https://www. sdapcd.org/content/sdapcd/planning/attainment-status.html. Accessed May 9, 2024.
San Diego Association of Governments (SANDAG). 2002. SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region. April. https://www.sandiegocounty .gov/content/dam/sdc/pds/ceqa/LehmanTPM/38%20Appendix%20T9_SANDAG%20Trip%20Gener ation%20Rates.pdf. Accessed May 9, 2024.
United States Environmental Protection Agency (USEPA). 1980. AP-42, Fifth Edition, Volume 1, Chapter 13: Miscellaneous Sources, Sub Chapter 13.3 Explosives Detonation. February. https://www. epa.gov/sites/default/files/2020-10/documents/13.3_explosives_detonation.pdf. Accessed May 9, 2024.
Biological Resources (Section 3.3)
California Department of Fish and Wildlife (C DFW). 2025. RareFind, Version 5.2.14 (Commercial Subscription). California Natural Diversity Database (CNDDB). Sacramento, California: CDFW, Biogeographic Data Branch. Accessed March 2025. https://www.wildlife.ca.gov/Data/CNDDB/Maps-and- Data.
Dudek. 2025 2024. Biological Resources Technical Report for the Armorlite Lofts. March October.
Holland, R.F. 1986 . Preliminary Descriptions of the Terrestrial Natural Communities of California.
Nongame-Heritage Program, California Department of Fish and Game. October.
Oberbauer, T., M. Kelly, and J. Buegge (Oberbauer, et al). 2008. Draft Vegetation Communities of San Diego County. March . https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/Soitec-Docu
7.0 References
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ments/Final-EIR-Files/references/rtcref/ch9.0/rtcrefaletters/O14%202014-12-19_OberbauerTM 2008.pdf. Accessed March 8, 2024.
SANDAG (San Diego Association of Governments). 2003. Multiple Habitat Conservation Program Final MHCP Plan. March . https://www.sandag.org/-/media/SANDAG/Documents/PDF/projects-and- programs/environment/regional-habitat-conservation/volume-1-final-multiple-habitat-conservation- program-plan-2003-03-01.pdf. Accessed March 8, 2024.
U.S. Fish and Wildlife Service (USFWS). 1997. “Coastal California Gnatcatcher Presence/Absence Survey Protocol.” Revised July 28. https://www.fws.gov/media/coastal-california-gnatcatcher- presenceabsence-survey-protocol. Accessed March 8, 2024.
Cultural Resources (Section 3.4)
ASM 2024. Archaeological Survey Report for Armorlite Lofts Project, San Marcos, California. July. City of San Marcos. 2024. City of San Marcos Archeological and Historical Resources Consultant Guidelines. https://www.san-marcos.net/home/showpublisheddocument/28161/6384059220902 70000
Gallegos and Associates. 2002. Data Recovery Program for Pacbell Site CA -SDI-5633, San Marcos, California.
Gallegos, Dennis, and Andrew Pigniolo (Gallegos and Pigniolo). 1990. The Copley Project, San Marcos California, Cultural Resources Survey and Testing Program at SDI -5633. ERC Environmental and Energy Services Co.
Guerrero, Monica, and Dennis Gallegos (Guerrero et al.). 2007. Cultural Resources Monitoring Report for the North County Transit District (NCTD) Sprinter Rail Project, Oceanside to Escondido, CA.
Bowman, Roy H. 1973 . Soil Survey, San Diego Area , California. United States Department of Agriculture, Washington, D.C.
Hines, Philip. 1991. A Re-evaluation of the Prehistoric Archaeological Sites within the Pendleton Coast District. In The Cultural Resources of the Pendleton Coast District . On file a t the South Coast Information Center, San Diego State University.
Munz, Philip S. 1974. A flora of Southern California. University of California Press, Berkely.
Oxendine, Joan. 1983. The Luiseno Village During the Late Prehistoric Era. Dissertation, University of California Riverside.
General Land Office. 1883. Land Patent for PLC 517. On file with Bureau of Land Management.
Parker, Patricia L, and Thomas F. King. 1998. Guidelines for Evaluating and Documenting Traditional Cultural Properties. https://www.resolutionmineeis.us/sites/default/files/references/parker-king- 1998.pdf Accessed by November 5, 2024.
Energy (Section 3.5)
California Air Resources Board (CARB). 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf. Accessed March 6, 2024.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-4
California Energy Commission (CEC). 2021. 2022 Building Energy Efficiency Standards Summary.
August. https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdate Summary_ADA.pdf. Accessed March 6, 2024.
California Public Utility Commission (CPUC). 2021. Natural Gas and California. https://www. cpuc.ca.gov/industries-and-topics/natural-gas/natural-gas-and-california. Accessed March 6, 2024.
Energy Information Administration, United States (EIA). 2023a. California State Energy Profile. April
20. https://www.eia.gov/state/print.php?sid=CA. Accessed March 6, 2024.
Energy Information Administration, United States (EIA). 2023b. State Electricity Profiles: Table 1. 2022 Summary Statistics (California). Released November 2. https://www.eia.gov/electricity/state /california/index.php. Accessed March 6, 2024.
LDN Consulting (LDN). 2024. Energy Usage Letter – Armorlite Lofts 225 Development (GPA23-0002, R23-0001, SDP23-0003, CUP23-0002), November 4.
Linscott Law & Greenspan (LLG). 202 4. Local Transportation Analysis: Armorlite Lofts, San Marcos California. November 7.
San Diego Gas & Electric (SDG&E). 2022a. The Path to Net Zero: A Decarbonization Roadmap for California. April. https://www.sdge.com/sites/default/files/documents/netzero2.pdf . Accessed March 6, 2024.
San Diego Gas & Electric (SDG&E). 2022b. 2022 Individual Integrated Resource Polan of San Diego Gas & Electric Company (U 902 E). Public Version. November 1. https://www.sdge.com /sites/default/files/regulatory/SDG%26E%202022%20Individual%20Integrated%20Resource%20Pl an%20%28PUBLIC%29_0.pdf. Accessed March 6, 2024.
San Diego Gas & Electric (SDG&E). 2024. About Us. https://www.sdge.com/more -information/our- company/about-us. Accessed March 6, 2024.
Greenhouse Gas (Section 3.6)
City of San Marcos. 2020. Final Climate Action Plan and Appendix D Guidance to Demonstrating Consistency with the City of San Marcos Climate Action Plan for Discretionary Projects Subject to CEQA and City of San Marcos Climate Action Plan Consistency Revie w Checklist. https://www.san - marcos.net/departments/development-services/planning/climate-action-plan. Accessed March 19, 2024.
Intergovernmental Panel on Climate Change (IPCC). 2007. IPCC Fourth Assessment Report: Climate Change 2007: Working Group I: The Physical Science Basis. Chapter 2, Changes in Atmospheric Constituents and in Radiative Forcing. https://www.ipcc.ch/site/assets/uploads/2018/02/ar4-wg1- chapter2-1.pdf. Accessed March 19, 2024.
LDN Consulting, Inc. (LDN). 2024. Greenhouse Gas Assessment, Armorlite Lofts Residential Development. City of San Marcos, CA. November 4.
Linscott Law & Greenspan (LLG). 202 4. Local Transportation Analysis: Armorlite Lofts, San Marcos California. November 7.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-5
United States Environmental Protection Agency (USEPA). 2023. Understanding Global Warming Potentials. Last Updated on April 18. https://www.epa.gov/ghgemissions/understanding-global- warming-potentials. Accessed March 19, 2024.
Land Use and Planning (Section 3.7)
California Department of Forestry and Fire Protection (CAL FIRE). 2009. Fire Hazard Severity Zones, San Marcos. https://osfm.fire.ca.gov/what -we-do/community-wildfire-preparedness-and-mitigation/ fire-hazard-severity-zones. Accessed February 7, 2024.
City of San Marcos. 2012. City of San Marcos General Plan, Land Use and Community Design Element.
Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument/8480 /636570701878000000. Accessed August 8, 2024.
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November https://www.san- marcos.net/home/showpublisheddocument?id=25036. Accessed July 3, 2024.
City of San Marco 2021. Zoning Ordinance, Section 20.225.060- Mixed Use 3 (SP) Zone. Adopted November 13, 2012. Last Supplemented March 31, 2021.
https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 240PUINZO. Accessed July 3, 2024.
Dudek. 2025 2024. Biological Resources Technical Report for the Armorlite Lofts. March October.
Linscott Law & Greenspan (LLG). 202 4a. Local Transportation Analysis: Armorlite Lofts, San Marcos California. November 7.
Linscott Law & Greenspan (LLG). 202 4b. Vehicle Miles Traveled Study: Armorlite Lofts, San Marcos California. November 7.
San Diego Association of Governments (SANDAG). 2016. https://www.sandag.org/- /media/SANDAG/Documents/PDF/funding/grant-programs/smart-growth-and-housing/smart- growth-in-the-san-diego-region-brochure-2016.pdf. Accessed August 8, 2024.
San Diego Association of Governments (SANDAG). 2002. Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region http://www.sandag.org/uploads/publicationid/pub licationid_1140_5044.pdf. Accessed August 8, 2024.
Noise (Section 3.8)
California Department of Transportation (Caltrans). 2020. Transportation and Construction Vibration Guidance Manual. April. https://dot.ca.gov/-/media/dot-media/programs/environmental-analysis /documents/env/tcvgm-apr2020-a11y.pdf. Accessed March 12, 2024.
City of San Marcos. 2023. Zoning Ordinance, Section 20.300.070- Performance Standards. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library. municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.300SIPLGEDES T_S20.300.070PEST. Accessed March 12, 2024.
Federal Highway Administration ( FHWA). 2006 . Highway Construction Noise Handbook. August. https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-6
Federal Transit Administration (FTA) 2018. Transit Noise and Vibration Impact Assessment Manual.
September. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131 /transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf. Accessed March 12, 2024.
Linscott Law & Greenspan ( LLG). 2024. Local Transportation Analysis: Armorlite Lofts, San Marcos California. November 7.
LDN Consulting (LDN). 2021. San Marcos Rock Crusher Noise.
LDN Consulting (LDN). 2024. Noise Assessment, Armorlite Lofts Residential Development, GPA23- 0002, R23-0001, SDP23-003, CUP23-0002, City of San Marcos, November 4.
Ontario Ministry of Labour (OML). 2016. Training, Skills, and Development.
Population and Housing (Section 3.9)
City of San Marcos. 2021. 2021-2029 Housing Element, Adopted July 13. https://www.san- marcos.net/departments/development-services/general-plan/housing-element. Accessed March 8 , 2024.
Department of Finance, California (DOF). 2023. E -5 Population and Housing Estimates For Cities, Counties, and State, 2020-2023. https://dof.ca.gov/forecasting/demographics/estimates/e-5- population-and-housing-estimates-for-cities-counties-and-the-state-2020-2023/. Accessed December 15, 2023.
San Diego Association of Governments (SANDAG). 2022. 2050 Series 14 Regional Growth Forecast for City of San Marcos and San Diego Region. August 11. https://datasurfer.sandag.org/ . Accessed January 9, 2023.
Public Services (Section 3.10)
California State University San Marcos ( CSUSM). 2023 . Borrowing Books and Media. https://biblio.csusm.edu/content/borrowing-policies-books-and-media. Accessed November 7.
City of San Marcos. 2012a. City of San Marcos General Plan. Parks, Recreation and Community Health Element. Adopted February 14. https://www.san -marcos.net/home/showpublisheddocument/8477 /636573113841930000. Accessed January 25, 2024.
City of San Marcos. 2012b. San Marcos General Plan EIR. Adopted February 14.
City of San Marcos. 2024 . Fire Department Overview. https://www.san-marcos.net/depart ments/public-safety/fire-department/department-overview. Accessed January 25, 2024.
Palomar College. 2023. Library Borrowing Privileges. https://www.palomar.edu/library/library- borrowing-privileges/. Accessed January 25, 2024
San Diego County Library. 2024. About the Library. https://www.sdcl.org/about/. Accessed February 6, 2024.
San Diego County Sheriff’s Department ( SDCSD). 2024 . San Marcos Station. https:// www.sdsheriff.gov/Home/Components/FacilityDirectory/FacilityDirectory/40/. Accessed February 7, 2024.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-7
San Marcos Unified School District (SMUSD). 2023 . Residential and Commercial Developer Fees. https://www.smusd.org/departments/facilities_planning_and_development/residential_and_comm ercial_developer_fee_summary. Accessed November 7, 2023.
San Marcos Unified School District (SMUSD). 2024a. SMUSD Fast Facts. https://www.smusd.org/ about_us/district_overview. Accessed January 25, 2024.
San Marcos Unified School District (SMUSD). 2024b. Armorlite Lofts Project- San Marcos E-Mail from Aaron Reyes, Administrative Analyst, SMUSD. February 13.
Transportation (Section 3.11)
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November . https://www.san- marcos.net/home/showpublisheddocument?id=25036. Accessed March 8, 2024.
City of San Marcos. 2024. Active Transportation Plan. June.
Linscott Law & Greenspan (LLG). 202 4a. Local Transportation Analysis: Armorlite Lofts, San Marcos California. November 7.
Linscott Law & Greenspan (LLG). 202 4b. Vehicle Miles Traveled Study: Armorlite Lofts, San Marcos California. November 7.
Tribal Cultural Resources (Section 3.12)
ASM Affiliates (ASM). 2024. Archaeological Survey Report for Armorlite Lofts Project, San Marcos, California. July.
Gallegos & Associates. 2002. Data Recovery Program for Pacbell Site CA-SDI -5633, San Marcos, California.
Utilities and Service Systems (Section 3.13)
California Department of Resources Recycling and Recovery ( CalRecycle). 2019a. SWIS Facility/Site Activity Details: Escondido Resource Recovery (37 -AA-0906). https://www2.calrecycle.ca.gov/Solid Waste/SiteActivity/Details/1830?siteID=2903. Accessed May 16, 2024.
California Department of Resources Recycling and Recovery (CalRecycle) . 2019b. Estimated Solid Waste Generation Rates. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates.
Accessed May 16, 2024.
California Department of Resources Recycling and Recovery ( CalRecycle). 2022. Jurisdiction Diversion/ Disposal Rate Summary . https://www2.calrecycle.ca.gov/LGCentral/Diversion Program/JurisdictionDiversionPost2006. Accessed October 16, 2023.
California Department of Resources Recycling and Recovery ( CalRecycle). 2024 . Mandatory Commercial Organics Recycling.
https://calrecycle.ca.gov/recycle/commercial/organics/https://www2.calrecycle.ca.gov/LGCentral/ DiversionProgram/JurisdictionDiversionPost2006. Accessed November 5, 2024.
City of San Marcos 2012. Land Use and Community Design Element, City of San Marcos General Plan. https://www.san-marcos.net/work/economic-development/general-plan. Accessed May 16, 2023.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-8
County of San Diego. 2005 . Integrated Waste Management Plan Countywide Siting Element.
September. https://www.sandiegocounty.gov/content/dam/sdc/common_components/images/dpw /recyclingpdfs/2005_sitingelement.pdf. Accessed May 16, 2023.
County of San Diego. 2022. Five-Year Review Report of the Countywide Integrated Waste Management Plan. June.
https://www.sandiegocounty.gov/content/dam/sdc/dpw/SOLID_WASTE_PLANNING_and_RE CYCLING/Files/2022%20Five-Year%20Review.pdf. Accessed May 16, 2023.
Metropolitan Water District of Southern California (MWD). 2021. 2020 Urban Water Management Plan (UWMP). June. https://www.mwdh2o.com/media/21641/2020-urban-water-management-plan-june- 2021.pdf. Accessed May 16, 2023.
San Diego County Water Authority ( SDCWA). 2021. 2020 Urban Water Management Plan (UWMP).
March. https://www.sdcwa.org/wp-content/uploads/2021/03/Draft-2020-UWMP.pdf. Accessed May 16, 2023.
San Diego Gas & Electric (SDG&E). 2024. About Us. https://www.sdge.com/more -information/our- company/about-us. Accessed March 6, 2024.
Vallecitos Water District ( VWD). 2018. 2018 Water, Wastewater and Recycled Water Master Plan.
October 4. https://www.vwd.org/home/showpublisheddocument/10656/636752049380230000.
Accessed May 16, 2023.
Vallecitos Water District (VWD). 2023. Armorlite Lofts Water and Sewer Study, Work Order #280233, Final Technical Memorandum, prepared by Elizabeth Lopez and Ingrid Stichter. December 12.
Alternatives (Section 4.0)
City of San Marcos. 2012. City of San Marcos General Plan, Land Use and Community Design Element.
Adopted February 14. https://www.san -marcos.net/home/showpublisheddocument/8480/ 636570701878000000. Accessed August 8, 2024.
San Diego Association of Governments (SANDAG). 2024. San Diego Region SB743 VMT Maps. https://www.arcgis.com/apps/webappviewer/index.html?id=5b4af92bc0dd4b7babbce21a742340 2a. Accessed August 8, 2024.
Environmental Effects Found Not to be Significant (Section 5.0) ASM. 2024. Archaeological Survey Report for Armorlite Lofts Project, San Marcos, California. July.
California Department of Forestry and Fire Protection (CAL FIRE). 2009. Fire Hazard Severity Zones, San Marcos. https://osfm.fire.ca.gov/what -we-do/community-wildfire-preparedness-and-mitigation/ fire-hazard-severity-zones. Accessed February 7, 2024.
California Department of Forestry and Fire Protection (CAL FIRE). 2022. Very High Fire Hazard Severity Zone in State Responsibility Areas (SRA).
https://osfm.fire.ca.gov/media/dqfbrtl1/fhsz_county_sra_11x17_2022_sandiego_ada.pdf.
Accessed February 27, 2024.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-9
California Department of Transportation (Caltrans). 2019. Officially Designated State Scenic Highways. http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/index.htm. Accessed February 27, 2024.
City of San Marcos. 2012. General Plan. Adopted February 14. http://www.san -marcos.net/ work/economic-development/general-plan. Accessed February 27, 2024.
City of San Marcos. 2023. City of San Marcos BMP Design Manual. February. https://www.san - marcos.net/home/showpublisheddocument/27192/638114580843700000. Accessed February 27, 2024.
County of San Diego. 2009 . Guidelines for Determining Significance Paleontological Resources.
January 15. https://www.sandiegocounty.gov/dplu/docs/Paleo-Guidelines.pdf. Accessed February 27, 2024.
Department of Toxic Substances Control (DTSC). 2023. EnviroStor Hazardous Waste and Substance Site List (Coretese).
https://www.envirostor.dtsc.ca.gov/public/search?cmd=search&reporttype=CORTESE&site_type=CS ITES,FUDS&status=ACT,BKLG,COM&reporttitle=HAZARDOUS+WASTE+AND+SUBSTANCES+SITE+LIS T+%28CORTESE%29. Accessed September 14, 2023.
Dudek. 2025 2024. Biological Resources Technical Report for the Armorlite Lofts. March October.
Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0793G . https://msc.fema.gov/portal/search. Accessed September 14, 2023.
GeoTek, Inc. 2023a. Due Diligence Environmental Review. A Portion of APN 219-162-57-00, 225 North Las Posas Road, San Marcos, California. January 26.
GeoTek, Inc. 2023b . Preliminary Geotechnical Evaluation for Eastern Portion of 225 N. Las Posas Road, San Marcos, California. August 10.
GeoTek, Inc. 2023c, Statement of Clarification Regarding Suspected UST, A Portion of APN 219-162- 57-00, 225 North Las Posas Road, San Marcos, California. October 5.
Latitude 33. 2024a. Drainage Study. Armorlite Lofts, Armorlite Drive, San Marcos, California 92069.
October 23.
Latitude 33. 2024 b. Priority Development Project (PDP) Storm Water Quality Management Plan (SWQMP) for Armorlite Lofts, Permit SP-23-0001. October 22.
San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan. January 25. Amended March 4, 2010 and December 1, 2011. https://www.lee- associates.com/elee/sandiego/LeeLandTeam/Ponto/McClellan-Palomar_ALUCP_20111.pdf.
Accessed February 27, 2024.
Stantec. 2021a. Phase I Environmental Site Assessment. 225 North Las Posas Road, San Marcos, California, 92069. February 1.
Stantec. 2021b. Phase II Environmental Site Assessment. 225 North Las Posas Road, San Marcos, California, 92069. March 23.
7.0 References
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 7-10
State Water Resources Control Board ( SWRCB). 2022. California 2020 -2022 Integrated Report (303(d) List/305(b) Report). State Water Board Approval January 19. U.S EPA Approval May 11. https://www.waterboards.ca.gov/water_issues/programs/water_quality_assessment/. Accessed October 16, 2023.
Other CEQA Considerations (Section 6.0)
City of San Marcos. 2021. 2021-2029 Housing Element. July 31. https://www.san-marcos.net/ home/showpublisheddocument/25740/637689416879030000. Accessed July 15, 2024.
San Diego Association of Governments (SANDAG). 2022. 2050 Series 14 Regional Growth Forecast for City of San Marcos and San Diego Region. August 11. https://datasurfer.sandag.org/ . Accessed January 9, 2023.
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 8-1
8.0 List of Preparers
City of San Marcos (Lead Agency)
Sean del Solar, Senior Planner
Bradley Holder, PE, CFM, Associate Civil Engineer – Land Development Kyrenne Chua, PE, MPA, Senior Civil Engineer
Environmental Impact Report
Sophia Mitchell & Associates, LLC
Sophia Habl Mitchell, LEED AP, Project Manager
Melyssa Sheeran, Senior Environmental Consultant
Air Quality, Energy, Greenhouse Gas, and Noise Reports
LDN Consulting
Jeremy Louden, Principal
Archeological Resources Inventory
ASM Affiliates
Shelby Castells, M.A., RPA, Principal Investigator
Michelle Hamilton, Associate Archaeologist and Field Director Terrence Luévano, M.A., RPA, Associate Archaeologist
Biological Resources Report, Rare Plant Surveys, CAGN Surveys and Aquatic Resource Assessment Dudek
Kamarul Muri, Senior Biologist
Shana Carey, Biologist
Callie Ford, Biologist
Kathleen Dayton, Biologist
Brock Ortega, Biologist
Geotechnical Investigation
GeoTek, Inc.
Christopher D. Livesey, RCE, Project Engineer, Vice President Hazardous Materials Assessments
Phase I and Phase II Environmental Site Assessments
Stantec Consulting Services
Jennifer Alvarado, Project Scientist
Deborah Hernandez, Geologic Staff
Alicia Jansen, Associate Scientist
Kyle Emerson, PG, CEG, Managing Principal Geologist
Due Diligence Environmental Review
Geotek Inc.
Christopher D. Livesey, CEG, Vice President
Anna M. Scott, Project Geologist
8.0 Preparers
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 8-2
Stormwater Quality Management Plan/Hydrology Report
Latitude 33 Planning & Engineering
Nick Psyhogios, RCE
Transportation Analysis, Local Transportation Analysis and Vehicle Miles Traveled Reports Linscott, Law & Greenspan Engineers
Renald Espiritu, Transportation Engineer II
John Boarman, PE, Principal