San Marcos City Council
June 24, 2025

ATTACHMENT E

ENVIRONMENTAL IMPACT REPORT
(EIR) 24-003
Armorlite Lofts Specific Plan
Final Environmental Impact Report
SCH No. 2024020372

SP-23-0001/ GPA23-0002 /R23-0001/ SDP23-0003/ CUP23-0002

Prepared for:

City of San Marcos
Planning Division
1 Civic Center Drive
San Marcos, CA 92069
Contact: Sean del Solar, Senior Planner

Prepared by:

Sophia Mitchell & Associates
P.O. Box 1700
Gualala, CA 95445
Contact: Sophia Habl Mitchell

April 2025

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0.1 INTRODUCTION AND SUMMARY
The applicant, Las Posas Ventures LLC, is proposing to develop 165 apartment units, 5,600 square feet (s.f.) of commercial use and associated common and private open space on a 2.44 acre site located on Armorlite Drive in the City of San Marcos.

The project applicant is requesting the following discretionary approvals from the City to allow for development of the proposed project:
• Specific Plan (SP23 -0001) – The Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan. The Specific Plan would be required to be reviewed and approved concurrently with the Multi-Family Site Development Plan application.
• General Plan Amendment (GPA23-0002) – A General Plan Amendment would be required to change the existing Public/Institutional (PI) designation to Specific Plan Area (SPA). • Rezone (R22-0001) - A rezone would be required to change the existing Public-Institutional (P- I) zoning to Specific Plan Area (SPA).
• Site Development Plan (SDP23-0003) - The Site Development Plan approval would be required to construct 165 apartment units and 5,600 s.f. of commercial and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Conditional Use Permit (CUP23-0002) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

This Final Environmental Impact Report (EIR) (SCH No. 2024020372) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.), CEQA Guidelines (California Administrative Code Section 15000 et seq.), and the City of San Marcos CEQA procedures. The City of San Marcos is the Lead Agency under CEQA.

According to CEQA Guidelines Section 15132, the Final EIR shall consist of the following:
a) The Draft EIR or a revision of the Draft;
b) Comments and recommendations received on the Draft EIR either verbatim or in summary; c) A list of persons, organizations, and public agencies commenting on the Draft EIR; d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and
e) Any other information added by the Lead Agency.

In accordance with these requirements, the Armorlite Lofts EIR is comprised of the following:
• Draft Environmental Impact Report, Armorlite Lofts Specific Plan (January 2025)

• This Final EIR document, April 2025, that incorporates the information required by Section 15132

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Format of the Final EIR
This document is organized as follows:

Section 0.1 Introduction
This section describes CEQA requirements and content of this Final EIR.

Section 0.2 Corrections and Additions
This section provides a list of those revisions made to the Draft EIR text as a result of comments received and/or minor errors and omissions discovered subsequent to release of the Draft EIR for public review. None of these revisions would result in the need to recirculate the Draft EIR.

Section 0.3 Responses to Comment Letters Received on the Draft EIR This section provides copies of the comment letters received and individual responses to written comments. In accordance with Public Resources Code 21092.5, copies of the written proposed responses to public agencies will be forwarded to the agencies at least 10 days prior to certifying an EIR. The responses conform to the legal standards established for response to comments on Draft EIRs.

Section 0.4 Mitigation Monitoring and Reporting Program This section includes the Mitigation Monitoring and Reporting Program (MMRP) which identified the mitigation measures, timing and responsibility for implementation of the measures.

Section 0.5 CEQANet Posting
This section contains the proof of posting of the Draft EIR for a 45-day public review on the State Clearinghouse CEQANet portal.

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0.2 CORRECTIONS AND ADDITIONS
The following Sections 0.2.1 and 0.2.2 contain a summary of revisions to information included in the Draft EIR ( January 2025). These revisions were made based upon comment s received on the Draft EIR, which are discussed in Section 0.3, Response to Written Comment.

Given the nature of the changes associated with the document, the information added to the EIR does not meet the requirements for recirculation pursuant to Section 15088.5 of the State CEQA Guidelines.

Pursuant to Section 15088.5(a), a lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review. The term “information” can include changes in the project or environmental setting as well as additional data or other information. New information added to the EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation includes, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyze would clearly lessen environmental impacts of the project, by the projects’ proponents decline to adopt it.
(4) The draft EIR was so fundamentally flawed and basically inadequate and conclusionary in nature that meaningful public review was precluded.

Changes to the Draft EIR include the following:
• Change to biological resources mitigation measure MM -BIO-1b and MM -BIO-2c to address comments from the California Department of Fish and Wildlife.

• Change to a cultural resources mitigation measures based upon a comment from the San Diego County Archaeological Society.

In summary, the revisions made to the Draft EIR do not meet the requirements of Section 15088.5 of the CEQA Guidelines. The revisions do not result in a new significant impact being identified, nor do the revisions identify a substantial increase in the severity of an environmental impact. Further, a feasible project alternative or mitigation measure considerable different from others previously analyzed was not included in the revisions. Finally, the Draft EIR has adequately disclosed the potential impacts of the project and identified mitigation measures, where feasible to reduce the impacts to below a level of significance.

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0.2.1 DRAFT EIR CORRECTIONS AND ADDITIONS
Changes to the Draft EIR were made in response to comments received on the Final EIR. The new information clarifies information and refines mitigation measures that were requested by commenters on the Draft EIR. Text that has been added to the document appears in an underline format. Text that has been deleted appears with strikeout.

The table below identifies the changed EIR sections and accompanying page numbers in the Final EIR.

The revised Draft EIR is included following this Final EIR Introduction.

Final EIR Section Page/Table/Figure Change

1.0 – Executive Summary Page 1-1 (Table 1-1) – minor revision to BIO-1 impact.

2.0 – Project Description Page 2-13 – California Department of Fish and Wildlife (CDFW) noted as a Responsible Agency should the project require an Incidental Take Permit.

3.3 – Biological Resources Page 3.3-5 – Statement added that site falls within an area identified as a Vernal Pool Amendment area in the City’s Draft Subarea Plan.

based upon comments from CDFW.

Section 3.3.6 (Biological Resources Mitigation Measures) • Revised mitigation measures MM-BIO-1a for
clarification purposes.
• Revised mitigation measure MM-BIO-1b based upon
CDFW comment.
• Revised mitigation measure MM-BIO-2c based upon
CDFW comments.

section based upon CDFW comment.

3.4 – Cultural Resources Section 3.4.6 (Cultural Resources Mitigation Measures) Minor revisions to mitigation measures MM-CR-1b, and MM- CR-2 for clarification purposes.

3.12 – Tribal Cultural Resources Page 3.12-8 – Changed No Project/Reduced Footprint alternative to No Project Reduced Development Footprint alternative to be consistent with how this alternative is named in the rest of the document. The characteristics of the alternative and conclusions do not change.

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Final EIR Section Page/Table/Figure Change
Section 3.12.6 (Tribal Cultural Resources Mitigation
Measures)
• Revised mitigation measure MM-TCR-1 based upon a
comment from the San Diego County Archaeological
Society.
• Revised mitigation measure MM-TCR-9 to provide
clarification on timing for Land Acknowledgement
Statement.
• Minor revisions to mitigation measures MM-TCR-4
and MM-TCR-10 for clarification purposes.

4.0 – Alternatives Various pages: Changed No Project/Reduced Footprint alternative to No Project Reduced Development Footprint alternative to be consistent with how this alternative is named in the rest of the document. The characteristics of the alternative and conclusions do not change.

Appendix D – Biological Resources Report The biological resources report was updated to reflect comments from CDFW. The updated report is included as
Appendix D. References to the biology report have been
updated throughout the EIR to reflect the date of the updated report (March 2025).

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0.2.2 REVISED AND SUPPLEMENTAL MITIGATION

MEASURES
Based upon a comment letter from CDFW on the Draft EIR as well as minor corrections and clarifications, the following mitigation measures were revised. The following represents the modified mitigation measures, with changes shown in a strike out/underline format:

Revised Mitigation Measures
MM-BIO-1a Breeding Season Avoidance. To the extent feasible, the applicant/developer shall only remove vegetation The removal of coastal sage scrub from the project impact footprint shall only occur from between September 1 through February 14 to avoid the bird breeding season. Further, to the maximum extent practicable, grading activities associated with construction of the project shall occur September 1 through February 14 to avoid the breeding season. If proje ct construction must occur during the breedi ng season, mitigation measure MM -BIO-1b shall be implemented.

MM-BIO-1b Nesting Bird Survey(s). Take of birds protected under the Migratory Bird Treaty Act and California Fish and Game Code shall be avoided during the nesting season. To avoid any direct impacts on raptors and/or any migratory birds protected under the Migratory Bird Treaty Act and California Fish and Game Code, removal of habitat that supports active nests on the proposed area of disturbance shall occur outside of the nesting season for these species (February 15 through August 31, annually).

If cons truction occurs during the nesting season, pre -construction nesting bird surveys must be conducted within 72 hours of construction -related activities. If nesting birds are detected by the biologist, the following buffers shall be established: (1) no work within 300 feet of a non-listed nesting migratory bird nest, and (2) no work within 500 feet of a listed bird or raptor nest. However, the biologist may reduce these buffer widths depending on site -specific conditions (e.g., the width and type of screening vegetation between the nest and proposed activity) or the existing ambient level of activity (e.g., existing level of human activity within the buffer distance) in conjunction with consultation with the City of San Marcos. If construction must take place w ithin the recommended buffer widths above, the project applicant shall contact the City of San Marcos and wildlife agencies (United States Fish and Wildlife Service [USFWS] and California Department of Fish and Wildlife [CDFW] to determine the appropriate buffer.

Additionally, take of a state candidate species is prohibited under the California Endangered Special Act (CESA). While Crotch’s bumble bee has low potential to occur on site, the pre -construction surveys for Crotch’s bumble bee shall be conducted within the construction footprint prior to the start of ground -disturbing activities occurring during the Crotch’s bumble bee nesting period (February 1 through October 31). The survey shall ensure that no nests for Crotch’s bumble bee are located within the const ruction area. The pre -construction survey shall include focused surveys, which shall be based on recommendations described in the Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species, released by CDFW on June 6, 2023, or the most current version at the time of construction.

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The surveys shall be performed by a biologist with expertise in surveying for bumble bees and include at least three (3) survey passes that are not on sequential days or in the same week, preferably spaced two ( 2) to four (4) weeks apart. Surveys may occur between 1 hour after sunrise and 2 hours before sunset. Surveys shall not be conducted during wet conditions (e.g., foggy, raining, or drizzling), and surveyors shall wait at least one (1) hour following rain. Optimal surveys are when there are sunny to partly sunny skies and a temperature greater than 60°F.

Surveys may be conducted earlier if other bees or butterflies are flying. Surveys shall not be conducted when it is windy (i.e., sustained winds greater than 8 miles per hour). Within non-developed habitats, the biologist shall look for nest resources suitable for bumble bee use. Ensuring that all nest resources receive 100% visual coverage, the biologist shall watch the nest resources for up to five (5) minutes, looking for exiting or entering worker bumble bees. Worker bees should arrive and exit an active nest site with frequency, such that their presence would be apparent after five (5) minutes of observation. If a bumble bee worker is detected, then a representative shall be identified to species. Biologists should be able to view several burrows at one time to sufficiently determine if bees are entering/exiting them, depending on their proximity to one (1) another. It is up to the discretion of the biologist regarding the actual survey viewshed limits from the chosen vantage point to determine which would provide 100% visual coverage; this could include a 30- to 50 -foot-wide area. If a nest is suspected, the surveyor can block the entrance of the possible nest with a sterile vial or jar until nest activity is confirmed (no longer than 30 minutes).

Identification shall include trained biologists netting/capturing the representative bumble bee in appropriate insect nets, per the protocol in U.S. National Protocol Framework for the Inventory and Monitoring of Bees. The bee shall be placed in a clear container for observation and photographic documentation, if able. The bee shall be photographed using a macro lens from various angles to ensure recordation of key identifying characteristics. If bumble bee -identifying characteristics cannot be adequately captured in the container due to movement, the container shall be placed in a cooler with ice until the bumble bee becomes inactive (generally within 15 minutes). Once inert, the bumble bee shall be removed from the container and placed on a white sheet of paper or card for examination and photographic documentation. The bumble bee shall be released into the same area from which it was captured upon completion of identification.

Based on implementation of this method on a variety of other bumble bee species, they become active shortly after removal from the cold environment, so photography must be performed quickly.

If Crotch’s bumble bee nests are not detected, no further mitigation is required.

The mere presence of foraging Crotch’s bumble bees shall not require implementation of additional mitigation measures because they can forage up to 10 kilometers from their nests. If nest resources occupied by Crotch’s bumble bee are detected within the project construction area, no construction activities shall occur within 100 feet of the nest, or as determined by a qualified biologist through evaluation of topographic featu res or distribution of floral resources. The nest resources shall be avoided for the duration of the Crotch’s bumble bee nesting period (February 1 through October 31). Outside of the nesting season, it is assumed that no live individuals would be present within the nest because the Armorlite Lofts Specific Plan April 2025
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daughter queens (gynes) usually leave by September, and all other individuals (original queen, workers, males) die. The gyne is highly mobile and can independently disperse to outside of the construction footprint to surrounding open space areas that support suitable hibernacula resources.

A written survey report shall be submitted to the City Planning Division Director within 30 days of the last survey pass. The report shall include survey methods, weather conditions, and survey results, including a list of insect species observed and a fig ure showing the locations of any Crotch’s bumble bee nest sites or individuals observed. The survey report shall include the qualifications/resumes of the surveyor(s) and approved biologist(s) for identification of photo vouchers and a detailed habitat ass essment. If Crotch’s bumble bee nests are observed, the survey report shall also include recommendations for avoidance, and the location information shall be submitted to the California Natural Diversity Database at the time of, or prior to, submittal of the survey report.

If Crotch’s bumble bee is detected within the project site, the applicant/developer shall consult with CDFW regarding the need to obtain an Incidental Take Permit.

Any measures determined to be necessary through the Incidental Take Permit process to offset impacts to Crotch’s bumble bee may supersede measures provided in this document.

In the event that an Incidental Take Permit is needed, mitigation for direct impacts to Crotch’s bumble bee shall be fulfilled through compensatory mitigation at a minimum 1:1 nesting habitat replacement of equal or better functions and values to those imp acted by the project, or as otherwise determined through the Incidental Take Permit process. Mitigation shall be accomplished through on -site preservation of suitable habitat and/or in accordance with CDFW guidance for off- site locations. The funding sourc e shall be in the form of an endowment to help the qualified natural lands management entity that is ultimately selected to hold the conservation easement(s). The endowment amount shall be established following the completion of a project-specific Property Analysis Record to calculate the costs of in -perpetuity land management. The Property Analysis Record shall take into account all management activities required in the Incidental Take Permit to fulfill the requirements of the conservation easement.

MM-BIO-2c Biological Monitor Requirements and Duties. A qualified biologist shall be on site per the discretion of the City during initial clearing/grubbing and during grading to ensure compliance with all project -imposed mitigation measures. The biologist shall be available during pre -construction and constr uction phases to review grading plans, address protection of potential biological resources, monitor ongoing work, and maintain communications with the project’s engineer to ensure that any issues are appropriately and lawfully managed.

The qualified biological monitor shall also be responsible for the following duties:

1. Periodically monitor the work area to ensure that work activities do not generate excessive amounts of dust.

2. Halt work, if necessary, and confer with the USFWS, CDFW, U.S. Fish and Wildlife Service, and City of San Marcos to ensure the proper implementation Armorlite Lofts Specific Plan April 2025
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of species and habitat protection measures. The biologist shall report any violation to USFWS and the City within 24 hours of its occurrence.

3. Submit a final report to the City within 60 days of project completion that includes the following:(1) as -built construction drawings for grading with an overlay of any active nests; (2) photographs of habitat areas during pre - construction and post-construction conditions; and (3) other relevant summary information documenting that authorized impacts were not exceeded and that general compliance with the avoidance/minimization provisions were achieved.

MM-CR-1b Unanticipated Discovery Procedures: The Qualified Archaeologist may temporarily halt or divert ground disturbing activities if previously unknown archaeological resources are discovered during construction activities. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be associated with Native American culture, it will be conside red a tribal cultural resource and subject to mitigation measures MM-TCR-4 and MM-TCR-5. Non-Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource (subject to MM-TCR-4) and a potentially significant archaeological resource that is associated with Native American culture , then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.

Isolates and clearly non-significant archaeological resources (as determined by the Qualified Archaeologist) will be minimally documented in the field. All unearthed archaeological resources will be collected, temporarily stored in a secure location until analysis and documentation are complete. If a determination is made that the archaeological resources are considered potentially significant by the Qualified Archaeologist, then an adequate artifact sample to address research avenues previously identified for sites in the area will be collected using professional archaeological collection methods.

In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections.

The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project c onstruction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the curation facility that the curation has been completed.

MM-CR-2 Human Remains : As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby Armorlite Lofts Specific Plan April 2025
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area reasonably suspected to overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code Section 5097.98.

If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two (2) business working days of being notified if the remains are subject to their authority. If the Medical Examiner recognizes the remains to be Native American, and not under their jurisdiction, then they shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

If suspected Native American remains are discovered, the remains shall be kept in situ (in place) until after the Medical Examiner makes its determination and notifications, and until after the Most Likely Descendent is identified, at which time the archae ological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public.

According to California Health and Safety Code, six (6) or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a location free from future disturb ance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

MM-TCR-1 Monitoring Agreement : Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall extend the invitation to enter into a Monitoring Agreement with the Rincon Band of Luiseño Indians and the San Luis Rey Band of Luiseño Indians (Tribes). The purpose of the Monitoring Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the Tribes for the monitoring for Native American human remains, funerary objects, cultural and/or religious landscapes, ceremonial items, traditional gathering areas, and other tribal cultural resources. Such resources may be located within and/or discovered during ground disturbing and/or construction activities for the proposed project, including any additional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities. In the event that either or both tribes choose not to enter into an agreement or fail to respond to the offer, the City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

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Any project -specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the Tribal requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation. The land owner shall relinquish ownership of all non -burial related tribal cultural resources collected during construction monitoring and from any previous archaeological studies or excavations on the project site to the Tribes for proper treatment and disposition per the Monitoring Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The requirement and timing of such release of ownership, and the recipient thereof, shall be reflected in the Monitoring Agreement. Additionally, all non-tribal artifacts collected by the archaeologist shall also be subject to curation.

MM TCR-2 Controlled Grading. The area illustrated on the confidential exhibit attached to the grading plans shall be subject to controlled grading. Under the observation of a tribal monitor and qualified archaeologist, the contractor shall use either a small piece of equipment or obse rve the removal of soil by a backhoe equipped with a flat-edge bucket to excavate soil using shallow cuts made in approximately one - foot lifts. The grading equipment will push the shallow cuts of soil to the outside of the cult ural deposit area and random samples may be screened to ensure adequate detection of any cultural materials that may be present. In the event that cultural materials or human remains are exposed, the procedures for unanticipated discoveries in mitigation measure MM-TCR-4 shall apply. Controlled grading shall continue to a depth of 30 centimeters below the depth of any recorded artifacts, suggesting an end to the potential for cultural deposits, or when restrictive layers or non-cultural formational soils are encountered that predate any human occupation of this location, as determined by the qualified professional archaeologist, in consultation with the tribal monitor. Once the identified depth has been reached, the controlled grading process will be terminated and mass grading may proceed, subject to review and approval by the City.

MM-TCR-4 Unanticipated Discovery Procedures: Native American monitors may temporarily halt or divert ground disturbing activities if previously unknown tribal cultural resources are discovered during construction activities. Ground disturbing activities shall be temporarily directed away from the ar ea of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be not associated with Native American culture, it will be subje ct to mitigation measure MM-CR-1b. Native American tribal cultural resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture (subject to mitigation measure MM-CR-1b), then the Qualified Archaeologist, Tribes, monitors, and City shall coordinate on appropriate treatment.

All unearthed tribal cultural resources will be collected, temporarily stored in a secure location, and repatriated according to the consulting tribes, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

If a determination is made that the tribal cultural resources are considered potentially significant by the Tribe and the Native American monitor, then the City Armorlite Lofts Specific Plan April 2025
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and the Tribe shall determine, in consultation with the Applicant/Owner, the culturally appropriate treatment of those resources.

All sacred sites and significant tribal cultural resources encountered within the project area shall be avoided and preserved as the preferred mitigation. If avoidance of the resource is determined to be infeasible by the City as the Lead Agency (as defined by the California Environmental Quality Act [CEQA]) , then the City shall require additional culturally appropriate mitigation to address the negative impact to the resource. The Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation. Any cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site and repatriated according to the terms of the Monitoring Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The removal of any artifacts from the project site will be inventoried with oversight by the Native American monitor. Any testing, taking of photos or 3D prints are prohibited, unless all monitoring tribes give prior written approval.

MM-TCR-5 Human Remains : As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. The procedures in mitigation measure MM-CR-2 shall apply.

MM-TCR-6 Reburial: Prior to the approval of grading plans, the Applicant shall designate a reburial location onsite and note the location as excluded from construction - related activity on grading plans. The reburial location shall be used to rebury any cultural materials enc ountered during monitoring, and to rebury existing collections from the previous data recovery effort. Following the completion of all ground disturbing activity and reburial of all materials and before the issuance of a Certificate of Occupancy, the Applicant shall file a deed restriction on the parcel that protects the reburial location from future disturbance and provide a copy to the City. The exhibit for the deed restriction and purpose of it shall be kept confidential and out of the public record.

MM-TCR-9 Land Acknowledgement Statement: The project applicant Applicant/Owner shall develop and post a Land Acknowledgement Statement inside a common area of the development. The statement shall be developed in coordination with Tr ibes and address the acknowledgement that the project is on the ancestral lands of culturally affiliated tribes that have been the original and ongoing stewards of the land. In the event that consulting tribes do not respond to the offer within 30 days of receipt, then the City w ill deem this mitigation measure satisfied provided that the offer was extended and documented in accordance with this measure. The location of the Land Acknowledgement Statement shall be noted on elevation and/or plan view drawings for the common area of the development.

MM-TCR-10 Project-Specific Ethnographic Synthesis: The Applicant shall fund the preparation of a project-specific ethnographic synthesis, not to exceed what is described in the confidential proposal provided by the Rincon Band of Luiseño Indians dated August Armorlite Lofts Specific Plan April 2025
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27, 2024. No later than 30 days after the final p roject approval, the Applicant/Owner shall extend a written offer to the Rincon Band of Luiseño Indians to enter into an agreement with their ethnographer to conduct and prepare the ethnographic synthesis in accordance with the aforementioned proposal . In the event of a dispute between the parties in entering into the agreement for the ethnographic synthesis, and after a good faith and reasonable effort, the City shall serve as the final arbiter. The City wil l determine the scope and content of an ethnographic synthesis in that event.

The synthesis will draw from oral histories, elder knowledge, and other sources of confidential Indigenous knowledge that relate to the tribal cultural resource affected by the proposed project. The ethnographer shall be afforded up to 90 days following funding of the ethnography to carry out any field visits with appropriate tribal representatives. After 90 days, or sooner if the ethnographer completed its field studies, the Applicant /Owner shall be permitted to proceed with ground disturbing activities an d construction of the project while non -field-based data gathering, such as ethnographic interviews of informants and review of tribal documents, is being carried out. Upon completion, a public (redacted) version of the ethnographic synthesis shall be subm itted to the California Historical Resources Information System and the City. The final non -redacted study shall belong to the Rincon Band of Luiseño Indians.

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0.3 RESPONSE TO WRITTEN COMMENTS
Section 3.0 contains responses to all comment letters received on the January 2025 Draft Environmental Impact Report (Draft EIR). A total of four comment letters were received during the comment period, which ran from January 10, 2025 to February 24 , 202 5. A response to each comment letter follows this introduction. A copy of each letter with bracketed comment numbers on the right margin is followed by the response for each comment as indexed in the letter.

Letter Number Commenter Date
1 California Department of Fish and Wildlife 2/24/25
2 California Public Utilities Commission 2/3/25
3 San Diego County Archaeological Society 2/24/25
4 Lozeau Drury on behalf of Supporters Alliance for
Environmental Responsibility (SAFER)
1/15/25
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1-1 1-1
LETTER 1
1-2
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1-2
Cont.
1-3
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1-3
Cont.
1-4

1-5

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1-5
Cont.

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1-5
Cont.

1-6

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1-6
Cont.

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1-7
1-8
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1-9
1-10
1-11
1-12
1-13
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1-14
1-15
1-16
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1-16
Cont.
1-17
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1-17
Cont.

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1-18
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1-18
Cont.

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1-18
Cont.

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1-19
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Letter 1
California Department of Fish and Wildlife
1-1 This comment provides opening remarks. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. (Los Angeles Conservancy v. City of W. Hollywood (2017) 18 Cal.App5th 1031; Browning- Ferris Indus. v. City Council (1986) 181 Cal.App.3d 852.). 1-2 This comment identifies California Department of Fish and Wildlife’s (CDFW) role as both a Trustee Agency and a Responsible Agency (as defined by the California Environmental Quality Act [CEQA]) for the project. Page 2-13 of the draft environmental impacts report (Draft EIR) notes CDFW as a Trustee Agency. If an Incidental Take Permit is required, CDFW would also be a Responsible Agency for the project. This has been noted on page 2-13 of the EIR. 1-3 This comment provides a summary of the project’s objective, location, biological setting and project history. It does not raise any specific environmental issues. 1-4 This comment provides an introduction to specific recommendations and comments for the project.
1-5 The comment states that the project may impact suitable nesting and foraging habitat for Crotch’s bumble bee, a candidate species for California Endangered Species Act (CESA) listing. The Draft EIR and biological technical report (BTR) do not include any discussion of Crotch’s bumble bee or propose species-specific mitigation measure.

As identified by CDFW, the Crotch’s bumble bee is a state of California candidate for listing as an endangered species (CDFW 2023). This species prefers open grassland and shrub habitats that support populations of nectar plants such as snapdragon (Antirrhinum spp.), phacelia (Phacelia sp.), clarkia (Clarkia spp.), bush poppy (Dendromecon rigida), California poppy (Eschscholzia californica), and buckwheat (Eriogonum spp.). In California, its distribution is exclusive to coastal areas from San Diego to Redding.

As it relates to the project, Crotch’s bumble bee has a low potential to occur within the approximately 2 acres of coastal sage scrub habitat within the project site (as described in Appendix D to the BTR). The project site is located within an urbanized setting and is surrounded by commercial and residential developments on all sides. Additionally, although the site does contain coastal sage scrub habitat, this habitat is largely depauperate, shows evidence of anthropogenic disturbance and historic grading activities, and lacks many of the diverse floral resources that this species prefers such as milkweeds, lupines, medics, phacelias, clarkias, poppies, and larkspurs. Furthermore, the closest known records of this species occur in the Lake Calavera area, approximately 5.5 miles northwest from the site (CDFW 2025). Therefore, the project site is not likely to support foraging or nesting of this species.

Despite the low potential for occurrence, to ensure that the project does not result in take of Crotch’s bumble bee, mitigation measure MM-BIO-6 has been updated to include pre- construction surveys that shall be conducted within the project’s construction footprint prior to the start of ground-disturbing construction activities occurring during the Crotch’s bumble Armorlite Lofts Specific Plan April 2025
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bee nesting period (February 1 through October 31). The survey shall ensure that no nests for Crotch’s bumble bee are located within the project’s construction area. The pre- construction surveys shall include three focused surveys, which shall be based on recommendations described in the Survey Considerations for CESA Candidate Bumble Bee Species, released by the CDFW on June 6, 2023, or the most current version of the same at the time of construction. Focused surveys are not necessary prior to finalizing the CEQA document at this time.

Appendix D (Biological Resources Report) and Section 3.3, Biological Resources of the Draft EIR, have been updated to acknowledge that an Incidental Take Permit could be required if take of Crotch’s bumble bee cannot feasibly be avoided. The appropriate consultation and other steps described will be taken if Crotch’s bumble bee is detected during the preconstruction survey(s) to ensure avoidance and minimization of impacts to the species to the satisfaction of CDFW. In addition, it should be noted that per MM-BIO-6 of the Final EIR, the project will make every effort to avoid clearing vegetation from the site during the nesting bird season (defined as February 15 to August 31), which overlaps with Crotch’s bumble bee nesting period (February 1 through October 31). Although the potential for the species to occur onsite is low, the Biological Resources Report has been updated to include measures to minimize and/or mitigate potential impacts to Crotch’s bumble bee as described herein.

1-6 The comment states that the project may impact habitat for pocket mouse species, including the Dulzura pocket mouse and/or northwestern San Diego pocket mouse, both “Special Species of Concern” (SSC).

The Dulzura pocket mouse (Chaetodipus californicus femoralis) and northwestern San Diego pocket mouse (Chaetodipus fallax fallax) have a low potential to occur within the project site, as it is relatively small, isolated from larger undeveloped lands, and there was a notable lack of small mammal burrows observed over the course of numerous site visits conducted between 2021-2023. The project site is located within an urbanized setting surrounded by commercial and residential development and has likely been long subject to adverse edge effects, predation, and habitat fragmentation. Additionally, the site is bounded by North Las Posas Road, West Mission Road, Armorlite Drive, and the Inland Rail Trail, which are busy, well-traveled thoroughfares that can act as significant barriers to wildlife movement including ingress and egress of the project site.

Additionally, although the site contains coastal sage scrub vegetation, the available habitat is largely depauperate and shows evidence of anthropogenic disturbance and historic grading activities. Furthermore, the closest CNDDB record of the Dulzura pocket mouse to the project site is from 1961 in the present-day downtown Escondido area, approximately 6.75 miles to the southeast. The closest record of the northwestern San Diego pocket mouse to the site occurred in 1992 in the city of Carlsbad, approximately 4 miles to the southwest (CDFW 2025, Tremor et al. 2017). Therefore, there is a low potential for either species to occur as the project site is not likely to support them, and therefore the project is not expected to impact either species.

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1-7 The comment states that the City proposes mitigation ratios of 1:1 for Diegan coastal sage scrub and 0.5:1 for non-native grassland, which are consistent with the ratios established in the City’s Draft SAP; however, those ratios may not fully account for the ecological value and functional loss of these habitats.

The project will implement the mitigation ratio of 1:1 for Diegan coastal sage scrub and 0.5:1 for non-native grassland as proposed by the Draft SAP (which was never formally adopted by the City). There are no other additional mitigation ratios applicable to the project for these species. Compliance with regulations is a common and reasonable mitigation measure. (See e.g., Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal.App.4th 884; Tracy First v.

City of Tracy (2009) 177 Cal.App.4th 912.) Therefore, ratios in compliance with the City’s SAP is sufficient mitigation.

Considering the depauperate condition of the habitat on project site, the lack of sensitive species on site, its location in an urbanized setting surrounded by commercial and residential development, and the fact that the site has likely been long subject to adverse edge effects, predation, and habitat fragmentation, the relatively limited ecological value and function of the habitat on site does not warrant higher mitigation ratios than currently proposed. Higher mitigation ratios, as proposed by CDFW, are unlikely to result in the desired effects to ecological functions as identified in Comment 1-7.

1-8 The comment states that the Cumulative Impact Analysis in the Draft EIR is incomplete because the Draft EIR does not disclose the project site it within a Vernal Pool Amendment Area of the City’s Draft Subarea Plan, the EIR does not include Palomar Station as a cumulative project.

Site-specific studies determined that the project site does not support vernal pool resources, despite the area being located within a polygon that is identified as a Vernal Pool Major Amendment Area identified in Table 2.3-5 of the City’s Draft Subarea Plan. Section 6.2 of the project’s BTR (Dudek 2025) notes that the project site is identified as a Vernal Pool Major Amendment Area. Additionally, this disclosure was also added to the Final EIR on page

3.3-5 of the Biological Resources section as a text edit to fully address the comment.

The Palomar Station project referenced in this comment is a mixed-use residential development located adjacent to and south of the project site. The EIR for the project was certified in 2007 (SCH No. 2003081116) and has been fully built out. Merkel & Associates prepared a biological technical report for the Palomar Station project (dated December 23, 2005). The analysis concluded that the Palomar Station project would result in impacts to sensitive habitats (Diegan coastal sage scrub, valley needlegrass grasslands, nonnative grassland and Orcutt’s brodiaea) and could potentially impact sensitive species including Migratory Bird Treaty Act protected species and San Diego Fairy Shrimp. Potential indirect impacts and impacts to avian linkages were also identified. Mitigation was identified for all impacts and appropriate permits were secured from the regulatory agencies.

CEQA Guidelines refer to a cumulative impact as the combination of the project’s impacts with those of other projects causing “related impacts.” (CEQA Guidelines § 15130(a)(1).) The key question in considering whether other projects should have been included in the EIR’s Armorlite Lofts Specific Plan April 2025
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list of projects “is whether it was reasonable and practical to include the projects and whether, without their inclusion, the severity and significance of the cumulative impacts were reflected adequately.” (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692.) The Palomar Station project, while in close proximity, does not result in impacts that are related to the project. (Citizens to Preserve the Ojai v County of Ventura (1985) 176 Cal.App.3d 421; Concerned Citizens of S. Cent. L.A. v. Los Angeles Unified Sch. Dist. (1994) 24 Cal.App.4th 826 [cumulative analysis is complete if it excludes projects that are only de minimis contributor to related impacts].)
As discussed in response to comments 1-5 and 1-6, in terms of biological resources, the potential for Crotch’s bumble bee and both pocket mouse species to occur on site is low due to the site being located within an urbanized setting, surrounded by commercial and residential development, and the fact that it has likely been long subject to adverse edge effects, predation, and habitat fragmentation. Furthermore, the coastal sage scrub habitat is depauperate, does not support sensitive species, and provides a relatively low ecological value and function. The cumulative impact analysis for the project was complete. 1-9 The comment states that the Draft EIR indicates that Dudek conducted focused coastal California gnatcatcher surveys between 2022-2023, which were negative. The U.S. Fish and Wildlife Service (USFWS) typically requires updated surveys every two years for coastal California gnatcatcher. Depending on project timing, updated surveys may be needed. CDFW recommends further coordination with USFWS regarding coastal California gnatcatcher surveys.

Mitigation measure MM-BIO-5 states that the removal of coastal sage scrub, a habitat for the California gnatcatcher, from the project impact footprint shall only occur from September 1 through February 14 to avoid the gnatcatcher nesting season. Furthermore, MM-BIO-6 states that if construction occurs during the nesting season, pre-construction surveys must be conducted within 72 hours of construction-related activities. If nesting birds are detected by the biologist, the following buffers shall be established: (1) no work within 300 feet of a non- listed nesting migratory bird nest, and (2) no work within 500 feet of a listed bird or raptor nest.

Because no coastal California gnatcatchers were detected during the protocol surveys conducted in 2022/2023, combined with the implementation of MM-BIO-5 and MM-BIO-6, no impacts are expected to occur to coastal California gnatcatchers. 1-10 This comment addresses mitigation measures MM-BIO-2c, which addresses biological monitoring. The City has incorporated the edit requested in this comment, as shown in track changes on page 3.3-22 of the Final EIR. The revised mitigation measure, in a track changes format, is also provided below:

MM-BIO-2c Biological Monitor Requirements and Duties. A qualified biologist shall be on site per the discretion of the City during initial clearing/grubbing and during grading to ensure compliance with all project -imposed mitigation measures. The biologist shall be available during pre - construction and construction phases to review grading plans, address Armorlite Lofts Specific Plan April 2025
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protection of potential biological resources, monitor ongoing work, and maintain communications with the Project’s engineer to ensure that any issues are appropriately and lawfully managed.

The qualified biological monitor shall also be responsible for the following duties:

1. Periodically monitor the work area to ensure that work activities do not generate excessive amounts of dust.

2. Halt work, if necessary, and confer with the U.S. Fish and Wildlife Service, California Department of Fish and Wildlife, and City of San Marcos to ensure the proper implementation of species and habitat protection measures. The biologist shall report any violation to USFWS and the City within 24 hours of its occurrence.

3. Submit a final report to the City within 60 days of Project completion that includes the following:(1) as -built construction drawings for grading with an overlay of any active nests; (2) photographs of habitat areas during pre -construction and post - construction conditions; and (3) other relevant summary information documenting that authorized impacts were not exceeded and that general compliance with the
avoidance/minimization provisions were achieved.
1-11 This comment addresses the biological resources conclusion of the Draft EIR and proposes revisions. The City has incorporated the edits requested in this comment, as shown in track changes on page 3.3-22 of the Final EIR. The revised text, in a track changes format, is also provided below:

Based on the presence of suitable avian nesting habitat, pre -construction clearance surveys for nesting birds will would be conducted to ensure that no impacts on nesting birds that are afforded protection under the MBTA or the Fish and Game Code occur (see mitigation measures MM-BIO-1a and MM-BIO-1b). Mitigation measures MM-BIO- 1a and MM-BIO-1b require a preconstruction survey if construction is proposed during the nesting season. If nesting birds are found, avoidance measures would be implemented to minimize impacts. With the implementation of mitigation measure s MM-BIO-1a and MM -BIO-1b, direct impacts on nesting birds would be less than significant.
1-12 This comment indicates CDFW and USFWS’s (Wildlife Agencies) interest in participating in the implementation of mitigation measure MM-BIO-3. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-13 This comment addresses the CDFW recommended mitigation identified in the letter and the preparation of a mitigation monitoring and reporting program (MMRP). The MMRP is included in the Final EIR i n Section 0.4. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-14 This comment addresses contribution of environmental data to the California Natural Diversity Database (CNDDB). The project biologist will be responsible for submitting any required field Armorlite Lofts Specific Plan April 2025
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survey results to the CNDDB. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-15 This comment addresses the CDFW filing fees. The project applicant will pay the applicable filing fee at the time the Notice of Determination is filed with the County of San Diego Recorder’s Office. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-16 This comment p rovides closing remarks. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-17 This comment provides a list of references. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-18 This comment provides a sample MMRP. The projects’ MMRP is included in Section 0.4 of this document. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted.
1-19 This comment provides a map from the City of San Marcos Draft Subarea Plan, including Vernal Pool Major Amendment areas. Please see response to comment 1-8, above.

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LETTER 2

2-1
2-2
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Letter 2
California Public Utilities Commission
2-1 This comment provides opening remarks and describes the project and its location near an at grade railroad and pedestrian crossing. This comment incorrectly described the notice received as a Notice of Preparation (NOP). The most recent notice sent to the California Public Utilities Commission (CPUC) was the Notice of Availability for the Draft EIR. The CPUC did not provide a response during the NOP comment period. As this comment does not identify a specific environmental concern, this comment is noted and no additional response is warranted.
2-2 This comment states that improvements at North Los Posas Road crossing may be required for safety due to the development adjacent to an active rail line. The project site would be fully fenced and there would not be direct access to the rail corridor directly from the project site.

As discussed on page 2 -4 and depicted in Figure 2 -5 of the Draft EIR, fencing for the project includes a mix of split face block and tubular steel fencing. Along the northern project boundary (which is adjacent to the SPRINTER rail line) would be a 5-foot split face block wall. Along the western and eastern project boundary 5-foot tubular steel fencing would be used. Pedestrians wishing to access the Palomar College SPRINTER station would travel via Armorlite Drive, Las Posas Road and then take the sidewalk from Las Posas Road to the station.

The Draft EIR did not identify any issues related to pedestrian safety and the rail line (see Section 3.11, Transportation, of the EIR).

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LETTER 3

3-1
3-2
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Letter 3
San Diego County Archaeological Society
3-1 This comment addresses the historic aerial photographs that were reviewed for the project.

As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted.

3-2 This comment addresses the potential for the project to encounter non-tribal cultural resources and requests that the mitigation measures be expanded to included non-tribal cultural resources. Mitigation measure MM-CR-1b details procedures for non-Native American resources. However, based upon this comment, mitigation measure MM-TCR-1 has been revised to note that all non-tribal artifacts collected by the archaeologist shall also be subject to curation. The revised text, in a track changes format, is also provided below.

MM-TCR-1 Monitoring Agreement : Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall extend the invitation to enter into a Monitoring Agreement with the Rincon Band of Luiseño Indians and the San Luis Rey Band of Luiseño Indians (Tribes). The purpose of the Monitoring Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the Tribes for the monitoring for Native American human remains, funerary objects, cultural and/or religious landscapes, ceremonial items, traditional gathering areas, and other tribal cultural resources. Such resources may be located within and/or discovered during ground disturbing and/or const ruction activities for the proposed project, including any additional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities. In the event that either or both tribes choose not to enter into an agreement or fail to respond to the offer, the City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

Any project -specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the Tribal requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation. The land owner shall relinquish ownership of all non -burial related tribal cultural resources collected during construction monitoring and from any previous archaeological studies or excavations on the project site to the Tribes for proper treatment and disposition per the Monitoring Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The requirement and timing of such release of ownership, and the recipient thereof, shall be reflected in the Monitoring Agreement. Additionally, all non-tribal artifacts collected by the archaeologist shall also be subject to curation.

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LETTER 4

4-1
4-2
4-3
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Letter 4
Lozeau Drury on behalf of Supporters Alliance for Environmental Responsibility (SAFER) 4-1 The comment provides an introduction to comments that follow and a summary of the project description. The comment does not raise any specific issues related to the adequacy of the Draft EIR.
4-2 The comment states that the Draft EIR fails as an informational document and fails to implement all feasible mitigation measures to reduce the project’s impacts. The comment does not raise any specific issues related to specific topics or mitigation measures in the Draft EIR that they believe are not adequately addressed. As discussed in the Draft EIR, all potentially significant impacts are mitigated to less-than-significant levels, and no further mitigation is required. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of physical environmental impacts in the Draft EIR. CEQA only requires an EIR be recirculated in a narrowly defined set of circumstances; none of which have been triggered here. (Pub. Res. Code § 21092.1; CEQA Guidelines § 15088.5.) Recirculation is not required if the new information merely clarifies, amplifies, or makes insignificant modifications to an adequate EIR. (CEQA Guidelines § 15088.5(b); Southwest Reg’l Council of Carpenters v. City of Los Angeles (2022) 76 Cal.App.5th 1154, 1184.) The changes made to the Final EIR do not trigger recirculation under CEQA.
4-3 The comment states that they reserve the right to supplement their comment during the review of the Final EIR and at public hearings for the project. As this comment does not identify a specific environmental concern, this commented is noted and no additional response is warranted.

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0.4 MITIGATION MONITORING AND REPORTING

PROGRAM

INTRODUCTION AND SUMMARY
Pursuant to Section 21081.6 of the Public Resources Code and the California Environmental Quality Act (CEQA) Guidelines Section 15097, public agencies are required to adopt a monitoring or reporting program to assure that mitigation measures and revisions identified in Final Environmental Impact Report (FEIR) are implemented. As stated in Section 21081.6 of the Public Resources Code:
“… the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment.”
Pursuant to Section 21081(a) of the Public Resources Code, findings must be adopted by the decision makers coincidental to certification of the FEIR. The Mitigation Monitoring and Reporting Program (MMRP) must be adopted when making the findings (at the time of approval of the project).

As defined in the CEQA Guidelines, Section 15097, “reporting” is suited to projects that have readily measurable or quantitative measures or which already involve regular review. “Monitoring” is suited to projects with complex mitigation measures, such as wetland restoration or archaeological protection, which may exceed the expertise of the local agency to oversee, are expected to be implemented over a period of time or require careful implementation to assure compliance. Both reporting and monitoring would be applicable to the proposed project.

MITIGATION MATRIX
To sufficiently track and document the status of mitigation measures, a mitigation matrix has been prepared and includes the following components:
• Impact
• Mitigation Measure
• Action
• Timing
• Responsibility

The mitigation matrix is included in Table 0.4-1. Additionally, the project will be required to adhere to the design features presented in Table 0.4-2.

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Table 0.4-1. Mitigation Measures
Armorlite Lofts Specific Plan Mitigation Monitoring and Reporting Program Impact Mitigation Measure Action Timing Responsibility

BIOLOGICAL RESOURCES
BIO-1 Potential to
impact avian species and
wildlife protected under
the Migratory Bird Treaty
Act and California Fish
and Game Code if tree
removal, vegetation
removal, or other
construction activities
occur during the nesting
season.

MM-BIO-1a Breeding Season Avoidance. To the extent feasible, the applicant/developer shall only remove vegetation from the project impact footprint between September 1 through February 14 to avoid the bird breeding season. Further, to the maximum extent practicable, grading activities associated with
construction of the project shall occur September 1 through February 14 to avoid the breeding season. If project construction must occur during the breeding season, mitigation measure MM- BIO-1b shall be implemented.

MM-BIO-1b Nesting Survey(s). Take of birds protected under the Migratory Bird Treaty Act and California Fish and Game Code shall be avoided during the nesting season. To avoid any direct impacts on raptors and/or any migratory birds protected under the Migratory Bird Treaty Act and California Fish and Game Code, removal of habitat that supports active nests on the proposed area of disturbance shall occur outside of the nesting season for these species (February 15 through August 31, annually). If construction occurs during the nesting season, pre-construction nesting bird surveys must be conducted within 72 hours of construction-related activities. If nesting birds are detected by the biologist, the following buffers shall be established: (1) no work within 300 feet of a non-listed nesting migratory bird nest, and (2) no work within 500 feet of a listed bird or raptor nest.

However, the biologist may reduce these buffer widths
depending on site-specific conditions (e.g., the width and type of screening vegetation between the nest and proposed activity) or the existing ambient level of activity (e.g., existing level of human activity within the buffer distance) in conjunction with consultation with the City of San Marcos. If construction must take place within the recommended buffer widths above, the project applicant shall contact the City of San Marcos and Avoid construction
during bird breeding
season but If
construction is
proposed during the
breeding season,
conduct a pre-
construction survey.

If nesting birds are
present, implement
buffer zone and
avoidance measures.

If nesting birds are
not detected during
the preconstruction
survey, no further
mitigation is
required.

Avoid ground-
disturbing activities
during the Crotch’s
bumble bee nesting
period. If ground-
disturbing activities
are proposed during
the Crotch’s bumble
bee nesting period,
For construction
activities
proposed for the
period of
February 15
through August
31, conduct bird
surveys within
seven days prior
to the start of
construction
activities.

For ground-
disturbing
activities
between
February 1
through October
31, conduct
Crotch’s bumble
bee surveys.

Applicant/
Landowner, Project
Biologist,
Contractor.

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Impact Mitigation Measure Action Timing Responsibility
wildlife agencies (United States Fish and Wildlife Service [USFWS] and California Department of Fish and Wildlife [CDFW]) to determine the appropriate buffer.

Additionally, take of a state candidate species is prohibited under the California Endangered Special Act (CESA). While Crotch’s bumble bee has low potential to occur on site, the pre- construction surveys for Crotch’s bumble bee shall be
conducted within the construction footprint prior to the start of ground-disturbing activities occurring during the Crotch’s bumble bee nesting period (February 1 through October 31). The survey shall ensure that no nests for Crotch’s bumble bee are located within the construction area. The pre-construction survey shall include focused surveys, which shall be based on
recommendations described in the Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species, released by CDFW on June 6, 2023, or the most current version of such guidelines at the time of construction.

The surveys shall be performed by a biologist with expertise in surveying for bumble bees and include at least three (3) survey passes that are not on sequential days or in the same week, preferably spaced two (2) to four (4) weeks apart. Surveys may occur between 1 hour after sunrise and 2 hours before sunset.

Surveys shall not be conducted during wet conditions (e.g., foggy, raining, or drizzling), and surveyors shall wait at least one (1) hour following rain. Optimal surveys are when there are sunny to partly sunny skies and a temperature greater than 60°F. Surveys may be conducted earlier if other bees or butterflies are flying. Surveys shall not be conducted when it is windy (i.e., sustained winds greater than 8 miles per hour).

Within non-developed habitats, the biologist shall look for nest resources suitable for bumble bee use. Ensuring that all nest resources receive 100% visual coverage, the biologist shall watch the nest resources for up to five (5) minutes, looking for exiting or entering worker bumble bees. Worker bees should arrive and exit an active nest site with frequency, such that their presence would be apparent after five (5) minutes of
conduct surveys, per
the requirements of
the mitigation
measure.

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Impact Mitigation Measure Action Timing Responsibility
observation. If a bumble bee worker is detected, then a representative shall be identified to species. Biologists should be able to view several burrows at one (1) time to sufficiently determine if bees are entering/exiting them, depending on their proximity to one another. It is up to the discretion of the biologist regarding the actual survey viewshed limits from the chosen vantage point to determine which would provide 100% visual coverage; this could include a 30- to 50-foot-wide area. If a nest is suspected, the surveyor can block the entrance of the possible nest with a sterile vial or jar until nest activity is confirmed (no longer than 30 minutes).

Identification shall include trained biologists netting/capturing the representative bumble bee in appropriate insect nets, per the protocol in U.S. National Protocol Framework for the Inventory and Monitoring of Bees. The bee shall be placed in a clear container for observation and photographic
documentation, if able. The bee shall be photographed using a macro lens from various angles to ensure recordation of key identifying characteristics. If bumble bee-identifying
characteristics cannot be adequately captured in the container due to movement, the container shall be placed in a cooler with ice until the bumble bee becomes inactive (generally within 15 minutes). Once inert, the bumble bee shall be removed from the container and placed on a white sheet of paper or card for examination and photographic documentation. The bumble bee shall be released into the same area from which it was captured upon completion of identification. Based on implementation of this method on a variety of other bumble bee species, they become active shortly after removal from the cold environment, so photography must be performed quickly.

If Crotch’s bumble bee nests are not detected, no further mitigation is required. The mere presence of foraging Crotch’s bumble bees shall not require implementation of additional mitigation measures because they can forage up to 10
kilometers from their nests. If nest resources occupied by Crotch’s bumble bee are detected within the project
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Impact Mitigation Measure Action Timing Responsibility
construction area, no construction activities shall occur within 100 feet of the nest, or as determined by a qualified biologist through evaluation of topographic features or distribution of floral resources. The nest resources shall be avoided for the duration of the Crotch’s bumble bee nesting period (February 1 through October 31). Outside of the nesting season, it is assumed that no live individuals would be present within the nest because the daughter queens (gynes) usually leave by September, and all other individuals (original queen, workers, males) die. The gyne is highly mobile and can independently disperse to outside of the construction footprint to surrounding open space areas that support suitable hibernacula resources.

A written survey report shall be submitted to the City Planning Division Director within 30 days of the last survey pass. The report shall include survey methods, weather conditions, and survey results, including a list of insect species observed and a figure showing the locations of any Crotch’s bumble bee nest sites or individuals observed. The survey report shall include the qualifications/resumes of the surveyor(s) and approved
biologist(s) for identification of photo vouchers and a detailed habitat assessment. If Crotch’s bumble bee nests are observed, the survey report shall also include recommendations for avoidance, and the location information shall be submitted to the California Natural Diversity Database at the time of, or prior to, submittal of the survey report.

If Crotch’s bumble bee is detected within the project site, the project applicant/developer shall consult with CDFW regarding the need to obtain an Incidental Take Permit. Any measures determined to be necessary through the Incidental Take Permit process to offset impacts to Crotch’s bumble bee may
supersede measures provided in this document.

In the event that an Incidental Take Permit is needed, mitigation for direct impacts to Crotch’s bumble bee shall be fulfilled through compensatory mitigation at a minimum 1:1 nesting habitat replacement of equal or better functions and values to Armorlite Lofts Specific Plan April 2025
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those impacted by the project, or as otherwise determined through the Incidental Take Permit process. Mitigation shall be accomplished through on-site preservation of suitable habitat and/or in accordance with CDFW guidance for off-site locations.

The funding source shall be in the form of an endowment to help the qualified natural lands management entity that is ultimately selected to hold the conservation easement(s). The endowment amount shall be established following the completion of a project-specific Property Analysis Record to calculate the costs of in-perpetuity land management. The Property Analysis Record shall take into account all management activities required in the Incidental Take Permit to fulfill the requirements of the conservation easement.

BIO-2: The proposed
project has the potential
to result in indirect
impacts to sensitive
species due to dust,
trash, and accidental
transport of non-native
plant species into the
project site, and invasive
plant species, and noise
and lighting effects.

MM-BIO-2a Construction Best Management Practices. The
project applicant shall ensure that the following conditions are implemented during project construction to minimize potential environmental impacts due to project implementation:

1. Impacts from fugitive dust shall be avoided and
minimized through watering and other appropriate
measures consistent with the Construction General
Permit Order 2009-009-DWQ.

2. Employees shall strictly limit their activities, vehicles, equipment, and construction materials to the project
site.

3. To avoid attracting predators, the project site shall be kept clean of debris. All food-related trash items shall be enclosed in sealed containers and regularly removed
from the site.

4. Pets of project personnel shall not be allowed on the project site.

Biological monitoring
and implementation
of BMPs during
construction.

Review/approve
landscape plans.

Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

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MM-BIO-2b Landscaping. The applicant shall ensure that
development landscaping habitat does not include exotic plant species that may be invasive to native habitats in the region.

Exotic plant species not to be used include any species listed on the California Invasive Plant Council’s “Invasive Plant Inventory” List. In addition, landscaping should not use plants that require intensive irrigation, fertilizers, or pesticides.

MM-BIO-2c Biological Monitor Requirements and Duties. A qualified biologist shall be on site per the discretion of the City during initial clearing/grubbing and during grading to ensure compliance with all project-imposed mitigation measures. The biologist shall be available during pre-construction and construction phases to review grading plans, address protection of potential biological resources, monitor ongoing work, and maintain communications with the Project’s engineer to ensure that any issues are appropriately and lawfully managed.

The qualified biological monitor shall also be responsible for the following duties:

1. Periodically monitor the work area to ensure that work activities do not generate excessive amounts of dust.

2. Halt work, if necessary, and confer with the USFWS,
CDFW, and City of San Marcos to ensure the proper
implementation of species and habitat protection
measures. The biologist shall report any violation to
USFWS and the City within 24 hours of its occurrence.

3. Submit a final report to the City within 60 days of project completion that includes the following:(1) as-built
construction drawings for grading with an overlay of any active nests; (2) photographs of habitat areas during
pre-construction and post-construction conditions; and
(3) other relevant summary information documenting
that authorized impacts were not exceeded and that
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general compliance with the avoidance/minimization
provisions were achieved.

BIO-3 The proposed
project would impact

2.13 acres of Diegan
coastal sage scrub and

0.12 acres of non-native
grassland-broadleaf
dominated for a total of

2.25 acres of impact.

MM-BIO-3 Off-Site Mitigation. The permanent loss of 2.13 acres of Diegan Coastal Sage Scrub will be mitigated at a minimum 1:1 ratio and the permanent loss of 0.12 acres of non-native grassland will be mitigated at a minimum 0.5:1 ratio. The amount of mitigation acreage required for non-native grassland may be reduced if up-tiered (i.e., coastal sage scrub) habitat is available for purchase. Section 5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on-site mitigation, off-site acquisition, in-lieu fees, and mitigation credits. Since on-site mitigation is not an option due to the project design, the impacted 2.13 acres of Diegan coastal sage scrub and 0.06 acres of non-native grassland will be mitigated by the project applicant through off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City’s Planning Division Director and wildlife agencies prior to issuance of the grading permit.

Proof of off-site
acquisition, in-lieu
fees, purchase of
credits from
mitigation bank, or
combination thereof
submitted to the
Planning Division
Director.

Prior to issuance
of Grading
Permit.

Applicant/
Landowner, Project
Biologist.

CULTURAL RESOURCES
CR-1 Due to grading
and ground disturbing
activities, the proposed
project may uncover
previously unidentified
archeological resources
associated with SDI-
5633 or may result in
previously unknown
archaeological resources
associated with other
time periods or cultures.

MM-CR-1a Archaeological Monitoring: Prior to the issuance of a Grading Permit or ground disturbing activities, the
Applicant/Owner or Grading Contractor shall provide written documentation (either as signed letters, contracts, or emails) to the City’s Planning Division stating that a Qualified Archaeologist has been retained at the Applicant/Owner or Grading
Contractor’s expense to monitor ground disturbing activities associated with project construction.

The Qualified Archaeologist shall be invited to attend all applicable pre-construction meetings with the General
Contractor and/or associated subcontractors to present the construction monitoring program. The Qualified Archaeologist shall be present on-site during grubbing, grading, trenching, and/or other ground disturbing activities that occur in areas of Provide
documentation that
a qualified
archaeologist has
been retained.

Archaeologist to
attend pre-
construction
meetings and
conduct monitoring
as described.

Prior to issuance
of Grading
Permit and/or
during all earth
moving and
ground
disturbing
activity.

Archaeologist
monitoring
report to be
provided prior to
Applicant/
Landowner,
Archaeologist,
Tribal Monitor(s),
Contractor.

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native soil or other permeable natural surfaces that have the potential to unearth any evidence of potential archaeological resources. In areas of artificial paving, the Qualified Archaeologist shall be present on-site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb more than six (6) inches below the original pre-project ground surface to identify any evidence of potential archaeological resources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non-commercial sources that have been determined to be absent of
archaeological resources by the Qualified Archaeologist.

The Qualified Archaeologist shall maintain ongoing collaborative coordination with the Native American monitor(s) (mitigation measure MM-TCR-1) during all ground disturbing activities. The requirement for the construction monitoring program shall be noted on all applicable construction documents, including demolition plans, grading plans, etc. The Applicant/Owner or Grading Contractor shall provide written notice to the Planning Division, preferably through e-mail, of the start and end of all ground disturbing activities.

Prior to the release of any grading bonds, or prior to the issuance of any project Certificate of Occupancy, an archaeological monitoring report, which describes the results, analysis, and conclusions of the construction monitoring shall be submitted by the Qualified Archaeologist, along with any Native American monitor’s notes and comments received by the Qualified
Archaeologist, to the Planning Division Director for approval.

Once approved, a final copy of the archaeological monitoring report shall be retained in a confidential City project file and may be released, as a formal condition of Assembly Bill (AB) 52 consultation, to consulting Tribes. A final copy of the report, with all confidential site records and appendices, will also be

Provide
archaeologist
monitoring report.
the release of
any grading
bonds, or prior to
the issuance of
any project
Certificate of
Occupancy.

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submitted to the South Coastal Information Center after approval by the City.

MM-CR-1b Unanticipated Discovery Procedures: The Qualified Archaeologist may temporarily halt or divert ground disturbing activities if previously unknown archaeological resources are discovered during construction activities. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a
determination of the resource’s potential significance. If the resource is determined to be associated with Native American culture, it will be considered a tribal cultural resource and subject to mitigation measures MM-TCR-4 and MM-TCR-5. Non- Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource (subject to MM-TCR-4) and a potentially significant archaeological resource that is associated with Native American culture, then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.

Isolates and clearly non-significant archaeological resources (as determined by the Qualified Archaeologist) will be minimally documented in the field. All unearthed archaeological resources will be collected, temporarily stored in a secure location until analysis and documentation are complete. If a determination is made that the archaeological resources are considered
potentially significant by the Qualified Archaeologist, then an adequate artifact sample to address research avenues
previously identified for sites in the area will be collected using professional archaeological collection methods.

In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final If potential cultural
resources are found,
halt ground
disturbance and
follow procedures
listed for discovery.

During all earth
moving and
ground
disturbing
activity.

Archaeologist,
Tribal Monitor(s),
Contractor, City
(Planning Division
Director).

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curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project construction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the curation facility that the curation has been completed.

CR-2 There is a
potential for Project
construction activities to
disturb previously
unidentified human
remains on the Project
site.

MM-CR-2 Human Remains: As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code Section 5097.98.

If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American
monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two (2) business days of being notified if the remains are subject to their authority. If the Medical Examiner recognizes
the remains to be Native American,
and not under their jurisdiction, then they shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

If human remains
are found, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

Archaeologist,
Tribal Monitor(s).

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If suspected Native American remains are discovered, the remains shall be kept in situ (in place) until after the Medical Examiner makes its determination and notifications, and until after the Most Likely Descendent is identified, at which time the archaeological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public. According to California Health and Safety Code, six (6) or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a location free from future disturbance (see Public Resources Code Sections 5097.98(e) and 5097.94(k)).

NOISE
N-1 Due to
temporary rock drilling
and blasting activities
during construction, the
proposed project has the
potential to create noise
levels in excess of the 75
dBA standard if rock
drilling equipment is
staged closer than 160
feet to an occupied noise
sensitive land use’s
property line
MM-N-1 Prior to issuance of a blasting permit, the project applicant or contractor shall provide the final location of the construction equipment, topography, and construction schedule to the Planning Division. If the rock drill is shown to be located within 160 feet from a sensitive land use’s property line, an acoustical engineer shall prepare a noise assessment to determine whether noise levels in excess of the 75 dBA standard would occur during construction.

If the rock drilling and blasting noise assessment determines noise levels at the affected property lines would exceed 75 dBA, the acoustical engineer shall develop a mitigation plan to ensure during rock drilling and blasting would be below 75 dBA at the property line. Potential measures to reduce drilling and blasting noise levels could include: 1) construction of a temporary noise barrier of solid non-gaping material ranging from 8 to 12 feet in Depending on final
location of rock drill,
prepare noise
assessment and if
necessary,
mitigation
plan.

Implement identified
measures including
construction of
temporary noise
barriers as
necessary.

Prior to issuance
of a blasting
permit and
during rock
drilling.

Applicant/
Landowner,
Acoustical
Engineer,
Contractor, City
(Planning Division
Director).

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height along any property line where the impacts could occur; 2) limits on usage of the equipment (amount of time used and/or the location in respect to the property line) or other measures to ensure the levels would be below 75 dBA. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

N-2 Due to
temporary rock crushing
activities, the proposed
project has the potential
to create noise levels in
excess of the applied
operational noise
standards for multi-
family residential (65
dBA Leq) and commercial
use (70 dBA Leq) if the
rock crusher is staged
within 210 feet of a
multi-family residential
use or within 160 feet of
a commercial use.

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

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

Depending on final
location of rock
crusher, prepare
noise assessment
and if necessary,
mitigation plan.

Implement identified
measures including
construction of
temporary noise
barriers as
necessary.

Prior to
issuance of a
Conditional Use
Permit for a rock
crusher and
during rock
crushing
activities.

Applicant/
Landowner,
Acoustical
Engineer,
Contractor, City
(Planning Division
Director).

Tribal Cultural Resources
TCR-1 As a result of
tribal consultation, the
City has determined that
construction of the
proposed project has the
potential to cause a
substantial adverse
change to a tribal cultural
MM-TCR-1 Monitoring Agreement: Prior to the issuance of a Grading Permit, or ground disturbing activities, the
Applicant/Owner shall extend the invitation to enter into a Monitoring Agreement with the Rincon Band of Luiseño Indians and the San Luis Rey Band of Luiseño Indians (Tribes). The purpose of the Monitoring Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the Tribes for the monitoring for Native American human remains, Extend invitation and
if accepted, enter
into a Monitoring
Agreement between
Applicant/Owner and
Tribes.

Prior to issuance
of a Grading
Permit or
commencement
of
ground
disturbing
Applicant/
Landowner, Tribal
Representative(s),
Tribal Monitor(s),
Archaeologist,
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resource that is eligible
for inclusion in the
California Register of
Historical Resources.

funerary objects, cultural and/or religious landscapes, ceremonial items, traditional gathering areas, and other tribal cultural resources. Such resources may be located within and/or discovered during ground disturbing and/or construction activities for the proposed project, including any additional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities. In the event that either or both tribes choose not to enter into an agreement or fail to respond to the offer, the City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

Any project-specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the Tribal requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation. The landowner shall relinquish ownership of all non-burial related tribal cultural resources collected during construction monitoring and from any previous archaeological studies or excavations on the project site to the Tribes for proper treatment and disposition

per the Monitoring Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The requirement and timing of such release of ownership, and the recipient thereof, shall be reflected in the Monitoring Agreement.

Additionally, all non-tribal artifacts collected by the archaeologist shall also be subject to curation.
activities and
during all earth
moving and
ground
disturbing
activities.

MM-TCR-2 Controlled Grading. The area illustrated on the confidential exhibit attached to the grading plans shall be subject to controlled grading. Under the observation of a tribal monitor and qualified archaeologist, the contractor shall use either a small piece of equipment or observe the removal of soil by a backhoe equipped with a flat-edge bucket to excavate soil using shallow cuts made in approximately one-foot lifts. The grading equipment will push the shallow cuts of soil to the outside of the cultural deposit area and random samples may be screened to ensure adequate detection of any cultural materials Controlled grading
under observation of
tribal monitor(s) and
archaeologist.

During
grading/earth
disturbing
activities in area
illustrated on
confidential
exhibit attached
to grading plans.

Applicant/
Landowner, Tribal
Monitor(s),
Archaeologist,
Contractor.

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that may be present. In the event that cultural materials or human remains are exposed, the procedures for unanticipated discoveries in mitigation measure MM-TCR-4 shall apply.

Controlled grading shall continue to a depth of 30 centimeters below the depth of any recorded artifacts, suggesting an end to the potential for cultural deposits, or when restrictive layers or non-cultural formational soils are encountered that predate any human occupation of this location, as determined by the qualified professional archaeologist, in consultation with the tribal monitor. Once the identified depth has been reached, the controlled grading process will be terminated and mass grading may proceed, subject to review and approval by the City.

MM-TCR-3 Construction Monitoring: Prior to the issuance of a Grading Permit or ground disturbing activities, the
Applicant/Owner or Grading Contractor shall provide written documentation (either as signed letters, contracts, or emails) to the City’s Planning Division stating that the Rincon Band and San Luis Rey Band have been retained at the Applicant/Owner or Grading Contractor’s expense to implement the construction monitoring program, as described in the Monitoring Agreement.

Native American monitoring shall include one (1) monitor from the Rincon Band of Luiseño Indians and one (1)
monitor from the
San Luis Rey Band of Luiseño Indians simultaneously. In the event that either tribe chooses not to enter into an agreement or fails to respond to the offer, the City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

The monitors shall be provided at least 72 hours’ notice of the initiation of construction and be kept reasonably apprised of changes to the construction schedule. In the event that a monitor is not present at the scheduled time, work can continue without the monitor present, as long as the notice was given and documented.

Native American monitors shall be invited to attend all applicable pre-construction meetings with the General Contractor and/or Provide
documentation that
Tribal Monitor(s)
have been retained.

Tribal Monitor(s) to
attend pre-
construction
meetings and
conduct monitoring
as described.

Prior to issuance
of Grading
Permit and/or
during all earth
moving and
ground
disturbing
activity.

Applicant/
Landowner, Tribal
Monitor(s),
Archaeologist,
Contractor.

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associated subcontractors to present the construction
monitoring program. The Native American monitors shall be present on-site during grubbing, grading, trenching, and/or other ground disturbing activities that occur in areas of native soil or other permeable natural surfaces that have the potential to unearth any evidence of potential archaeological resources or tribal cultural resources. In areas of artificial paving, the Native American monitors shall be present on-site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb the original pre-project ground surface to identify any evidence of potential tribal cultural resources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non-commercial sources that have been
determined to be absent of tribal cultural resources by the Native American monitors.

The Qualified Archaeologist (mitigation measure MM-CR-1a) and Native American monitors shall maintain ongoing collaborative coordination with one another during all ground disturbing activities. The requirement for the construction monitoring program shall be noted on all applicable construction
documents, including demolition plans, grading plans, etc. The Applicant/Owner or Grading Contractor shall provide written notice to the Planning Division and the Tribes, preferably through e-mail, of the start and end of all ground disturbing activities.

MM-TCR-4 Unanticipated Discovery Procedures: Native
American monitors may temporarily halt or divert ground disturbing activities if previously unknown tribal cultural resources are discovered during construction activities. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be not associated with Native If potential tribal
cultural resources
are found, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

Tribal Monitor(s),
Archaeologist,
Contractor, City
(Planning Division
Director).

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American culture, it will be subject to mitigation measure MM- CR-1b. Native American tribal cultural resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture (subject to mitigation measure MM-CR-1b), then the Qualified Archaeologist, Tribes, monitors, and City shall coordinate on appropriate treatment.

All unearthed tribal cultural resources will be collected, temporarily stored in a secure location, and repatriated according to the consulting tribes, unless ordered to do otherwise by responsible agency or court of competent
jurisdiction.

If a determination is made that the tribal cultural resources are considered potentially significant by the Tribe and the Native American monitor, then the City and the Tribe shall determine, in consultation with the Applicant/Owner, the culturally appropriate treatment of those resources.

All sacred sites and significant tribal cultural resources encountered within the project area shall be avoided and preserved as the preferred mitigation. If avoidance of the resource is determined to be infeasible by the City as the Lead Agency (as defined by the California Environmental Quality Act [CEQA]), then the City shall require additional culturally appropriate mitigation to address the negative impact to the resource. The Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation. Any cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site and repatriated according to the terms of the Monitoring Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The removal of any artifacts from the project site will be inventoried with oversight by the Native

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American monitor. Any testing, taking of photos or 3D prints are prohibited, unless all monitoring tribes give prior written approval.

MM-TCR-5 Human Remains: As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. The procedures in mitigation measure MM-CR-2 shall apply.

If human remains
are found, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

Native American
Monitor(s),
Archaeologist,
MM-TCR-6 Reburial: Prior to the approval of grading plans, the Applicant shall designate a reburial location onsite and note the location as excluded from construction-
related activity on grading
plans. The reburial location shall be used to rebury any cultural materials encountered during monitoring, and to rebury existing collections from the previous data recovery effort. Following the completion of all ground disturbing activity and reburial of all materials and before the issuance of a Certificate of Occupancy, the Applicant shall file a deed restriction on the parcel that protects the reburial location from future disturbance and provide a copy to the City. The exhibit for the deed restriction and purpose of it shall be kept confidential and out of the public record.

Designate a reburial
location on grading
plan to be excluded
from construction-
related activities.

Bury new and/or
existing cultural
resources in this
location.

File deed restriction
on parcel to protect
reburial location
from future
disturbance.

Prior to approval
of grading plans,
and prior to
issuance of
Certificate of
Occupancy.

Applicant/Land
Owner, Tribal
Monitor(s),
Archaeologist, City
(Planning Division
Director).

MM-TCR-7 Access Agreement and Management Policy: Prior to the issuance of a Certificate of Occupancy, the Applicant/Owner shall extend a written offer to each consulting tribe to enter into an access agreement, which is binding on successors and heirs Extend offer to
Tribe(s) and if
accepted prepare
access agreement
Prior to the
issuance of a
Applicant/ Land
Owner, Tribal
Representative(s),
Tribal Monitor(s),
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to the property, that allows for legal access to visit the reburial location after construction is completed. If more than one tribe elects to enter into an access agreement, each tribe shall have its own agreement. In the event that one (1) or more consulting tribe does not respond to the offer within 30 days of receipt, then the City will deem this mitigation measure satisfied provided that the offer was extended and documented in
accordance with this measure. Management of the reburial area is to include the development of a revegetation plan in consultation with the consulting tribes, including notification process for proposed maintenance of the reburial area.
(s) for future visits to
the site’s reburial
location after
construction.

Develop and include
revegetation plan.

Certificate of
Occupancy.

City (Planning
Division Director).

MM-TCR-8 Native Vegetation: Prior to clearing and grubbing of vegetation in the project area, a qualified professional botanist shall flag the presence of white sage for transplanting into the landscaping or offsite. In the event that transplanting is determined infeasible by the botanist, in their professional judgement, the Applicant/Owner shall ensure that native white sage is included in the landscaping plan for the project.

Flag presence of
white sage for
transplanting into
landscaping; Include
white sage in
Landscaping Plan.

Prior to clearing
and grubbing of
vegetation in the
project area and
prior to final
approval of
landscape plan.

Qualified botanist,
Tribal Monitor(s),
Applicant/ Land
Owner, Contractor.

MM-TCR-9 Land Acknowledgement Statement: The
Applicant/Owner shall develop and post a Land
Acknowledgement Statement inside a common area of the
development. The statement shall be developed in coordination with Tribes and address the acknowledgement that the project is on the ancestral lands of culturally affiliated tribes that have been the original and ongoing stewards of the land. In the event that consulting tribes do not respond to the offer within 30 days of receipt, then the City will deem this mitigation measure satisfied provided that the offer was extended and documented in accordance with this measure. The location of the Land Acknowledgement Statement shall be noted on elevation and/or plan view drawings for the common area of the development.

Develop and post
Land
Acknowledgement
Statement inside
common area of
development. Note
statement on
elevation and/or
plan view drawings.

Prior to approval
of elevation
and/or plan view
drawings.

Applicant/ Land
Owner, City
(Planning Division
Director).

MM-TCR-10 Project-Specific Ethnographic Synthesis: The Applicant/Owner shall fund the preparation of a project-specific ethnographic synthesis, not to exceed what is described in the Extend written offer
and if accepted
prepare
No later than 30
days after the
Applicant/ Land
Owner, Tribal
Representative(s).

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Impact Mitigation Measure Action Timing Responsibility
confidential proposal provided by the Rincon Band of Luiseño Indians dated August 27, 2024. No later than 30 days after the final project approval, the Applicant/Owner shall extend a written offer to the Rincon Band of Luiseño Indians to enter into an agreement with their ethnographer to conduct and prepare the ethnographic synthesis in accordance with the aforementioned proposal. In the event of a dispute between the parties in entering into the agreement for the ethnographic synthesis, and after a good faith and reasonable effort, the City shall serve as the final arbiter. The City will determine the scope and content of an ethnographic synthesis in that event.

The synthesis will draw from oral histories, elder knowledge, and other sources of confidential Indigenous knowledge that relate to the tribal cultural resource affected by the proposed project. The ethnographer shall be afforded up to 90 days following funding of the ethnography to carry out any field visits with appropriate tribal representatives. After 90 days, or sooner if the ethnographer completed its field studies, the Applicant/Owner shall be permitted to proceed with ground disturbing activities and construction of the project while non-field-based data gathering, such as ethnographic interviews of informants and review of tribal documents, is being carried out. Upon
completion, a public (redacted) version of the ethnographic synthesis shall be submitted to the California Historical Resources Information System and the City. The final non- redacted study shall belong to the Rincon Band of Luiseño Indians.

ethnographic
synthesis. Submit
public (redacted)
version of the
ethnographic
synthesis to the
California Historical
Resources
Information System
and the City.
final Project
approval
City (Planning
Division Director).

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City of San Marcos Page 0.4-21
Table 0.4-2. Design Considerations for the Project
Aesthetics
• Implementation of the Landscape Plan to provide a cohesive and visually appealing planting scheme.
• Compliance with the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards.

Air Quality
• Compliance with San Diego Air Pollution Control District (SDACPD) Rule 55 – Fugitive Dust. • In accordance with SDAPCD Rule 67.0 (Architectural Coatings), the project would utilize low- volatile organic compound (VOC) paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces. • Heavy diesel construction equipment shall be rated Tier IV or better. • Blasting activities would be limited as follows: 1) blasts would be limited to once per day; blasts are limited to six tons of ammonium nitrate for any given blast operation; and the blast area would be limited to 20,000 s.f. (100-foot X 200-foot area).

Biological Resources
• The applicant/developer/property owner shall pay Public Facility Fees, a portion of which go towards City-wide habitat conservation efforts.

Energy
• Ensure proper maintenance of all construction equipment per manufacturer recommendations. • Comply with the California Air Resources Board (CARB)’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. • Installation of rooftop solar photovoltaic consistent with Title 24.

Greenhouse Gas Emissions
• Provision of 13 Level 2 EV charging stations.
• Provision of 25 EV capable and 62 EV ready parking spaces in the community parking area. • To meet the requirements of Reduced Parking Near Transit (Measure T-12) in the City’s CAP:
the project would provide 247 spaces for residential use (69 garage standard spaces, 102 garage tandem spaces, 18 tuck under spaces and 58 open spaces) and 17 spaces for the commercial uses. Commercial parking requirements would be met by providing 7 open parking spaces, and 10 of the residential open spaces would be available for commercial use from 9:00 AM to 5:00 PM to meet the required 17 spaces.
• Installation of rooftop solar photovoltaic consistent with Title 24 and the CAP compliance checklist.
• Provision of bicycle racks.
• Provision of pedestrian connection between the proposed building to Armorlite Drive. • The property manager shall provide transit information to the owners and make a good faith effort in offering transit fare subsidies to residents and businesses. • Designated parking for EV, carpool, vanpool, and/or park-and-ride spaces on site. • Provision of a workspace in the community room for telecommuting employees.

Armorlite Lofts Specific Plan April 2025
City of San Marcos Page 0.4-22
• Compliance with the City’s Model Water Efficient Landscape Ordinance and Municipal Code, Title 20.
• Installation of electric (rather than natural gas) tank water heaters. • None of the units shall have fireplaces.
• Planting of shade trees.

Hazards
• Future residents shall be notified of potential annoyances commonly associated with proximity to airports (e.g., noise, vibrations, and overflights) through the recording of overflight notification documents as outlined in the McClellan-Palomar Airport Land Use Compatibility Plan and Chapter 20.265 of the City’s Municipal Code.

Noise
• Grading, excavation, and other earth moving activities shall occur between 7:00 AM and 6:00 PM, Monday through Friday and between 8:00 AM and 5:00 PM on Saturdays. No grading, excavation and other earth moving activities shall occur on Sunday or City holidays in accordance with the City’s Municipal Code, Sections 10.24.200 and 17.080.00. • Compliance with Municipal Code Section 17.60.060 (Blasting Operations Procedures). • All equipment shall be properly fitted with mufflers and all staging and maintenance shall be conducted as far away from the existing residences as possible to reduce construction noise. • The residential units with direct line-of-site to W. Mission Road and Las Posas Road shall have enhanced balcony and patio shielding consisting of 3.5-foot barriers. The barriers shall be constructed of a non-gapping material consisting of masonry, ¼ inch thick glass, earthen berm, or any combination of these materials.
• Parapet walls shall be constructed to shield rooftop HVAC units. • To ensure compliance with California Code of Regulations (CCR) Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).

Public Services – Fire Protection, Police Protection and Schools • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001-01 (Fire and Paramedic). • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 98-01 (Police).
• The applicant shall pay the San Marcos Unified School District developer fees that are in effect at the time of building permit issuance. The current residential fee is $5.17 per square foot and
the current commercial fee is $0.84 per square foot.

Transportation (Vehicle Miles Traveled)
• The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2011-01 (Congestion Management).

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Utilities and Service Systems
• The applicant shall pay applicable Water and Wastewater Capital Facility Fees to Vallecitos Water District per Ordinances Nos. 175 and 176.

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0.5 CEQANET POSTING

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Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page I
Table of Contents
Table of Contents ................................ ................................ ................................ ................................ .... i Technical Appendices (included on USB) .............................................................................................. v List of Tables ........................................................................................................................................... v List of Figures ......................................................................................................................................... vii Acronyms .......................................................................................................................................... viii

1.0 Summary ................................ ................................ ................................ ................................ . 1-1

1.0 Project Summary .......................................................................................................................1-1

1.1 Summary of Significant Effects/Mitigation ..............................................................................1-1

1.2 Areas of Controversy .................................................................................................................1-3

1.3 Issues to be Resolved ...............................................................................................................1-3

1.4 Project Alternatives ...................................................................................................................1-4

1.4.1 No Project/No Development Alternative................................ ..................................................... 1-4

1.4.2 No Project/Existing Plan Alternative ................................ ........................................................... 1-4

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

1.4.4 Reduced Intensity Alternative................................ ...................................................................... 1-5

1.4.5 Environmentally Superior Alternative ................................ .......................................................... 1-6

2.0 Project Description, Location and Environmental Setting ................................ ...................... 2-1

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

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

2.2.1 Discretionary Actions ................................ ................................................................................... 2-2

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

2.3 Environmental Setting ............................................................................................................ 2-10

2.3.1 Existing Land Use and Setting ................................ ................................................................... 2-10

2.3.2 Existing General Plan and Zoning ................................ ............................................................. 2-11

2.3.3 Regional Setting ................................ ......................................................................................... 2-11

2.4 Intended Uses of EIR .............................................................................................................. 2-12

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

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

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

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

2.5 Matrix of Project Approvals .................................................................................................... 2-16

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

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

3.0 Environmental Impact Analysis ................................ ................................ ............................... 3-1

3.1 Aesthetics ..................................................................................................................................3-2

3.1.1 Existing Conditions ................................ ....................................................................................... 3-2

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

3.1.3 Thresholds of Significance ................................ .......................................................................... 3-4

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

3.1.5 Cumulative Impact Analysis................................ ......................................................................... 3-7

3.1.6 Mitigation Measures ................................ .................................................................................... 3-8 Table of Contents
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City of San Marcos Page ii

3.1.7 Conclusion .................................................................................................................................... 3-8

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

3.2.1 Existing Conditions .................................................................................................................... 3.2-1

3.2.2 Regulatory Setting ..................................................................................................................... 3.2-6

3.2.3 Thresholds of Significance .....................................................................................................3.2 -11

3.2.4 Project Impact Analysis ...........................................................................................................3.2 -13

3.2.5 Cumulative Impact Analysis....................................................................................................3.2 -19

3.2.6 Mitigation Measures ...............................................................................................................3.2 -20

3.2.7 Conclusion ...............................................................................................................................3.2 -20

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

3.3.1 Existing Conditions .................................................................................................................... 3.3-1

3.3.2 Regulatory Setting ..................................................................................................................... 3.3-9

3.3.3 Thresholds of Significance .....................................................................................................3.3 -14

3.3.4 Project Impact Analysis ...........................................................................................................3.3 -14

3.3.5 Cumulative Impact Analysis....................................................................................................3.3 -18

3.3.6 Mitigation Measures ...............................................................................................................3.3 -18

3.3.7 Conclusion ...............................................................................................................................3.3 -22

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

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

3.4.2 Regulatory Setting ...................................................................................................................3.4 -11

3.4.3 Thresholds of Significance .....................................................................................................3.4 -13

3.4.4 Project Impact Analysis ...........................................................................................................3.4 -14

3.4.5 Cumulative Impact Analysis....................................................................................................3.4 -16

3.4.6 Mitigation Measures ...............................................................................................................3.4 -17

3.4.7 Conclusion ...............................................................................................................................3.4 -19

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

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

3.5.2 Regulatory Setting ..................................................................................................................... 3.5-4

3.5.3 Thresholds of Significance .....................................................................................................3.5 -14

3.5.4 Project Impact Analysis ...........................................................................................................3.5 -14

3.5.5 Cumulative Impact Analysis....................................................................................................3.5 -21

3.5.6 Mitigation Measures ...............................................................................................................3.5 -21

3.5.7 Conclusion ...............................................................................................................................3.5 -21

3.6 Greenhouse Gas Emissions .................................................................................................. 3.6-1

3.6.1 Existing Conditions .................................................................................................................... 3.6-1

3.6.2 Regulatory Setting ..................................................................................................................... 3.6-2

3.6.3 Thresholds of Significance .....................................................................................................3.6 -14

3.6.4 Project Impact Analysis ...........................................................................................................3.6 -15

3.6.5 Cumulative Impact Analysis....................................................................................................3.6 -20

3.6.6 Mitigation Measures ...............................................................................................................3.6 -20

3.6.7 Conclusion ...............................................................................................................................3.6 -21

3.7 Land Use and Planning ......................................................................................................... 3.7-1

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

3.7.2 Regulatory Setting ..................................................................................................................... 3.7-7

3.7.3 Thresholds of Significance .....................................................................................................3.7 -14

3.7.4 Project Impact Analysis ...........................................................................................................3.7 -14 Table of Contents
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page iii

3.7.5 Cumulative Impact Analysis....................................................................................................3.7 -23

3.7.6 Mitigation Measures ...............................................................................................................3.7 -24

3.7.7 Conclusion ...............................................................................................................................3.7 -24

3.8 Noise ..................................................................................................................................... 3.8-1

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

3.8.2 Regulatory Setting ..................................................................................................................... 3.8-4

3.8.3 Thresholds of Significance ....................................................................................................... 3.8-9

3.8.4 Project Impact Analysis ...........................................................................................................3.8 -12

3.8.5 Cumulative Impact Analysis....................................................................................................3.8 -23

3.8.6 Mitigation Measures ...............................................................................................................3.8 -23

3.8.7 Conclusion ...............................................................................................................................3.8 -24

3.9 Population and Housing ........................................................................................................ 3.9-1

3.9.1 Existing Conditions .................................................................................................................... 3.9-1

3.9.2 Regulatory Setting ..................................................................................................................... 3.9-2

3.9.3 Thresholds of Significance ....................................................................................................... 3.9-5

3.9.4 Project Impact Analysis ............................................................................................................. 3.9-6

3.9.5 Cumulative Impact Analysis...................................................................................................... 3.9-7

3.9.6 Mitigation Measures ................................................................................................................. 3.9-7

3.9.7 Conclusion ................................................................................................................................. 3.9-8

3.10 Public Services .................................................................................................................... 3.10-1

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

3.10.2 Regulatory Setting ...................................................................................................................3.10- 3

3.10.3 Thresholds of Significance .....................................................................................................3.10- 5

3.10.4 Project Impact Analysis ...........................................................................................................3.10- 5

3.10.5 Cumulative Impact Analysis....................................................................................................3.10- 8

3.10.6 Mitigation Measures ...............................................................................................................3.10- 9

3.10.7 Conclusion ...............................................................................................................................3.10- 9

3.11 Transportation ..................................................................................................................... 3.11-1

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

3.11.2 Regulatory Setting ...................................................................................................................3.11- 3

3.11.3 Thresholds of Significance .....................................................................................................3.11- 9

3.11.4 Project Impact Analysis ...........................................................................................................3.11- 9

3.11.5 Cumulative Impact Analysis................................................................................................. 3.11-12

3.11.6 Mitigation Measures ............................................................................................................ 3.11-12

3.11.7 Conclusion ............................................................................................................................ 3.11-12

3.12 Tribal Cultural Resources .................................................................................................... 3.12-1

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

3.12.2 Regulatory Setting ...................................................................................................................3.12- 6

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

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

3.12.5 Cumulative Impact Analysis....................................................................................................3.12- 9

3.12.6 Mitigation Measures ............................................................................................................ 3.12-10

3.12.7 Conclusion ............................................................................................................................ 3.12-14

3.13 Utilities and Service Systems ............................................................................................. 3.13-1

3.13.1 Existing Conditions ..................................................................................................................3.13- 2

3.13.2 Regulatory Setting ...................................................................................................................3.13- 7 Table of Contents
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City of San Marcos Page iv

3.13.3 Thresholds of Significance .................................................................................................. 3.13-12

3.13.4 Project Impact Analysis ........................................................................................................ 3.13-12

3.13.5 Cumulative Impact Analysis................................................................................................. 3.13-21

3.13.6 Mitigation Measures ............................................................................................................ 3.13-24

3.13.7 Conclusion ............................................................................................................................ 3.13-24

4.0 Alternatives ................................ ................................ ................................ ............................. 4-1

4.0 Introduction to Alternatives ......................................................................................................4-1

4.1 Project Objectives ......................................................................................................................4-1

4.2 Project Alternatives Considered in This EIR .............................................................................4-2

4.2.1 Description of Alternative ............................................................................................................ 4-2

4.2.2 Summary of Impacts .................................................................................................................... 4-2

4.2.3 No Project/No Development Alternative..................................................................................... 4-3

4.2.4 No Project/Existing Plan Alternative ........................................................................................... 4-7

4.2.5 Reduced Development Footprint Alternative ........................................................................... 4-13

4.2.6 Reduced Intensity Alternative.................................................................................................... 4-18

4.3 Alternatives Considered But Rejected .................................................................................. 4-22

4.3.1 Alternative Location ................................................................................................................... 4-23

4.4 Environmentally Superior Alternative .................................................................................... 4-23

5.0 Environmental Effects Found not to be Significant ................................ ................................ 5-1

5.0 Aesthetics ..................................................................................................................................5-1

5.1 Agriculture and Forestry Resources .........................................................................................5-2

5.2 Biological Resources .................................................................................................................5-3

5.3 Geology and Soils ......................................................................................................................5-4

5.4 Hazards and Hazardous Materials ...........................................................................................5-6

5.5 Hydrology and Water Quality .................................................................................................. 5-10

5.6 Land Use and Planning .......................................................................................................... 5-14

5.7 Mineral Resources ................................................................................................................. 5-14

5.8 Noise ...................................................................................................................................... 5-14

5.9 Population and Housing ......................................................................................................... 5-15

5.10 Public Services ....................................................................................................................... 5-15

5.11 Recreation............................................................................................................................... 5-15

5.12 Transportation ........................................................................................................................ 5-16

5.13 Wildfire .................................................................................................................................... 5-16

6.0 Other CEQA Considerations ................................ ................................ ................................ .... 6-1

6.0 Significant and Unavoidable Impacts ......................................................................................6-1

6.1 Growth Inducement ...................................................................................................................6-1

6.2 Significant Irreversible Environmental Changes .....................................................................6-2

7.0 References ................................ ................................ ................................ .............................. 7-1

8.0 List of Preparers................................ ................................ ................................ ...................... 8-1

Table of Contents
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page v
Technical Appendices (included on USB)
Appendix A.1 Specific Plan
Appendix A.2 Project Plans
Appendix A.3 Landscape Plan
Appendix B.1 Initial Study Checklist
Appendix B.2 Notice of Preparation
Appendix B.3 NOP Comment Letters
Appendix C Air Quality Assessment
Appendix D Biological Resources Report
Appendix E Greenhouse Gas Report
Appendix F Climate Action Plan Checklist
Appendix G Energy Report
Appendix H Geotechnical Report
Appendix I Phase 1 Environmental Site Assessment
Appendix J Phase 2 Environmental Site Assessment
Appendix K Due Diligence Memorandum
Appendix L Statement of Clarification
Appendix M Drainage Study
Appendix N Stormwater Quality Management Plan
Appendix O Local Transportation Analysis
Appendix P Noise Assessment
Appendix Q SMUSD Response
Appendix R Vehicle Miles Traveled Analysis
Appendix S Water/Sewer Study

List of Tables
Table 1-1. Summary of Potentially Significant Environmental Impacts ............................................... 1-2 Table 1-2. Comparison of Impacts of Proposed Project and Alternatives ............................................ 1-7 Table 1-3. Summary of Alternatives and Project Objectives ................................................................. 1-8 Table 2-1. Project Design Features ......................................................................................................... 2-8 Table 2-2. Required Actions and Approvals ......................................................................................... 2-16 Table 2-3. Cumulative Projects ............................................................................................................. 2-17 Table 3.1-1. Aesthetics Summary of Impacts ........................................................................................ 3-2 Table 3.2-1. Air Quality Summary of Impacts ...................................................................................... 3.2-1 Table 3.2-2. San Diego County Air Basin Attainment Status by Pollutant ......................................... 3.2-3 Table 3.2-3. Two Year Ambient Air Quality Summary Near the Project Site (Camp Pendleton or Carmel Mountain Ranch Stations) ............................................................................................................ 3.2-4 Table 3.2-4. Ambient Air Quality Standards ........................................................................................ 3.2-7 Table 3.2-5. Screening-Level Criteria for Air Quality Impacts ........................................................... 3.2-12 Table 3.2-6. Construction Emissions (Pounds/Day) ......................................................................... 3.2-16 Table 3.2-7. Operational Emissions (Pounds/Day) ........................................................................... 3.2-17 Table 3.3-1. Biological Resources Summary of Impacts .................................................................... 3.3-1 Table 3.3-2. Vegetation Community/Land Cover Types within Project Site ...................................... 3.3-3 Table of Contents
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City of San Marcos Page vi
Table 3.3-3. Vegetation Community/Land Cover Impacts ............................................................... 3.3-16 Table 3.4-1. Cultural Resources Summary of Impacts ....................................................................... 3.4-1 Table 3.5-1. Energy Summary of Impacts ........................................................................................... 3.5-1 Table 3.5-2. Proposed Construction Phase and Duration Equipment............................................. 3.5-16 Table 3.5-3. Annual Energy Use for Proposed Project and General Plan Buildout (Data Center) Scenario ....................................................................................................................................... 3.5-18 Table 3.5-4. Project Consistency with Applicable CAP Checklist Measures .................................... 3.5-19 Table 3.6-1. Greenhouse Gas Emissions Summary of Impacts ......................................................... 3.6-1 Table 3.6-2. Proposed Project Expected Annual Construction Emissions Summary (MT/Year).... 3.6-16 Table 3.6-3. Proposed Project Operational Emissions Summary (MT/Year) .................................. 3.6-17 Table 3.6-4. Project Consistency with Applicable CAP Checklist Measures .................................... 3.6-18 Table 3.7-1. Land Use Summary of Impacts ....................................................................................... 3.7-1 Table 3.7-2. Signalized Intersection LOS Operational Analysis Method ........................................... 3.7-3 Table 3.7-3. LOS Criteria for Stop-Controlled Unsignalized Intersections ......................................... 3.7-4 Table 3.7-4. Roadway Segment Daily Capacity and LOS Standards ................................................. 3.7-4 Table 3.7-5. Peak Hour Intersection LOS – Existing Conditions ........................................................ 3.7-6 Table 3.7-6. Roadway Segment LOS Results – Existing Conditions .................................................. 3.7-7 Table 3.7-8. Project Trip Generation .................................................................................................. 3.7-17 Table 3.7-9. Near-Term Year 2025 - Intersection Operations Without and With Project ............... 3.7-18 Table 3.7-10. Near-Term Year 2025 Roadway Segment Operations Without and With Project ... 3.7-20 Table 3.7-11. Horizon Year (2050) Intersection Operations Without and With Project ................. 3.7-21 Table 3.7-12. Near-Term Year 2025 Roadway Segment Operations Without and With Project ... 3.7-23 Table 3.7-7. Project Consistency with Applicable San Marcos General Plan Goals and Policies .. 3.7-26 Table 3.8-1. Noise Summary of Impacts ............................................................................................. 3.8-1 Table 3.8-2. Measured Long-Term Noise Levels ................................................................................ 3.8-3 Table 3.8-3. Exterior Noise Standards by Zone .................................................................................. 3.8-8 Table 3.8-4. Permitted Increase in Noise Levels ................................................................................ 3.8-9 Table 3.8-5. Permitted Increase in Interior Noise Levels ................................................................... 3.8-9 Table 3.8-6. Groundborne Vibration and Noise Impact Criteria (Human Annoyance).................... 3.8-10 Table 3.8-7. Groundborne Vibration Impact Criteria (Structural Damage) ..................................... 3.8-11 Table 3.8-8. Construction Noise Levels ............................................................................................. 3.8-14 Table 3.8-9. Construction Noise Levels from Rock Drill ................................................................... 3.8-15 Table 3.8-10. Rock Crushing Noise Levels (Residential Receptors) ............................................... 3.8-16 Table 3.8-11. Rock Crushing Noise Levels (Commercial Receptors) .............................................. 3.8-16 Table 3.8-12. Future Traffic Parameters ........................................................................................... 3.8-17 Table 3.8-13. Future Exterior Noise Levels Before Balcony Design Features ................................ 3.8-19 Table 3.8-14. Future Exterior Noise Levels with Balcony Design Features..................................... 3.8-20 Table 3.8-15. Project HVAC Noise Levels (Eastern Residential Property Line) ............................... 3.8-21 Table 3.8-16. Vibration Levels from Construction Activities (Residential Receptors) .................... 3.8-22 Table 3.9-1. Population/Housing Summary of Impacts ..................................................................... 3.9-1 Table 3.9-2. Forecasted Growth for the San Diego Region and the City of San Marcos .................. 3.9-4 Table 3.10-1. Public Services Summary of Impacts ......................................................................... 3.10-1 Table 3.10-2. Student Generation ..................................................................................................... 3.10-7 Table 3.11-1. Transportation Summary of Impacts .......................................................................... 3.11-1 Table 3.11-2. Project Vehicle Miles Traveled Analysis .................................................................. 3.11-11 Table 3.12-1. Tribal Cultural Resources Summary of Impacts ........................................................ 3.12-1 Table 3.13-1. Utilities and Service Systems Summary of Impacts .................................................. 3.13-1 Table 3.13-2. Metropolitan Water District Total Water Demands in Acre Feet Per Year ............... 3.13-3 Table 3.13-3. Projected Wastewater Flows within VWD Service Area ............................................. 3.13-4 Table of Contents
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Table 3.13-4. Estimated Water Demands for Proposed Project ................................................... 3.13-14 Table 3.13-5. Potable Water Pipeline Results under Maximum Day Demand plus Fire Flow Conditions .................................................................................................................................................. 3.13-14 Table 3.13-6. Existing Reservoir Storage Capacity and Requirements ........................................ 3.13-15 Table 4-1. Summary of Alternatives and Project Objectives ............................................................... 4-24 Table 4-2. Comparison of Impacts of Proposed Project and Alternatives .......................................... 4-26

List of Figures
Figure 2-1. Project Location and Vicinity .............................................................................................. 2-20 Figure 2-2. Conceptual Site Plan .......................................................................................................... 2-21 Figure 2-3. Conceptual Landscape Plan............................................................................................... 2-22 Figure 2-4. Building Elevations ............................................................................................................. 2-23 Figure 2-5. Wall and Fencing Plan ........................................................................................................ 2-24 Figure 2-6. Lighting Plan ........................................................................................................................ 2-25 Figure 3.1-1. Site Photos Key Views ....................................................................................................... 3-9 Figure 3.1-2. View 1 - Southwest Corner Looking Northeast .............................................................. 3-10 Figure 3.1-3. View 2 – Southeast Corner Looking Northwest ............................................................. 3-11 Figure 3.1-4. View 3 – Northwest Corner Looking Southeast ............................................................. 3-12 Figure 3.1-5. View 4 – Northeast Corner Looking Southwest ............................................................. 3-13 Figure 3.1-6. View 5 – Offsite Fencing ................................................................................................. 3-14 Figure 3.1-7. View 6 – Eastern Property Line ....................................................................................... 3-14 Figure 3.1-8. View 7 – Western Property Line ..................................................................................... 3-15 Figure 3.1-9. View 8 – Looking Northwest from Project Site .............................................................. 3-16 Figure 3.3-1. Vegetation Communities and Land Cover Types ........................................................ 3.3-24 Figure 3.3-2. Proposed Impacts to Vegetation Communities and Land Cover Types .................... 3.3-25 Figure 3.7-1. Existing Conditions – Traffic Analysis Area .................................................................. 3.7-25 Figure 3.8-1. Ambient Monitoring Location ....................................................................................... 3.8-26 Figure 3.8-2. Area of Enhanced Shielding on Patios and Balconies ............................................... 3.8-27 Figure 3.8-3. Modeled Receptor Locations ....................................................................................... 3.8-28 Figure 3.8-4. Locations of Proposed HVAC Units .............................................................................. 3.8-29 Figure 3.11-1. Project Location within SANDAG SB 743 VMT Map .............................................. 3.11-13

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Acronyms
μg/m3 Micrograms per Cubic Meter
AAQS Ambient Air Quality Standards
AB Assembly Bill
AC Acre
ADT Average Daily Traffic
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plan
AMI Area Median Income
AMSL Above Mean Sea Level
ANFO Ammonia Nitrate and Fuel Oil
ANSI American National Standards Institute
APN Assessor’s Parcel Number
AQIA Air Quality Impact Assessment
ASTM American Society for Testing and Materials
ATP Active Transportation Plan
BAU Business-as-Usual
BMP Best Management Practices
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
CAL FIRE California Department of Forestry and Fire Protection CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards Code
Cal/OES California Office of Emergency Services
CalRecycle Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CARB California Air Resources Board
CaRFG California Reformulated Gasoline
CAS California Approved Samplers
CBC California Building Code
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFD Community Facilities District
CFS Cubic Feet Per Second
CH4 Methane
CHRIS California Historical Resources Information System CIP Capital Improvement Program
CLTL Continuous Left-Turn Lane
CMP Congestion Management Plan
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO Carbon Monoxide
Acronyms
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page ix
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent
COPPS Community Oriented Policing and Problem Solving
CPTED Crime Prevention Through Environmental Design
CPUC California Public Utilities Commission
CRPR California Rare Plant Rank
CRHR California Register of Historic Resources
CSUSM California State University San Marcos
CUP Conditional Use Permit
CWA Clean Water Act
CWC California Water Code
CY Cubic Yard
dB Decibel
dBA A-Weighted Decibel
dc Direct Current
DDE Dichlorodiphenyldichloroethylene
DEIR Draft Environmental Impact Report
DOF Department of Finance
DOT Department of Transportation
DPM Diesel Particulate Matter
DU Dwelling Unit
DU/AC Dwelling Unit/Acre
EDCO EDCO Waste and Recycling
EIR Environmental Impact Report
EISA Energy Independence and Security Act
EO Executive Order
EOP Emergency Operations Plan
EPA Environmental Protection Agency
ESA Environmental Site Assessment
EV Electric Vehicle
EWPCF Encina Water Pollution Control Facilities
FAR Floor Area Ratio
FEIR Final Environmental Impact Report
FEMA Federal Emergency Management Agency
FESA Federal Endangered Species Act
FHWA Federal Highway Administration
FPA Focused Planning Area
FT Feet
FT/S Feet per Second
FTA Federal Transit Administration
GHG Greenhouse Gas
GIS Geographic Information System
GPA General Plan Amendment
GPD Gallons per Day
GPNE General Plan Noise Element
GPR Ground Penetrating Radar
GW Gigawatt
GWP Global Warming Potential
H2S Hydrogen Sulfide
Acronyms
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page x
HAP Hazardous Air Pollutant
HCFC Hydrochlorofluorocarbon
HERO Human and Ecological Risk Office
HFC Hydrofluorocarbon
HVAC Heating, Ventilation, and Air Conditioning
IEPR Integrated Energy Policy Report
IIRP Individual Integrated Resource Plan
IPCC Intergovernmental Panel on Climate Change
IRP Integrated Resource Plan
IS Initial Study
KBtu One Thousand British Thermal Units
kWh Kilowatt-Hour
Lbs Pounds
LCFS Low Carbon Fuel Standard
LED Light Emitting Diode
Leq Equivalent Sound Level
LLG Linscott, Law & Greenspan
LOS Level of Service
LTA Local Transportation Analysis
LTS Less than Significant
LTSM Less than Significant with Mitigation
LUST Leaking Underground Storage Tank
MBTA Migratory Bird Treaty Act
MFR Multi-Family Residential
MG Million Gallon
MG/M3 Milligrams per Cubic Meter
MGD Million Gallons per Day
MHCP Multiple Habitat Conservation Plan
MM Mitigation Measure
MMT Million Metric Tons
MPH Miles per Hour
MRF Meadowlark Reclamation Facility
MRZ Mineral Resource Zone
MT Metric Ton
MW Megawatt
MWD Metropolitan Water District
MWdc Megawatt direct current
MWH Megawatt Hour
N2 Nitrogen
N2O Nitrous Oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Planning
NCTD North County Transit District
NEV Neighborhood Electric Vehicle
N. North
NO2 Nitrogen Dioxide
NOP Notice of Preparation
NOx Nitrogen Oxides
Acronyms
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page xi
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
NSLU Noise Sensitive Land Use
NTA Northern Tributary Area
O2 Oxygen
O3 Ozone
OCP Organochlorine Pesticide
OHWM Ordinary High Water Mark
OPR Office of Planning and Research
Pb Lead
PFC Perfluorocarbon
PFF Public Facility Fee
PG&E Pacific Gas & Electric
PI Public/Institutional
PM2.5 Particulate Matter Less than 2.5 Microns in Diameter PM10 Particulate Matter Less than 10 Microns in Diameter POC Point of Confluence
PPB Parts per Billion
PPHM Parts per Hundred Million
PPM Parts per Million
PPV Peak Particle Velocity
PRC Public Resources Code
PV Photovoltaic
PVC Polyvinyl Chloride
RAQS Regional Air Quality Strategies
REC Recognized Environmental Condition
REL Reference Exposure Levels
RFS Renewable Fuel Standard
RHNA Regional Housing Needs Allocation
RMS Root Mean Square
ROG Reactive Organic Gas
ROW Right-of-Way
ROZ Ridgeline Overlay Zone
RPS Renewable Portfolio Standard
RSL Regional Screening Level
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
S.F. Square Feet
SF6 Sulfur Hexafluoride
SANDAG San Diego Association of Governments
SB Senate Bill
SCAQMD South Coast Air Quality Management District
SCIC South Coastal Information Center
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCWA San Diego County Water Authority
SDG&E San Diego Gas & Electric
SDNR San Diego Northern Railroad
Acronyms
Armorlite Lofts Specific Plan Draft EIR January 2025
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SDP Site Development Plan
SFR Single Family Residential
SIP State Implementation Plans
SLCP Short-Lived Climate Pollutants
SMFD San Marcos Fire Department
SMFPD San Marcos Fire Protection District
SMUSD San Marcos Unified School District
SO2 Sulfur Dioxide
SPA Specific Plan Area
SR-78 State Route 78
SRTS Safe Route to School
SSC Species of Special Concern
STP Shovel Test Pit
SVFC Specific Volumetric Fuel Consumption
SWPPP Stormwater Pollution Prevention Plan
SWQMP Stormwater Quality Management Plan
SWRCB State Water Resources Control Board
TAC Toxic Air Contaminant
T-BACT Toxics Best Available Control Technology
TCA Traditionally and Culturally Affiliated
TDM Transportation Demand Management
TIA Transportation Impact Analysis
TIAG Transportation Impact Analysis Guidelines
TPHv Total Petroleum Hydrocarbons as Vapor
USACE U.S. Army Corps of Engineers
USCB U.S. Census Bureau
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UST Underground Storage Tank
UWMP Urban Water Management Plan
V/C Volume-to-Capacity
VdB Vibration Velocity
VHFHSZ Very High Fire Hazard Severity Zone
VMT Vehicle Miles Traveled
VOC Volatile Organic Compound
VPHPL Vehicles per Hour per Lane
VWD Vallecitos Water District
WELO Water Efficiency Landscape Ordinance
WQIP Water Quality Improvement Plan
ZEB Zero Emission Bus
ZEV Zero Emission Vehicle

Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 1-1

1.0 Summary

1.0 Project Summary
The applicant, Las Posas Ventures LLC, is proposing to develop 1 65 apartment units, 5,600 square feet (s.f.) of commercial use and associated common and private open space on a 2. 44 acre site located on Armorlite Drive in the City of San Marcos.

The project applicant is requesting the following discretionary approvals from the City to allow for development of the proposed project:
• Specific Plan (SP23 -0001) – The Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan. The Specific Plan would be required to be reviewed and approved concurrently with the Multi-Family Site Development Plan application.
• General Plan Amendment (GPA23-0002) – A General Plan Amendment would be required to change the existing Public/Institutional (PI) designation to Specific Plan Area (SPA). • Rezone (R22-0001) - A rezone would be required to change the existing Public-Institutional (P- I) zoning to Specific Plan Area (SPA).
• Site Development Plan (SDP23-0003) - The Site Development Plan approval would be required to construct 165 apartment units and 5,600 s.f. of commercial and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Conditional Use Permit (CUP23-0002) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

1.1 Summary of Significant Effects/Mitigation
Table 1 -1 provides a summary of potentially significant environmental impacts resulting from the project, mitigation measures identified to reduce and/or avoid the environmental effects, and a determination of the level of significance of each impact following impl ementation of the identified mitigation measures. The analysis shows that, with implementation of mitigation measures, all project impacts will be mitigated to below a level of significance. Detailed analyses of significant environmental effects and mitigation are provided in Chapter 3 of this Environmental Impact Report (EIR).

In addition to mitigation measures, regulatory standards for grading, construction, and environmental protection have been incorporated into the project design to reduce adverse environmental effects.

These include, but are not limited to, grading design a nd earthwork specifications, erosion control measures, Best Management Practices for pollutant control during construction, and biofiltration basins to handle and treat runoff.

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

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Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 1-2
Table 1-1. Summary of Potentially Significant Environmental Impacts Impact Mitigation Measures Level of Significance After
Mitigation
Biological Resources
BIO-1: Potential to impact avian species
protected under the Migratory Bird
Treaty Act and California Fish and Game
Code 3503.5 and other wildlife if tree
removal, vegetation removal, or other
construction activities occur during the
nesting season.

Implementation of MM-BIO-1a and
MM-BIO-1b, refer to Section 3.3.6 Less than significant BIO-2: The proposed project has the
potential to result in indirect impacts to
sensitive species due to dust, trash, and
accidental transport of non-native plant
species into the project site, and
invasive plant species, and noise and
lighting effects.

Implementation of MM-BIO-2a,
MM-BIO-2b and MM-BIO-2c, refer to
Section 3.3.6
Less than significant
BIO-3: The proposed project would
impact 2.13 acres of Diegan coastal
sage scrub and 0.12 acres of non-native
grassland-broadleaf dominated for a
total of 2.25 acres of impact.

Implementation of MM-BIO-3, refer to
Section 3.3.6 Less than significant
Cultural Resources
CR-1: Due to grading and ground
disturbing activities, the proposed
project may uncover previously
unidentified archeological resources
associated with SDI-5633 or may result
in previously unknown archaeological
resources associated with other time
periods or cultures.

Implementation of MM-CR-1a and
CR-1b, refer to Section 3.4.6 Less than significant
CR:2 There is a potential for project
construction activities to disturb
previously unidentified human remains
on the project site.

Implementation of MM-CR-2, refer to
Section 3.4.6 Less than significant
Noise
N-1: Due to temporary rock drilling and
blasting activities during construction,
the proposed project has the potential to
create noise levels in excess of the 75
dBA standard if rock drilling equipment
is staged closer than 160 feet to an
occupied noise sensitive land use’s
property line.

Implementation of MM-N-1, refer to
Section 3.8.6 Less than significant
N-2: Due to temporary rock crushing
activities, the proposed project has the
potential to create noise levels in excess
of the applied operational noise
standards for multi- family residential
Implementation of MM-N-2, refer to
Section 3.8.6 Less than significant

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Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 1-3
Impact Mitigation Measures Level of Significance After
Mitigation
(65 dBA Leq) and commercial use (70
dBA Leq) if the rock crusher is staged
within 210 feet of a multi-family
residential use or within 160 feet of a
commercial use.

Tribal Cultural Resources
TCR-1: As a result of tribal consultation,
the City has determined that
construction of the proposed project has
the potential to cause a substantial
adverse change to a tribal cultural
resource that is eligible for inclusion in
the California Register of Historical
Resources.

Implementation of MM-TCR-1 through
MM-TRC-10, refer to Section 3.12.6 Less than significant Note: MM = Mitigation Measure

1.2 Areas of Controversy
A Notice of Preparation (NOP) was distributed on February 12, 2024, for a 30-day public review and comment period. Additionally, a public scoping meeting was held on February 15, 2024.

Comments received during the NOP public scoping period were considered part of the preparation of this EIR. The NOP and written comments are included in Appendices B.2 and B.3 to this EIR. Topics raised during the NOP comment period and scoping meeting include:
• Biological Resources: focused surveys, mitigation measures, biological resources report preparation, analysis of direct and indirect impacts, alternatives, and cumulative analysis; • Cultural Resources: San Diego County Archaeological Society will review the Draft EIR when available;
• Transportation: prepare a traffic impact study and CEQA analysis; • Utilities and Service Systems: water and sewer study provided by VWD.

These concerns are addressed in Chapter 3 of this EIR.

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

The lead agency, the City of San Marcos, must respond to each significant effect identified in the EIR by making “Findings” for each significant effect. The issues to be resolved by the decision makers for the project include whether or how to mitigate the associated significant effects, including whether to implement a project alternative.

Issues to be resolved that are directly related to the proposed project include the choice among the alternatives and whether or how to mitigate the significant effects. In particular, the decision makers

1.0 Executive Summary
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 1-4
must decide if the significant impacts to biological resources, cultural resources , noise, and tribal cultural resources have been mitigated to less than significant. Lastly, the decision makers must determine whether any of the project alternatives would substantially reduce significant effects while still meeting key objectives of the project.

1.4 Project Alternatives
Four alternatives are proposed to provide an understanding of how environmental effects could be reduced by varying the design and scope of the project. Table 1-2 provides a comparison of the impacts of project alternatives to the impacts of the proposed project. Table 1-3 identifies each of the project objectives and the ability of each alternative to meet those objectives. Tables 1-2 and 1-3 are included at the end of this section.

1.4.1 No Project/No Development Alternative
Under the No Project/No Development Alternative, the proposed project would not be implemented, and the project site would remain undeveloped and in its current condition. No grading or construction would occur on the project site under this alternative. T he project site is currently undeveloped and supports Diegan coastal sage scrub, non-native grassland, and disturbed habitat.

Since the No Project/No Development Alternative would not develop any residential or commercial uses on the project site, overall impacts would be less than those of the proposed project or eliminated entirely. There are some benefits of the project that w ould not be realized under this alternative, including providing additional housing units, including affordable units, which helps the City meet its Regional Housing Need Allocation numbers. Under this alternative, off -site water, sewer, and stormwater infrastructure improvements would not be realized. Also, under this alternative there would not be any payment of the City’s public facility fees ( PFF), which goes toward supporting a variety of services and improvements in the City, including but not limited to Circulation Streets, State Route78 Interchanges, National Pollutant Discharge Elimination System, Tech Improvements, Parks, and Habitat Conservation. Payment of these fees provides improvements that benefit all residents of the city. Similarly, this alternative would not contribute any school fees. Finally, there would not be any protection or repatriation afforded to the existing cultural resources and tribal cultural resources on the site and they could be subject to future disturbance from those who may access the site without authorization. The No Project/ No Development Alternative would not meet any of the project objectives.

1.4.2 No Project/Existing Plan Alternative
Under the No Project/Existing Plan Alternative, the project site would be developed consistent with the site’s existing land use designation. The project site has an existing General Plan Land Use designation of Public/Institutional (PI) which has a maximu m floor area ratio (FAR) of 3.0. According to Table 2 -3 of the Land Use Element of the City’s G eneral Plan, this designation is for “facilities built and maintained for public use such as academic facilities, institutional uses, community service facilities, water and sewer facilities, detention and drainage facilities, cemeteries, police and fire stations, and other government buildings and properties. This designation may include privately owned facilities built and maintained for public use” (City of San Marcos 2012).

One development scenario that would meet the P -I (Public/Institutional) zoning requirements would be a three story, 160,000 s.f. telecommunications building that would be used as a data center. This is similar to the existing use of the adjacent AT&T facility and since AT&T was the previous owner of

1.0 Executive Summary
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 1-5
the project site, a data center would be a logical alternative use. Overall, the development footprint would stay the same as the proposed project.

The No Project/Existing Plan Alternative would result in fewer average daily trips ( ADT) but would require 285 times more electricity than the proposed project which results in a corresponding proportional increase in air pollutant and greenhouse gas (GHG) emissions.

Footprint-specific impacts, such as those related to biological resources, cultural , and tribal cultural resources, would be similar as the proposed project, as the same amount of site area would be disturbed.

This alternative would not generate any students for San Marcos Unified School District (SMUSD) and would reduce demand for parks, libraries, natural gas, solid waste, water, and sewer services compared to the proposed project. This alternative would result in a vehicle miles traveled ( VMT) impact and would require mitigation to reduce VMT to 85% of the regional mean for employees. Finally, this alternative does not meet any of the project objectives.

1.4.3 Reduced Development Footprint Alternative
Under the Reduced Development Footprint Alternative, the project site would be developed with 14 live/work rowhomes and associated infrastructure. The units would be three stories high and would be a for-sale product. No affordable housing would be proposed under this alternative. Two-car garages would be included on the ground level of each unit and five additional open parking spaces would be provided for a total of 33 space s. This alternative would have a density of 5.83 du/acre and would include seven 3 bed/2.5 bath units (1,600 s.f.) and seven 4 bed/2.5 bath units (1,800 s.f.). Access would be via Armorlite Drive and a drive aisle adjacent to the western project boundary would provide access to some of the townhomes. Private and common open space would be provided consistent with the City’s Outdoor Space Standards (Section 20.255.120 of the San Marcos Municipal Code).

Architectural treatments would be incorporated into the design of this alternative to provide for visual interest and to break up the bulk and scale of the development.

Overall, the development footprint and area of disturbance would be reduced compared to the proposed project, as only 41% of the project site would be disturbed. This results in a corresponding decrease in the amount of grading that would be required for the project.

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 percent of the project site. This alternative would contribute less PFF and school fees since fewer residentia l units would be constructed. This alternative could be designed in a manner that would meet the majority of the project objectives.

1.4.4 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

1.0 Executive Summary
Armorlite Lofts Specific Plan Draft EIR January 2025
City of San Marcos Page 1-6
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, depending on how large the units would be. Pri vate 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.

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.

1.4.5 Environmentally Superior Alternative
Table 1 -2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project. As shown in Table 1 -2 and Table 1 -3 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 if 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.

Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 1-7
Table 1-2. 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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Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 1-8
Table 1-3. 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 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 planning 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

1.0 Executive Summary
Armorlite Lofts Specific Plan Draft EIR January 2025 City of San Marcos Page 1-9
Objective Proposed Project No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Development
Footprint
Alternative
Reduced Intensity
Alternative
Establish development standards and design
guidelines that ensure distinctive architecture,
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 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
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

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Armorlite Lofts Specific Plan Draft EIR January 2025
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2.0 Project Description, Location and Environmental Setting This Draft Environmental Impact Report (EIR) has been prepared by the City of San Marcos to evaluate the potential effects associated with the construction and implementation of the proposed Armorlite Lofts Specific Plan Project (proposed project) as descr ibed in Section 2.2 of this EIR. The EIR is intended to provide information to the San Marcos City Council, public agencies, stakeholders and organizations, and the general public regarding the potential environmental impacts, mitigation measures, and alternatives to the proposed project.

2.1 Project Objectives
The following objectives describe the underlying purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in the EIR. • Maximize housing opportunities close to major transit facilities, education facilities, shopping and employment opportunities, and trails to optimize land use with transit use and active modes of transportation, reduce reliance on automobiles, and potentially reduce greenhouse gas emissions.
• To the extent possible, given site constraints, maximize the opportunity to provide transit - oriented housing for the City of San Marcos up to 67 dwelling units per acre. • Develop high-quality market-rate for rent housing which meets the housing needs of the City of San Marcos and the region.
• Provide an affordable dwelling unit component that satisfies the State of California qualifying affordable housing income category of very -low income (30 to 50% of area median income [AMI]), through development onsite.
• Facilitate connections to the Armorlite Drive complete street circulation system and provide pedestrian friendly architecture and landscaping to promote walkability and connect ivity for people to surrounding transit and places.
• Design a vehicular circulation system that adequately accommodates traffic and minimizes traffic impacts in and around the project area.
• Establish development standards and design guidelines that ensure distinctive architecture, landscaping and recreational amenities that complement and enhance the existing surrounding neighborhood while providing a desirable living environment for resident s within the Specific Plan area.
• Provide flexible (“flex”) Commercial space that is capable of adapting to future market conditions and designed to support potential future retail needs. • Institute a program for the long-term maintenance of the community to ensure all facilities are adequately maintained to City standards.
• Finance or contribute a fair share of funding to all community services and infrastructure needed to support development proposed by the Specific Plan to promote economic stability.

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2.2 Project Description
The approximately 2.44-acre project site is located at 225 N. Las Posas Road. The site is located on the north side of Armorlite Drive generally between N. Las Posas Road to the west and Bingham Drive to the east within the Business/Industrial District in the City of San Marcos (City), California. The Specific Plan a rea was created from the subdivision of the neighboring AT&T lot. The project site is approximately 0.25 miles north of State Route 78 (SR -78) and adjacent to the NCTD SPRINTER Palomar College Station. The assessor parcel number (APN) is 219-162-62-00 (Figure 2-1).

The project applicant is requesting approval of a Specific Plan (SP23-0001), General Plan Amendment (GPA23-0002), Rezone (R23-0001), Site Development Plan (SDP23-0003) and a Conditional Use Permit (CUP23-0002). If approved, these entitlements would allow for the development of a 246,323 square foot (s.f.) building containing 165 apartment units and 5,600 square feet s.f. of commercial use. The conceptual site plan is included in Figure 2-2.

2.2.1 Discretionary Actions
As mentioned above, the requested project entitlements/discretionary actions, and permits by the City include a Specific Plan, General Plan Amendment, Rezone, Site Development Plan, and Conditional Use Permit. Each of these actions is described in more detail below. The Specific Plan is included in Appendix A.1 and the project plans are included in Appendix A.2. • Specific Plan (SP23 -0001) – The Specific Plan establishes the development rules and regulations for all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan. The Specific Plan would be required to be reviewed and approved concurrent ly with the Multi-Family Site Development Plan application.
• General Plan Amendment (GPA23-0002) – A General Plan Amendment would be required to change the existing PI (Public Institutional) designation to Specific Plan Area (SPA). • Rezone (R22-0001) - A rezone would be required to change the existing Public-Institutional (P- I) zoning to Specific Plan Area (SPA).
• Site Development Plan (SDP23-0003) - The Site Development Plan approval would be required to construct 165 apartment units and 5,600 s.f. of commercial and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Conditional Use Permit (CUP23-0002) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

2.2.2 Project Characteristics
This section details the characteristics of the proposed project.

2.2.2.1 Land Use
Residential Land Use
The project proposes 165 residential apartments . The Specific Plan proposes providing 15% of the base density total dwelling units as affordable housing units in the very-low income level (30% to 50%

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of the Area Median Income or AMI) 1. Per State density bonus law (AB 2345), a 50% increase of the base market rate units is allowed. The base density of the site utilizes MU-2 zoning and a maximum of 45 dwelling units per acre, which equates to a total of 110 units for the 2.44 -acre site. To utilize the 50% density bonus, a total of 17 affordable housing units would be included as part of the project, thereby adding 55 market rate units based on 50% of the base density of 110 dwelling units, for a maximum total of 165 dwelling units (67.6 du/acre). The conceptual site plan is included as Figure 2- 2 at the end of this section.

Commercial Use
The project proposes 5,600 s.f. of commercial use. This would be on the ground-floor facing Armorlite Drive adjacent to the project’s entrance.

Retail/Flex Space Concept
The Specific Plan includes a provision for Flex Space. Flex Space allows for commercial, retail, and office uses, as well as the temporary conversion of commercial space to residential units. Section

3.2.1.1 of the Specific Plan provides more detail and supporting documentation on the market conditions affecting commercial vacancies.

Open Space
The project provides a total of 47,375 s.f. of open space which includes a mix of common open space, and private open space, as further detailed below.

Common Open Space
Common open space is for the shared use of residents. The project design proposes 36,944 s.f. of common outdoor open space (32% of the project site). This includes 20,196 s.f. of ground -level common open space consisting of passive areas (18,320 s.f.) and a dog park with dog washing station (1,876 s.f.). On the second level would be 16,748 s.f. of common open space including 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 Private Open Space
Private open space is associated with private patio and balcony areas on the residential units and totals 10,431 s.f. The private open space consists of patios and balconies ranging from 55 s.f. to 80 s.f., depending on the unit type and location.

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

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Cultural Resources Repatriation Area
An approximate 100 s.f. area would be set aside on the project site should repatriation of cultural resources be the preferred approach for any found resources. This area would be subject to a conservation easement.

Landscape Plan
The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes low and moderate water use species. Proposed tree species include: golden rain tree, Chinese pistache, fern pine, African suman, Japanese zelkova, Chitalpa, king palm, queen palm, Marina strawberry tree, gold medallion tree, desert museum palo verde, Brisbane box, Swan Hill fruitless olive, Mexican palo verde, tree aloe, eastern redbud, western redbud, and crape myrtle. The proposed project would also comply with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20. The landscape concept plan is included as Figure 2-3 and the complete landscape plan and planting palette is included in Appendix A.3.

2.2.2.2 Architectural Design
One building is proposed and would have four stories of stacked flats over one level of podium parking (five stories total). The commercial use would be on the ground level. The building would have a maximum height of 74 feet. Overall, the project proposes 93 one bedroom/one bath units (ranging from 620 s.f. to 670 s.f.) and 72 two bedroom/one bath units (ranging from 875 s.f. to 1,020 s.f.). All units would be single story. Proposed materials include stucco walls, siding, stone veneer, metal and glass railings, metal or stucco awnings, decorative stucco frame and the use of decorative metal grills.

Building elevations are presented in
Figure 2-4.

Walls and Fencing
Walls and fencing within the proposed project are functional boundaries framing outdoor spaces and complementary pieces of the landscape design. Walls and fences create partitions between private open space, screen the development from roadways and enhance the overall site design.

The wall and fencing exhibit is included as Figure 2-5. Fencing for the project includes a mix of split face block and tubular steel fencing. Along the northern project boundary would be a 5-foot split face block wall. Along the western and eastern project boundary 5-foot tubular steel fencing would be used.

The proposed dog park would have 4-foot tubular steel fencing.

An existing retaining wall topped with cable rail is current located adjacent to the project’s eastern boundary. Th at retaining wall would remain. The project w ould construct a retaining wall along a portion of the northern project boundary.

Lighting
Lighting for the proposed project would be used to accent landscaping and provide safety and accent lighting for the building. The lighting concept plan is included as Figure 2-6. Proposed lighting fixtures
include pole lights, bollard lights, louvered recessed wall lighting, uplit lighting for the entry monument and accent trees. Festoon lighting is proposed for the outdoor common space. All li ghting fixtures for the proposed project would be energy efficient, architecturally appropriate, and designed to minimize glare, conflict, and light pollution, while providing illumination levels that create a safe environment for both vehicles and pedestrians. Street area lights would be full cut -off fixtures and would utilize

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house-side shields to reduce light trespass and prevent light pollution. Lighting requirements are detailed in Section 3.4.1 of the Specific Plan and all l ighting would be required to conform with the City’s lighting ordinance and standards, (San Marcos Municipal Code Title 20, Section 20.300.080).

Access, Circulation and Parking
Access and Circulation
Access to the project site would be via one unsignalized driveway on Armorlite Drive. The entrance driveway would be ungated and would be 24-feet wide. Internal vehicular movement would be via a minimum 24- foot-wide drive aisle. Secondary emergency -only access would be provided at the northwest corner of the project site and would be accessed through the adjacent AT&T parcel (APN 219-162-61-00).

Parking
Per the San Marcos Municipal Code Section 20.340 (Off -Street Parking and Loading) 339 spaces would be required for the residential use and 23 spaces would be required for the commercial use (362 total). However, per the requirements of Measures T -12 of the City’s Climate Action Plan (CAP), the project is required to reduce its total required parking by 27% (264 total) since the site is within one half mile of a major transit station. To meet the requirements of the CAP, the project would provide 247 spaces for the residential use (69 garage standard spaces, 102 garage tandem spaces, 18 tuck under spaces and 58 open spaces) and 17 spaces for the commercial use. Commercial parking requirements would be met by providing 7 open parking spaces, and 10 of the residential open spaces would be available for commercial use from 9:00 AM to 5:00 PM to meet the required 17 spaces. The project design includes 13 Level 2 electric vehicle (EV) spaces, 62 EV ready spaces and 25 EV capable spaces

2. The project also includes 34 bicycle parking spaces.

2.2.2.3 Grading and Construction Phase
The project is anticipated to start construction in 2026 with full occupancy in late 2027/early 2028.

Grading would consist of approximately 6,950 cubic yards (CY) of cut material and 4,400 CY of fill material requiring an export of approximately 2,250 CY of material once materials shrinkage is considered. Assuming use of 15 CY trucks and 15 workdays, this equates to approximately 10 truck trips per day.

Grading cuts will range from 3 to 7 feet , with maximum fill depths of 9.5 feet. The project design incorporates retaining walls along most of the northern project boundary and along a portion of the eastern boundary. Retaining wall heights would be a maximum of 4 feet on the northern boundary and up to 9 feet on the eastern boundary. Blasting and the use of a temporary rock crusher may be required due to bedrock conditions on the project site.

The import and export of earth material is guided by Section 17.32.080 of the City’s Municipal Code and prior to any import of soils, a haul route would be submitted for review and approval by the City Engineer. Additionally, Municipal Code Sections 10.24.020 and Section 17.08.080 limit the hours of grading, extraction, and construction activities to between the hours of 7:00 AM and 6:00 PM, Monday

2 An EV capable space provides the infrastructure (conduit, breaker space, junction box, etc.) for the future installation of an EV charging station. An EV ready space has all the required infrastructure installed, including the wires and circuit breakers.

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through Friday, 8:00 AM and 5:00 PM Saturdays, No grading, extraction or construction is allowed on Sundays or City holidays.

The project would comply with San Diego Air Pollution Control District (SDAPCD) Rule 55 – Fugitive Dust Control. This rule limits airborne dust beyond the property line and the property line and roadway dust associated with construction equipment and trucks.

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

17.60.06 as it relates to blasting and blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. Blasting also require s issuance of a Blasting Permit from the San Marcos Fire Department. If blasting occurs, notification of surrounding property owners would be required consistent with Section 17.60.06 of the City’s Municipal Code.

The project’s requested approvals include a Conditional Use Permit (CUP23--0002), which would allow for the use of the temporary rock crusher. A rock crusher is required due to the bedrock conditions on the project site and for implementation of the proposed grading plan. Rock crushing could occur between 7:00 AM and 4:00 PM and the duration of rock crushing is two to three weeks. The rock crusher, a Thunderbird Hazemag impact crusher, would be located in the northwest corner of the project site, which woul d position the crusher as far as possible from the existing residences to the east and south. The crusher would be approximately 300 feet from the multi -family residential units to the east and approximately 500 feet from the residential uses to the south.

2.2.2.4 Public Utilities and Services
Water and Wastewater Facilities
The project site lies within the service area of Vallecitos Water District (VWD) for water service and sewer service. The project would connect to the existing 8 -inch water main in Armorlite Drive for potable water and fire protection. Three water connections are proposed for the project site. One potable water connection and one connection for the fire service line will occur at the southwestern corner of the project site with Armor lite Drive. A landscaping irrigation connection is also proposed approximately at the center of the project’s southern property line along Armorlite Drive. For sewer service, the project would connect to the existing 8 -inch sewer main in Armorlite Drive. Offsite water and sewer improvements are discussed later in this section.

Site Drainage and Stormwater Management
Storm drain systems and connections would be designed using best management practices (BMPs) to accommodate the proposed future development. The project would construct two biofiltration basins (BMP-A and BMP -B) for stormwater quality and a stormwater vault (BMP -C). These features would collect stormwater from the building paved areas and direct the stormwater through stormwater drainage pipes to points of confluence ( POCs). The project would also construct storm drain improvements in Armorlite Drive to connect the project to the existing storm drain system in Armorlite Drive. This includes the installation of approximately 175 feet of 12-inch reinforced concrete storm drain to provide the connection between the project site and the downstream storm drain. T his work would take place within the Armorlite Drive right -of-way and full pavement restoration would be required once the work is completed. All storm water quality and drainage facilities would be required

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with final engineering submittals in conformance with the 2023 City of San Marcos Best Management Practices Design Manual, and the project’s Storm Water Quality Management Plan and Drainage Study.

Electricity and Gas
The project would be served by San Diego Gas & Electric (SDG&E) for electricity and gas service. The design for the dry utilities connection are still under preparation ; however, the project would connect to existing underground infrastructure within Armorlite Drive. This work would take place within existing right-of-way and would not disturb any vegetation.

Solid Waste Disposal
Solid waste collection and recycling services to the proposed project would be provided by EDCO Waste & Recycling. Non -recyclable waste, including general trash and green materials, would be collected and transported to the Sycamore Sanitary Landfill in Santee. Recyclable materials would be transferred to the Escondido Resources Recovery Transfer Station for further processing.

Fire Protection
The project is located within the San Marcos Fire Protection District (SMFPD) boundary. The San Marcos Fire Department (SMFD) would provide fire protection for urban and wildland fires and emergency services to the project site. SMFD services San Marcos with four stations, the closest of which is Fire Station No. 1 located at 180 W. Mission Road, approximately 1.4 miles west of the project site.

Police Protection
Police protection for the proposed project would be provided by the County of San Diego Sheriff’s Department. The County Sheriff provides contract law enforcement services to the City of San Marcos through the station located at 182 Santar Place, approximately 2.5 miles east of the project site.

Schools
The project site is within the San Marcos Unified School District (SMUSD) boundary. SMUSD is 49 square miles in size and encompasses most of the City of San Marcos and portions of the Cities of Vista, Escondido, and Carlsbad, as well as the unincorporated areas of the County of San Diego between these cities. The project would generate approximately 82 students for SMUSD. Students generated by the project would attend La Mirada Academy (grades K-8) and San Marcos High School (grades 9-12).

Parks
There are 24 community parks, 13 neighborhood parks and three recreation centers in the City. The closest park to the project site is Innovation Park. Innovation Park, located at 1151 Armorlite Drive , has a dog park, pickleball court, play equipment, permanent restrooms, and picnic tables.

Libraries
The City is served by the San Diego County Library. The San Marcos Branch is located at 2 Civic Center Drive, approximately 1.75 miles west of the project site.

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2.2.2.5 Offsite Improvements
Water and Wastewater Infrastructure
The project includes the following off-site water and sewer improvements. These improvements would be completed prior to project occupancy and would occur within existing roadways:
• Upsize approximately 223 feet of 8-inch diameter water main in Armorlite Drive to a 10-inch diameter main (Pipe Segment P-755). This segment is located west of the project site. • Upsize approximately 539 feet of 8-inch diameter sewer main in Armorlite Drive to a 10 -inch diameter main (Pipe Segments AL -1 through AL -3). This segment is located adjacent to and west of the project site.

Stormwater Infrastructure
The project includes the following off -site stormwater improvement. Th is improvement w ould be completed prior to project occupancy and would occur within an existing roadway:
• Installation of approximately 175 feet of 12 -inch reinforced concrete storm drain within Armorlite Drive right-of-way, west of the project site.

2.2.2.6 Project Design Features
The project incorporates the following design features and would adhere to specific regulatory requirements that would minimize potential environmental effects. These are summarized, in Table 2-

1. Table 2-1. Project Design Features
Aesthetics
• Implementation of the Landscape Plan to provide a cohesive and visually appealing planting scheme.
• Compliance with the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards.

Air Quality
• Compliance with San Diego Air Pollution Control District (SDACPD) Rule 55 – Fugitive Dust. • In accordance with SDAPCD Rule 67.0 (Architectural Coatings), the project would utilize low- volatile organic compound (VOC) paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces.
• Heavy diesel construction equipment shall be rated Tier IV or better. • Blasting activities would be limited as follows: 1) blasts would be limited to once per day; blasts are limited to six tons of ammonium nitrate for any given blast operation; and the blast area would be limited to 20,000 s.f. (100-foot X 200-foot area).

Biological Resources
• The applicant/developer/property owner shall pay Public Facility Fees, a portion of which go towards City-wide habitat conservation efforts.

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Energy
• Ensure proper maintenance of all construction equipment per manufacturer recommendations. • Comply with the California Air Resources Board (CARB)’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. • Installation of rooftop solar photovoltaic consistent with Title 24.

Greenhouse Gas Emissions
• Provision of 13 Level 2 EV charging stations.
• Provision of 25 EV capable and 62 EV ready parking spaces in the community parking area. • To meet the requirements of Reduced Parking Near Transit (Measure T-12) in the City’s CAP: the project would provide 247 spaces for residential use (69 garage standard spaces, 102 garage tandem spaces, 18 tuck under spaces and 58 open spaces) and 17 spaces for the commercial uses. Commercial parking requirements would be met by providing 7 open parking spaces, and 10 of the residential open spaces would be available for commercial use from 9:00 AM to 5:00 PM to meet the required 17 spaces.
• Installation of rooftop solar photovoltaic consistent with Title 24 and the CAP compliance checklist. • Provision of bicycle racks.
• Provision of pedestrian connection between the proposed building to Armorlite Drive. • The property manager shall provide transit information to the owners and make a good faith effort in offering transit fare subsidies to residents and businesses. • Designated parking for EV, carpool, vanpool, and/or park-and-ride spaces on site. • Provision of a workspace in the community room for telecommuting employees. • Compliance with the City’s Model Water Efficient Landscape Ordinance and Municipal Code, Title 20. • Installation of electric (rather than natural gas) tank water heaters. • None of the units shall have fireplaces.
• Planting of shade trees.

Hazards
• Future residents shall be notified of potential annoyances commonly associated with proximity to airports (e.g., noise, vibrations, and overflights) through the recording of overflight notification documents as outlined in the McClellan-Palomar Airport Land Use Compatibility Plan and Chapter

20.265 of the City’s Municipal Code.

Noise
• Grading, excavation, and other earth moving activities shall occur between 7:00 AM and 6:00 PM, Monday through Friday and between 8:00 AM and 5:00 PM on Saturdays. No grading, excavation and other earth moving activities shall occur on Sunday or City holidays in accordance with the City’s Municipal Code, Sections 10.24.200 and 17.080.00.
• Compliance with Municipal Code Section 17.60.060 (Blasting Operations Procedures). • All equipment shall be properly fitted with mufflers and all staging and maintenance shall be conducted as far away from the existing residences as possible to reduce construction noise. • The residential units with direct line-of-site to W. Mission Road and Las Posas Road shall have enhanced balcony and patio shielding consisting of 3.5-foot barriers. The barriers shall be constructed of a non-gapping material consisting of masonry, ¼ inch thick glass, earthen berm, or any combination of these materials.
• Parapet walls shall be constructed to shield rooftop HVAC units. • To ensure compliance with California Code of Regulations (CCR) Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring

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a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).

Public Services – Fire Protection, Police Protection and Schools • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001-01 (Fire and Paramedic).
• The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 98-01 (Police).
• The applicant shall pay the San Marcos Unified School District developer fees that are in effect at the time of building permit issuance. The current residential fee is $5.17 $4.79 per square foot and the current commercial fee is $0.84 $0.78 per square foot.

Transportation (Vehicle Miles Traveled)
• The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2011-01 (Congestion Management).

Utilities and Service Systems
• The applicant shall pay applicable Water and Wastewater Capital Facility Fees to Vallecitos Water District per Ordinances Nos. 175 and 176.

2.3 Environmental Setting

2.3.1 Existing Land Use and Setting
On-Site
The project site is currently undeveloped, vacant land enclosed by chain-link fencing along the north, south and western property boundary and open cable railing situated atop a small retaining wall along the eastern property boundary. A gated driveway ont o the site is located on Armorlite Drive, and a second gated driveway in the northwestern portion of the property provides vehicular access via the adjacent AT&T facility to the west. Well-used foot paths and a hole in the chain-link fencing along the northern property limits indicate informal walk-through access across the property. Other signs of site disturbance include pet waste and miscellaneous trash and litter. The site is generally flat with two small, paved drive aisles and slopes downward along it s edges. The project site is generally flat.

Elevations range from 575 above mean sea level (amsl) in the central knoll on the site to approximately 562 feet amsl along Armorlite Drive.

Surroundings
The project site is in a developed portion of the City. The project vicinity includes a mix of multi-family residential and commercial uses. The site is bounded by North County Transit District (NCTD) right of way to the north, the Palomar Station mixed -use development to the east and south, and George Burgers and AT&T to the west. The Palomar College Station SPRINTER station is located approximately

0.1-miles from the project site , approximately 1,000 feet east of the intersection of Las Posas Road and W. Mission Road. SR-78 is approximately 0.25 miles south of the project site.

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

Existing Zoning Designation
The project site has a zoning designation of P-I (Public/Institutional). According to Section 20.240.020 of the City’s Zoning Ordinance, this zone is intended to “ provide a district for the orderly and harmonious development of public facilities to adequately meet the needs of the San Marcos community. Appropriate P -I Zone uses may include maintenance, public buildings, recreation facilities, schools, and utility in stallations. The P -I Zone is intended to implement and be consistent with the Public/Institutional (PI) land use designation of the General Plan” (City of San Marcos 2012).

SANDAG Smart Growth Corridor
The project site is located within the SM -3 Mixed Use Transit Corridor as identified in the San Diego Association of Government’s Smart Growth Concept Map for North County. The Smart Growth Concept Map identifies locations in the region that can support smart growth, transit, walking, and biking. The map serves as the foundation for prioritizing transportation investments and determining eligibility for local smart growth incentive funds.

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

Additional descriptions of the project’s environmental setting as it relates to environmental issue areas can be found in Chapter 3.

2.3.3.1 Climate
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi -permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average summertime high tempera ture in the region is approximately 74 degrees Fahrenheit ( °F), with highs approaching 76°F in August on average. The average wintertime low temperature is approximately 49°F. Precipitation in the local area is approximately 10 inches per year, with the bulk of precipitation falling between December and March.

2.3.3.2 Air Basin
The City and project site is within the San Diego Air Basin (SDAB) and is under the jurisdiction of the SDAPCD. The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB lies in the southwest corner of California and com prises the entire San Diego region, covering 4,260 square miles, and it is an area of high air pollution potential. The SDAB experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological

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pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The SDAB is currently classified as a federal nonattainment area for ozone (O 3) and a state nonattainment area for coarse particulate matter less than or equal to 10 microns (PM 10), fine particulate matter less than or equal to 2.5 microns (PM2.5), and O3.

2.3.3.3 Soils
Based upon the geotechnical report prepared for the project site, the surficial soils consist of colluvium and alluvium (undifferentiated) and tonalite . Soils near subgrade would be classified as “very low” expansive (GeoTek 2023).

2.3.3.4 Terrain and Topography
The project site is located within the 7.5 -minute San Marcos Quadrangle map. The project site is generally flat. Elevations range from 575 amsl in the central knoll on the site to approximately 562 feet amsl along Armorlite Drive.

2.3.3.5 Watersheds and Hydrology
The project site is located within the jurisdiction of the San Diego Regional Water Quality Control Board (RWQCB). The San Diego Region is divided into eleven hydrologic units. The project site is in the Richland Hydrologic Subarea (904.52) within the San Marcos Hydrologic Area (904.5) of the Carlsbad Watershed or Hydrologic Unit (904). The project site has a central high point and drainage flows in all directions and does not become concentrated on the property (Latitude 33, 2023).

2.3.3.6 Regional Biology
The City of San Marcos Subarea Habitat Conservation Plan/Natural Community Conservation Plan (NCCP) has not been finalized or implemented, and the City is no longer an active participant in the NCCP program and the subregional Multiple Habitat Conservation Program (MHCP) conservation planning effort. However, it is the City’s General Plan policy to comply with the conservation policies identified in the MHCP through use of the Draft San Marcos Subarea Plan as an implementation tool.

The project site is not located within a Focused Planning Area (FPA) in the City’s Draft Subarea Plan.

Based upon the biological resources study prepared for the project (Dudek 2025 2024), the project site contains Diegan coastal sage scrub, non -native grassland, and disturbed habitat. Rare plant surveys were conducted in 2023 and no rare plants were observed on the project site. No special - status wildlife was observed within the project site during the biological surveys conducted in 2022 and 2023. Focused surveys for the coastal California gnatcatcher (Polioptila californica californica) (a federally listed threatened species and a California Department of Fish and Wildlife Species of Special Concern) were conducted within the project site between October 2022 and February 2023. California Gnatcatcher was not observed during these focused surveys.

2.4 Intended Uses of EIR
The EIR was prepared in accordance with the California Environmental Quality Act ( CEQA) (California Public Resources Code, Section 21000 et seq.), CEQA Guidelines (14 CCR 15000 et seq.).

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The EIR is an informational document that provides the City’s decision makers, public agencies, responsible and trustee agencies, and members of the public with information about (1) the potential for significant adverse environmental impacts that would result from the development of the proposed project, (2) possible ways to minimize any significant environmental impacts, and (3) feasible alternatives to the proposed project that would reduce or avoid significant impacts associated with the proposed projec t (California Public Resources Code, Section 21002.1[a]; 14 CCR 15121[a]).

Responsible and trustee agencies may use the EIR to fulfill their legal authority to issue permits for the proposed project. The analysis and findings in the EIR reflect the indepen dent judgment of the City.

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

Responsible Agencies
As defined by CEQA Guidelines Section 15381, a “Responsible Agency” includes all public agencies other than the lead agency which have discretionary approval power over the project. After certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project would use the Final EIR as the basis for their evaluation of environmental effects related to the proposed project that would culminate with the approval or denial of applicable p ermits. If an Incidental Take Permit would be required for the project, then California Department of Fish and Wildlife (CDFW) would be a Responsible Agency for the project.

Trustee Agencies
As defined by CEQA Guidelines Section 15381, a “Trustee Agency” means a state agency having jurisdiction by law over natural resources affected by a project which are held in trust for the people of the State of California. CDFW is a Trustee Agency with regard to the fish and wildlife of the state, to designated rare and endangered native plant s, and to game refuges, ecological reserves, and other areas administered by the department. CDFW is a Trustee Agency for the project.

2.4.1 Scope of the EIR
For the proposed project, the City determined that a Project EIR, as defined by CEQA Guidelines, Section 15161, was required. The City made this determination based on the scope and the location of the proposed project, as well as preparation of an Initial Study in accordance with CEQA Guidelines, Section 15063 (included as Appendix B.1 to the EIR).

The EIR evaluates all subject areas listed in Appendix G to the CEQA Guidelines, with the exception of those subject areas determined not to have a potentially significant impact on the environment, as determined during preparation of the Initial Study (refer to Chapter 5 of the EIR). Chapter 3 of the EIR evaluates in detail, the following subject areas: aesthetics, air quality, biological resources, cultural resources, energy, greenhouse gas, land use and planning, noise, population and housing, public

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services, transportation, tribal cultural resources, utilities and service systems, cumulative impacts, and growth-inducing impacts.

As a “Project EIR,” the EIR is “focused primarily on the changes in the environment that would result from the development project” (CEQA Guidelines Section 15161). In addition, as a Project EIR, the EIR examines all phases of the proposed project includin g planning, construction, and operation (CEQA Guidelines Section 15161). Where environmental impacts have been determined to be significant, the EIR recommends mitigation measures directed at reducing or avoiding those significant environmental impacts.

2.4.2 Notice of Preparation and Scoping
CEQA establishes mechanisms to inform the public and decision makers about the nature of the proposed project and the extent and types of impacts that the proposed project and alternatives to the proposed project would have on the environment should the pr oposed project or alternatives be implemented. Pursuant to Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated February 12, 2024 to interested agencies, organizations, and parties. The NOP was also posted to the State Clearinghouse CEQANet portal. State Clearinghouse assigned a state identification number (SCH No 2024020372) to the EIR.

The NOP is intended to encourage interagency and public communication regarding the proposed action so that agencies, organizations, and individuals are afforded an opportunity to respond with specific comments and/or questions regarding the scope and content of the EIR.

An online public scoping meeting was held on February 15, 2024. No community members attended.

The 30-day public scoping period ended on March 13, 2024. A total of four NOP comment letters were received.

Comments received during the NOP public scoping period were considered part of the preparation of the EIR. The NOP and written comments are included in Appendices B.2 and B.3 to the EIR. Topics raised during the NOP comment period include:
• Biological Resources: focused surveys, mitigation measures, biological resources report preparation, analysis of direct and indirect impacts, alternatives, cumulative analysis; • Cultural Resources: San Diego County Archaeological Society will review Draft EIR when available;
• Transportation: prepare a traffic impact study and CEQA analysis; • Utilities: water and sewer study provided by VWD.

Public scoping comments regarding the proposed project’s potential impact on the environment have been incorporated in the analysis in the EIR in Sections 3.3 (Biological Resources), 3.4 (Cultural Resources), 3.11 (Transportation), 3.12 (Tribal Cultural Resources), and 3.13 (Utilities and Service Systems).

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

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Public review of the Draft EIR is intended to focus “on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated” (14 CCR 15204). The Notice of Completion of the Draft EIR will be filed with the State Clearinghouse as required by CEQA Guidelines, Section 15085. In addition, the Notice of Availability of the Draft EIR will be distributed pursuant to CEQA Guidelines, Section 15087.

Interested parties may provide comments on the Draft EIR in written form. The EIR and related technical appendices are available for review during the 45-day public review period at:

City of San Marcos
Development Services Department Counter
1 Civic Center Drive
San Marcos, CA 92069
The document is also available online at: https://www.san -marcos.net/departments/development- services/planning/environmental-review-sustainability/environmental-documents.

Interested agencies and members of the public may submit written comments on the adequacy of the Draft EIR to the City’s Development Services Department at the address above, addressed to Sean del Solar, Senior Planner, or emailed at: [email protected].

Comments on the Draft EIR must be received by the close of business on the last day of the 45 - day review period.

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

When deciding whether to approve the proposed project, the City will use the information provided in the Final EIR to consider potential impacts to the physical environment. The City will also consider all written comments received on the Draft EIR during the 45- day public review period in making its decision to certify the Final EIR as complete and compliant with CEQA and in making its determination whether to approve or deny the proposed project. Environmental considerations, as well as economic and social factors, will be weighed by the City to determine the most appropriate course of action.

If the proposed project is approved, the City will file a Notice of Determination with the State Clearinghouse and San Diego County Clerk within five working days after project approval (14 CCR 15094.)
Subsequent to certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project will use the Final EIR’s evaluation of the proposed project’s environmental effects in considering whether to approve or deny applicable permits.

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2.5 Matrix of Project Approvals
Consistent with the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20, the proposed project requires certain entitlements be submitted, reviewed, and approved by the City.

The requested entitlements include a Specific Plan, General Plan Amendment, Rezone, and Site Development Plan, among others. These entitlements, listed and described in Table 2-2, would govern the development of the project site.

The City will use the EIR and associated documentation in its decision to approve or deny the required discretionary permits. Other responsible and/or trustee agencies can use the EIR and supporting documentation in their decision-making process to issue additional approvals.

Table 2-2. Required Actions and Approvals
Agency Required Action/Approval
City of San Marcos – Lead Agency
• Specific Plan
• General Plan Amendment
• Rezone
• Site Development Plan
• Conditional Use Permit
• Grading Plan/Permit
• Public Improvement Plan/Permit
• Landscape Plan/Permit
• Building Permits
• Annexation into CFD 2001-01 (Fire and Paramedic)
• Annexation in CFD 98-01 (Police)
• Annexation into CFD 98-02 (Lighting and Landscaping)
• Annexation into CFD 2011-01 (Congestion
Management)
San Diego Regional Water Quality Control
Board
National Pollutant Discharge Elimination System Construction General Permit (State Water Resources Control Board Order 2009-09-DWQ and MS4 Permit R9-2015-0001).

Vallecitos Water District Approval for water and sewer service

2.6 Project Inconsistencies with Applicable Regional and General Plans Throughout Chapter 3 of this EIR, the project has been evaluated in relation to the applicable goals, policies, and objectives of: the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20 (Section 3.7, Land Use); Regional Air Quality Strategy (Section 3.2, Air Quality); San Diego Air Pollution Control District polic ies (Section 3.2, Air Quality); City’s Climate Action Plan (Section 3.6, Greenhouse Gas Emissions); Regional Water Quality Control Board permits (Section 5.6, Hydrology and Water Quality); the Multiple Habitat Conservation Program (Section 3.3, Biological Resources); Airport Land Use Compatibility Plans (Sections 5.5, Hazards and Hazardous Materials, 3.7, Land Use, and 3.8, Noise); and various other applicable regional and local plans and policies.

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2.7 List of Past, Present and Reasonably Anticipated Future Projects in the Project Area
CEQA requires an EIR to analyze cumulative impacts. Section 15355 of CEQA Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” Section 15130 of the CEQA Guidelines provides guidance for analyzing significant cumulative impacts in an EIR. The discussion of cumulative impacts “need not provide as great detail as is provided for the effects attributable to the project alone,” but in stead is to be “be guided by standards of practicality and reasonableness” (CEQA Guidelines §15130(b)). The discussion should also focus only on significant effects resulting from the project’s incremental effects and the effects of other projects. According to Section 15130(a)(1), “an EIR should not discuss impacts which do not result in part from the project evaluated in the EIR.”
Cumulative impacts can result from the combined effect of past, present, and future projects located in proximity to the project under review. Therefore, it is important for a cumulative impacts analysis to be viewed over time and in conjunction with other related past, present, and reasonably foreseeable future developments whose impacts might compound or interrelate with those of the project under review.

According to Section 15130(b)(1) of the CEQA Guidelines, a cumulative impact analysis may be conducted and presented by either of two methods:
• A list of past, present, and probable activities producing related or cumulative impacts; or • A summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document that has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact.

With the exception of the impact analyses of air quality and greenhouse gas emissions, the cumulative list approach has been used in this cumulative analysis, as discussed below. The cumulative impacts of air quality and greenhouse gas emissions have been evaluated using the summary of projections method because the geographic scope of such impacts tends to be broad and area wide.

An inventory of past, present, and reasonably foreseeable future projects within the vicinity of the project site is presented in Table 2-3.

Table 2-3. Cumulative Projects
No. Project Location Description(1)
City of San Marcos
1 Capalina
Apartments
North side of Capalina Road
between N. Rancho Santa Fe
Road and N. Pacific Street
119 muti-family residential (MFR) units
and 4,000 s.f. commercial
2 CRP III Mission, LLC 528 W. Mission Road
Redevelopment of existing 10.83 acre
industrial park with 3 new industrial
buildings
3 Hughes SMCC, LLC Northeast corner of Pacific Street 67,410 s.f. industrial building 4 Kiddie Academy Northeast corner of Twin Oaks
Valley Road and Windy Way 11,430 s.f. preschool

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No. Project Location Description(1)
5 Lanikai Senior
Residential
Northwest corner of E. Mission
Road and Woodward Street 115 MRF units (age-restricted for 55+) 6 Lonnie Tabbaa
(ARCO)
Southwest corner of W. Mission
Road and N. Las Posas Road
Gas station, car wash, commercial drive
thru and convenience store
7 Main Square Southeast corner of San Marcos
Boulevard and McMahr Road
486 MFR units and approximately
44,000 s.f. of commercial
8 Marcos Specific Plan Grand Avenue and Linda Vista
Drive
63,000 s.f. commercial, 7 live-work units,
102 condos
9 Mariposa II/
Phase 1 (Alora)
Richmar Avenue and Los Olivos
Drive
100 MFR affordable units to replace 40
existing MFR units (net increase of 60
units)
10 Mariposa II/
Phase 2 (Estrella)
Richmar Avenue and Los Olivos
Drive
96 MFR affordable units to replace 30
existing MFR units (net increase of 66
units)
11 McDonald Group 1100 W. San Marcos Boulevard
(Former Sears site) 82 MFR units and 5,000 s.f. commercial 12 Mercy Hill and
Marian Center Borden Road 22,800 s.f. of institutional uses 13 Meritage Homes
(Grand Vista Multi-
Family)
West of Las Posas Road and Palm
Road intersection 120 MFR units
14 Murai-Sab N. Las Posas Road 89 SFR units
15 Pacific Commercial Northeast corner of Grand Avenue
and N. Pacific Street 122-room hotel
16 Pacifica San Marcos S. Rancho Santa Fe Road and
Creek Street 31 MFR units and 4,375 s.f. commercial
17 Pacific Specific Plan Las Posas Road and La Mirada 449 MFR units 18 Paul Mayer/Santa
Fe Las Flores
Northwest corner of S. Santa Fe
and N. Las Flores Drive 50 MFR units
19 Pico Investments 236 Pico Avenue 16 MFR units
20 Restaurant Row
Specific Plan 1020 W. San Marcos Boulevard
202 MFR units, 10,400 s.f. commercial
space, 1.5 acre park site, and street
improvements
21 San Marcos
Highlands North end of N. Las Posas Road 187 single family residential (SFR) units and 21.68 acre passive park
22 University District
Specific Plan and
Discovery Villages
Twin Oaks Valley Road, south of
SR-78, Discovery and Barham
Street areas
Various projects within the University
District Specific Plan (North City) and
adjacent area:
• Block 3 student housing
• Discovery Village North -
office/commercial/residential
• Discovery Village South - SFR
• SH North City, LLC – MFR units,
Master Association community

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No. Project Location Description(1)
recreation center, public and
private trail systems
• Univ District SPA – North City
Phase A&B - mixed-use
development comprised of
20,000 s.f. retail, 100,00 s.f.
office, and 537 MFR units
23 Villa Serena Phases
1 & 2
Northwest corner of Richmar
Avenue and Marcos Street
Demolish 136 MFR units and construct
148 MFR units (net increase of 12 units)
24 Woodward 46
Specific Plan
East side of Woodward St, north
of Mission Road 46 MFR units
Notes: (1) SFR = Single-Family Residential, MFR= Multi-Family Residential

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Figure 2-1. Project Location and Vicinity

SPRINTER Station
Palomar
College

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Figure 2-2. Conceptual Site Plan

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Figure 2-3. Conceptual Landscape Plan

Note: The complete conceptual landscape plan is included as Appendix A.3.

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Figure 2-4. Building Elevations

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Figure 2-5. Wall and Fencing Plan

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Figure 2-6. Lighting Plan

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3.0 Environmental Impact Analysis
Sections 3.1 through 3.13 provide the project- and cumulative-level environmental impact analysis for the proposed project.

After preparation of the Initial Study (IS) for the proposed project (Appendix B.1), it was concluded that impacts to agriculture/forestry resources, geology/soils, hazards/hazardous materials, hydrology/water quality, mineral resources, recreation, and wildfire would be less than significant.

Additionally, some of the specific CEQA thresholds under specific environmental topics 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 pri vate 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). The topics that were eliminated during the IS process are discussed in Chapter 3.0.

However, the IS process also concluded that the following issue areas could possibly result in significant impacts: aesthetics, air quality, biological resources, cultural resources, energy, greenhouse gas emissions, land use and planning, noise, population and housing, public services, transportation, tribal cultural resources, and utilities and services systems. Therefore, this Environmental Impact Report (EIR) evaluates the potential for impacts related to these iss ue areas.

The focus of the environmenta l analysis in each of the following sections is the suite of proposed actions as described in Chapter 2.0, Project Description.

The 13 environmental topics analyzed in Sections 3.1 through 3.13 are organized as follows:
• Introduction – provides a brief overview to each section. • Existing Conditions – describes the existing environmental conditions on the project site as it relates to the specific environmental topic being addressed in the subchapter. • Regulatory Setting – describes the federal, state, regional, and local regulatory requirements applicable to the proposed project.
• Thresholds of Significance – describes the thresholds by which the significance of project impacts are determined. A “no impact” conclusion means the project will not have any impacts for a given threshold. A “less than significant impact” conclusion means the project may have an impact; however, the impact is not to a level that would be deemed significant per the given threshold. A “significant impact” means the project has an impact that meets or exceeds a threshold and mitigation is required to reduce the impact. • Project Impact Analysis – analyzes the project-level impacts, by threshold. • Cumulative Impact Analysis – analyzes the cumulative-level impacts of the project. Cumulative projects considered in this analysis are listed in Table 2-3 in Chapter 2.0, Project Description. • Mitigation Measures – identifies the mitigation measures to reduce project - and/or cumulative-level impacts to below a level of significance. • Conclusion – briefly summarizes the analysis of each section.

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3.1 Aesthetics
Introduction
This section addresses the aesthetic resources of the proposed project area and the potential effects that implementation of the proposed project may have related to aesthetics, including impacts to degradation of visual character and lighting/glare. The a nalysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G, and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s website.3 In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to have an adverse impact on a scenic vista, nor would the project damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. Therefore, these issue will not be discussed further in the Environmental Impact Report (EIR). Section 5.1, Environmental Effects Found Not to be Significant – Aesthetics, of the EIR provides additional information on this topic.

Table 3.1 -1 summarizes the project - and cumulative -level impact analysis for each threshold of significance.

Table 3.1-1. Aesthetics Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 - In non-urbanized areas, substantially degrade
the existing visual character or quality of public
views of the site and its surroundings? (Public
views are those that are experienced from publicly
accessible vantage point). If the project is in an
urbanized area, would the project conflict with
applicable zoning and other regulations governing
scenic quality?
Less Than
Significant
Less Than
Significant
Less Than
Significant
Without
Mitigation
#2 - Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area.

Less Than
Significant
Less Than
Significant
Less Than
Significant
Without
Mitigation

3.1.1 Existing Conditions
Visual Character
The following is a description of the existing visual characteristics and visual quality of the project site and surrounding area.

The City of San Marcos is in the northern portion of San Diego County. The majority of the City is located on the valley floor, with State Route 78 (SR-78) running through the center of the City. Landforms such as the mountain ranges to the north and south of San Marcos contribute to its scenic corridors.

3 http://www.san-marcos.net/work/economic-development/general-plan

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The project site is located on the north side of Armorlite Drive, east of Las Posas Road. 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 Armorl ite Drive. The project site is currently undeveloped, vacant land and contains Diegan coastal sage scrub, non -native grassland and disturbed habitat (Dudek 2025 2024).

Figure 3.1-1 presents an overview of the project site and a key view map. Figures

3.1-2 through 3.1-9 present photos of the project site viewed from both onsite and offsite.

The project site is in a developed portion of the City. The project vicinity includes a mix of multi-family residential and commercial uses. The site is bounded by North County Transit District (NCTD) right of way to the north, the Palomar Station mixed -use development to the east and south, and George Burgers and AT&T facility to the west. The Palomar College SPRINTER station is located approximately

0.1-miles from the project site, approximately 1,000 feet east of the intersection of Las Posas Road and W. Mission Road. SR-78 is approximately 0.25 miles south of the project site.

Existing Light and Glare Conditions
The project site is currently undeveloped and thus does not contain any existing sources of light or glare. Additionally, the project site does not contain any reflective surfaces that would function as sources for glare. The project vicinity contains sources of nighttime lighting typical of residential and commercial uses. The project site is adjacent to developed areas and typical lighting sources in the project vicinity would include outdoor lighting fixtures on structures, in parking areas, and street lights on poles. There are no sources of substantial glare present in this area.

3.1.2 Regulatory Setting
This section describes the local regulations related to aesthetics that are applicable to the proposed project.

Local
San Marcos General Plan – Conservation and Open Space Element The following goal and policies from the City of San Marcos General Plan, Conservation and Open Space Element pertain to aesthetics and visual quality:
• Goal COS-3: Protect natural topography to preserve and enhance the natural beauty of San Marcos.
o Policy COS-3.1: Preserve scenic resources, including prominent landforms such as Double Peak, Owens Peak, San Marcos Mountains, Merriam Mountains, Cerro de Las Posas, Franks Peak, and canyon areas through conservation and management policies. o Policy COS -3.2: Encourage and maintain high -quality architectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character in San Marcos.
o Policy COS -3.3: Continue to work with new development and redevelopment project applicants in designing land use plans that respect the topography, landforms, view corridors, wildlife corridors, and open space that exists. o Policy COS-3.4: Evaluate potential impacts to visual and aesthetic resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

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

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

The San Marcos Municipal Code Zoning Ordinance Title 20 is the primary implementation tool for the policies of the General Plan. The Zoning Ordinance provides more detailed direction related to design and development standards; permitted, conditionally permitted, and prohibited uses; and other regulations such as lighting and sign regulations. The land uses specified in the Zoning Ordinance are based upon and consistent with the land use policies set forth in the General Plan. Specifically, building design, setbacks, lighting, and signage standards as well as open space requirements for development to protect open space and ambient light levels in the city. T he lighting standards of the Ordinance require energy -efficient lighting that limits light and glare for private projects, with exceptions for specialized streetscape lighting. Private developments are required to submit lighting plans to ensure consistency with dark sky needs of the region (City of San Marcos 2024a).

Title 20, Section 20.300.080, Site Planning and General Development Standards The City of San Marcos Street Lighting Standards and Specifications describes the lighting and glare standards for the city. These standards require lighting to be directed downward and limit the type and spacing of lighting to maintain reasonable lighting levels that do not contribute to light pollution. The City uses International Dark Sky Association thresholds to inform its own testing, leading to a policy that allows for the use of energy -efficient lighting sources that include, but are not limited to, light- emitting diode (LED) and induction lighting technologies (City of San Marcos 2024b).

Title 20, Chapter 20.260, Ridgeline Protection and Management Overlay Zone The City of San Marcos adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008-1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, mi nimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, and Ridgeline Overlay Zones (ROZ), surrounding these ridgelines (City of San Marcos 2024b). No primary or secondary ridgelines are located within or adjacent to the project site. The nearest primary ridgeline is within the North City Area #1 map and includes Owens Peak and “P” Mountain. This primary ridgeline is located approximately 1.25 miles northeast of the project site.

3.1.3 Thresholds of Significance
According to Appendix G of the California Environmental Quality Act (CEQA) Guidelines, visual quality and aesthetics impacts are considered potentially significant if the project would:
• Threshold #1: In non -urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbaniz ed area, would the project conflict with applicable zoning and other regulations governing scenic quality.

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• Threshold #2: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

3.1.4 Project Impact Analysis
Construction
Project construction involves grading and site preparation activities to prepare the site for future buildings and infrastructure improvements. Construction could require staging areas with construction equipment and supplies, and portable trailers to serve as temporary office space or storage. Grading on the site would result in minor modifications to the project site to prepare the site for development.

The project plans are included in Appendix A.2.

Operations
The project proposes 165 apartments and 5,600 square feet (s.f. ) of commercial floor area on the

2.44-acre site. The conceptual site plan is included as Figure 2 -2 in Chapter 2. One building is proposed and would have four stories of stacked flats over one level of podium parking (five stories total). The building wou ld have a maximum height of 74 feet. Overall, the project proposes 93 one bedroom/one bath units (ranging from 620 s.f. to 670 s.f.) and 72 two bedroom/one bath units (ranging from 875 s.f. to 1,020 s.f.). All units would be single story. Proposed materials include stucco walls, siding, stone veneer, metal and glass railings, metal or stucco awnings, decorative stucco frame and the use of decorative metal grills. Elevations are included as Figure 2-4.

The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes low and moderate water use species. Proposed tree species include: golden rain tree, Chinese pistache, fern pine, African suman, Japanese zelkova, Chitalpa, king palm, queen palm, Marina strawberry tree, gold medallion tree, desert museum palo verde, Brisbane box, Swan Hill fruitless olive, Mexican palo verde, tree aloe, eastern redbud, western redbud and crape myrtle. The proposed project would also comply with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20. The landscape concept plan is included as Figure 2-3 and the complete landscape plan and planting palette is included in Appendix A.3.

Threshold #1: In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is i n an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? The City of San Marcos (which includes the project site) is considered an urbanized area per the Public Resources Code (PRC). Per PRC Section 21071, an “urbanized area” is defined as “(a) an incorporated city that meets either of the following criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.” As of July 1, 2022, the U.S. Census Bureau (USCB) estimated the population of San Marcos to be 94,854 persons (USCB 2023). While this is less than 100,000 persons, the City of San Marcos is contiguous with the City of Escondido, which has an estimated population of 151,074 persons as of July 1, 2022 (USCB 2023).

The combined estimated population of these two contiguous cities is 245,928 persons, which is well over the 100,000 persons threshold. Thus, the City would be considered an urbanized area per CEQA.

Therefore, the first question of this aesthetics threshold does not apply to the proposed project, as it is directed at non-urbanized areas.

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The second part of this threshold is for projects in urbanized areas, which applies to the project. A significant impact would occur if the project conflicts with the applicable zoning and other regulations that govern scenic quality. Scenic quality is a measure of the visual appeal of the landscape, which is subjective and varies.

The City of San Marcos adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008-1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, mi nimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, or ROZ surrounding these ridgelines (City of San Marcos 2024b). No primary or secondary ridgelines are located within or adjacent to the project site. The nearest primary ridgeline is within the North City Area #1 map and includes Owens Peak and “P” Mountain. This primary ridgeline is located approximately 1.25 miles northeast of the project site.

The project would not result in any visual impact to primary and secondary ridgelines. Therefore, the project would not conflict with the ordinance.

The project site is currently zoned P -I (Public/Institutional) and includes a rezone request to change the zoning to Specific Plan Area (SPA). The project’s consistency with goals and policies related to scenic views and aesthetics is presented in Table 3.7-7 in Section 3.7, Land Use and Planning. No conflicts were identified.

The project design incorporates architectural treatments and design to break up the bulk and scale of the proposed building. This includes building articulation and setbacks with varied rooflines.

Additionally, the Specific Plan includes design and develop ment standards that the project will be required to comply with. The proposed landscaping plan would further enhance the project site through implementation of a comprehensive and aesthetically pleasing landscape design, which would be maintained by the pr oject owner. The landscape plan is included as Appendix A.3 of the EIR. With approval of the requested waivers, the project would not conflict with applicable zoning and other regulations governing scenic quality and impacts would be less than significant. Further, the project
site is within a Transit Priority Area (TPA), defined as within a half mile of a major transit stop (PRC Section 21064,3). Per PRC Section 21099(d) aesthetics impacts of a residential project on an infill site within a TPA shall not be considered a significant impact.

Threshold #2: Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Exterior lighting proposed for the project shall be guided by the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards. These standards require downward-directed LED lighting, with the exception of specialized streetscape lighting or architectural detail lighting, which aid in the preservation of dark - sky conditions that are needed by the local observatories. The location, type, and direction of the lighting wou ld be reviewed during the Improvement Plan review to ensure compliance with City requirements.

Lighting in the project vicinity is associated with roadway lighting along W. Mission Road and lighting associated with existing residential and commercial uses in the area and immediately adjacent to the project site. Development of the proposed project would introduce permanent lighting to a site that is currently undeveloped and does not have lighting.

Excessive, poorly designed, or unshielded lighting can be detrimental to astronomical observations.

Two observatories are located in San Diego County: Palomar Observatory, located over 20 miles

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northeast of the proposed project site, and Mount Laguna Observatory - located approximately 50 miles southeast of the proposed project site.

Lighting for the proposed project would be used to accent landscaping and provide safety and accent lighting for the building. The lighting concept plan is included as Figure 2-6. Proposed lighting fixtures include pole lights, bollard lights, louvered recessed wall lighting, uplit lighting for the entry monument and accent trees. Festoon lighting is proposed for the outdoor common space. All lighting fixtures for the proposed project would be energy efficient, architecturally appropriate, and designed to minimize glare, conflict, and light pollution, while providing illumination levels that create a safe environment for both vehicles and pedestrians. Street area lights would be full cut -off fixtures and would utilize house-side shields to reduce light tresp ass and prevent light pollution. Lighting requirements are detailed in Section 3.4.1 of the Specific Plan and all lighting would be required to conform with the City’s lighting ordinance and standards (San Marcos Municipal Code Title 20, Section 20.300.080).

The project does not propose features that would be characterized as creating a new source of glare that would adversely affect daytime or nighttime views in the area. The proposed materials include stucco walls, siding, stone veneer, metal and glass railings, metal or stucco awnings, decorative stucco frame and the use of decorative metal grills. The roof and wall colors and materials are not reflective and would not create significant sources of glare.

Since the project would be required to comply with the lighting standards set forth by the City, all lighting would be shielded to minimize light scatter and maintain dark sky conditions. Additionally, the proposed materials to be used in the homes are not glare-inducing so the project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Impacts would be less than significant.

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

Projects contributing to a cumulative aesthetic impact include those within the project viewshed. The viewshed encompasses the geographic area within which the viewer is most likely to observe the proposed project and surrounding uses. Typically, this is delineated based on topography, as elevated vantage points, such as scenic vistas, offer unobstructed views of expansive visible landscapes.

From Owen’s Peak and “P” Mountain, the closest primary ridgelines to the project site, viewers may be able to see cumulative projects in the same viewshed, and potentially portions of the project site.

The proposed building would be four stories of stacked flats over one level of podium parking (five stories total) and have a maximum height of approximately 74 feet. There is existing multi -story development in the project vicinity and the project would not substantially contrast with the visual patterns of the area. The project would appear as an extension of the already urbanized landscape.

When the proposed project is considered with other cumulative projects in the same viewshed, cumulatively, the increase in development would blend in with the existing urban landscape and would

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not result in a significant visual impact. Therefore, the proposed project would not substantially contribute to a cumulative change in the visual character of the surrounding area.

Cumulative effects of lighting are visible over a wide area, due to the potential for lighting from a number of projects to create sky glow. Currently, the project site does not have night lighting since it is undeveloped. Lighting in the project vicinity is associated with roadway lighting along W. Mission Road and lighting associated with existing residential and commercial uses in the area and immediately adjacent to the project site. As described in Section 3.1.4, the project would introduce new lighting sources at the project site; however, these fixtures would be shielded to minimize light scatter and maintain dark sky conditions and would be required to comply with the lighting standards set forth by the City. Cumulative projects would also be required to adhere to the lighting standards of the jurisdictions in which they are located. When the proposed project is considered with other cumulative projects adding night lighting, the impact would be less than significant due to the compliance with lighting standards set forth in the City that minimize light scatter and maintain dark sky conditions. Therefore, development of the project would not be a considerable contribution to sky glow such that a new significant cumulative sky glow impact would occur. C umulative impacts would be
less than significant.

3.1.6 Mitigation Measures
Based upon the analysis in section 3.1.4 and 3.1.5, aesthetics impacts would be less than significant and no mitigation measures are required.

3.1.7 Conclusion
The project site is in an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality, including the scenic resource protection policies in the Conservation and Open Space Element of the City’s General Plan (refer to Section 3.7, Land Use and Planning). Implementation of the proposed project would reasonably result in changes to the visual character of the site by allowing a mixed -use residential development; however, impacts would be minimal due to a general lack of public vantage points and the developed nature of the project vicinity.

Landscaping associated with the project would also soften views of the project site from adjacent uses.

Lighting and glare impacts were also determined to be less than significant, as the future multi-family mixed use building would not include highly reflective finishes or excessive lighting. Further, exterior lighting proposed for the project would comply with the City of San Marcos Street Lighting Standards and Specifications and the San Marcos Municipal Code. Cumulative impacts were determined to be less than significant. Therefore, aesthetic impacts are concluded to be less than significant.

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Figure 3.1-1. Site Photos Key Views

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Figure 3.1-2. View 1 - Southwest Corner Looking Northeast

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Figure 3.1-3. View 2 – Southeast Corner Looking Northwest

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Figure 3.1-4. View 3 – Northwest Corner Looking Southeast

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Figure 3.1-5. View 4 – Northeast Corner Looking Southwest

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Figure 3.1-6. View 5 – Offsite Fencing

Figure 3.1-7. View 6 – Eastern Property Line

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Figure 3.1-8. View 7 – Western Property Line

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Figure 3.1-9. View 8 – Looking Northwest from Project Site

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3.2 Air Quality
Introduction
This section identifies, describes, and evaluates air quality issues associated with the proposed project. This section analyzes short -term construction impacts and long -term operational impacts to air quality and determines whether the project would result in a significant air quality impact. This section is based upon the following report, w hich is included as Appendix C of the Environmental Impact Report (EIR)4:
• Air Quality Assessment, Armorlite Lofts Residential Development Project prepared by LDN Consulting, November 4, 2024 (LDN 2024).

Table 3.2-1 summarizes the project- and cumulative-level air quality impacts, by threshold.

Table 3.2-1. Air Quality Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 - Conflict with or obstruct implementation
of the applicable air quality plan.

Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#2 - Result in a cumulatively considerable
net increase of any criteria pollutant for
which the project region is in non-attainment
under an applicable federal or state ambient
air quality standard?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#3 - Expose sensitive receptors to
substantial pollutant concentrations.

Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#4 – Result in other emissions (such as
those leading to odors) adversely affecting a
substantial number of people?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation

3.2.1 Existing Conditions
This section introduces the meteorologic/climate conditions for the project area and presents the current physical setting and pollutant levels in the proximity of the proposed project.

Meteorology/Climate
Climate within the San Diego Air Basin (SDAB) area often varies dramatically over short geographical distances with cooler temperatures on the western coast gradually warming to the east as prevailing winds from the west heats up. Most of southern California is dominated by high-pressure systems for much of the year, which keeps San Diego mostly sunny and warm. Typically, during the winter months, the high-pressure systems drop to the south and brings cooler, moister weather from the north.

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

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Meteorological trends within the City of San Marcos produce daytime highs typically ranging between 64ºF in the winter to approximately 88ºF in the summer with August usually being the hottest month.

Daytime Low temperatures range from approximately 37ºF in the winter to approximately 59ºF in the summer. Precipitation is generally about 16.2 inches per year. Prevailing wind patterns for the area vary during any given month during the year and vary depending on the time of day or night. The predominant pattern throughout the year is usually from the west or westerly (LDN 2024).

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

Project area air quality can best be characterized by ambient measurements made by the SDAPCD.

SDAPCD operates a network of ambient air monitoring stations throughout San Diego County, which measure ambient concentrations of pollutants and determine whether the ambient air quality meets national and state air quality standards. Pursuant to the 1990 Clean Air Act amendments, U.S.

Environmental Protection Agency (USEPA) classifies air basins (or portions thereof) as “attainment” or “nonattainment” for each cr iteria air pollutant, based on whether the National Ambient Air Quality Standards (NAAQS) have been achieved. Generally, if the recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that pollutant. I f an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. As explained further below, these standards are set by USEPA or the California Air Resources Board (CARB) for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare. If there is not enough data available to determine whether the standard is exceeded in an area, the area is designated as “unclassified” or “unclassifiable.” The designation of “unclassifiable/attainment” means that the area meets the standard or is expected to meet the standard despite a lack of monitoring data. Areas that achieve the standards after a nonattainment designation are re-designated as maintenance areas and must have approved maintenance plans to ensure continued attainment of the standards. The California Clean Air Act, like its federal counterpart, calls for the designation of areas as “attainment” or “nonattainment,” but based on the California Ambient Air Quality Standards (CAAQS) rather than the NAAQS.

Current attainment designations for the SDAB are presented in Table 3.2 -2. As shown, the SDAB currently exhibits a non-attainment status for the federal 8-hour standard for ozone (O3). Additionally, the SDAB is either in attainment or unclassified for federal standards of 1 -hour O3, carbon monoxide (CO), respirable particulate matter (PM10), fine particulate matter (PM2.5), nitrogen dioxide (NO2), sulfur dioxide (SO 2), and lead (Pb). The SDAB is also in attainment of state air quality standards for all pollutants except for O3, PM10, and PM2.5. An attainment plan is available for O3.

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Table 3.2-2. San Diego County Air Basin Attainment Status by Pollutant Criteria Pollutant Federal Designation State Designation Ozone (O3) – 8-hour Nonattainment Nonattainment
Ozone (O3) – 1-hour Attainment Nonattainment(1)
Carbon Monoxide (CO) Attainment Attainment
Respirable Particulate Matter (PM10) Unclassifiable(2) Nonattainment Fine Particulate Matter (PM2.5) Attainment Nonattainment(3) Nitrogen Dioxide (NO2) Attainment Attainment
Sulfur Dioxide (SO2) Attainment Attainment
Lead (Pb) Attainment Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Visibility Reducing Particles No Federal Standard Unclassified Source: SDAPCD 2024.

Notes: (1) The federal 1-hour standard of 12 parts per hundred million (pphm) was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in State Implementation Plans.
(2) At the time of designation, if the available data does not support a designation of attainment or nonattainment, the area is designated as unclassifiable.
(3) The California Air Resources Board (CARB) has not reclassified the region to attainment yet due to: incomplete data, and the use of non-California Approved Samplers (CAS). While data collected does meet the requirements for designation of attainment with federal PM 2.5 standards, the data completeness requirements for state PM 2.5 standards substantially exceed federal requirements and mandates and have historically not been feasible for most air districts to adhere to given local resources. SDAPCD has be gun replacing most regional filter -based PM 2.5 monitors as they reach the end of their useful life with continuous PM2.5 air monitors to ensure collected data meets stringent completeness requirements in the future. SDAPCD anticipates these new monitors will be approved as "CAS" monitors once CARB reviews the list of approved monitors, which has not been updated since 2013.

Local
The SDAPCD air quality monitoring stations located in Carmel Mountain Ranch and Camp Pendleton are the closest stations to the project area. Table 3.2-3 summarizes the two most recent years of monitoring data from the Carmel Mountain Ranch and Camp Pendleton monitoring stations.

Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by CARB, include children, the elderly, an d people with cardiovascular and chronic respiratory diseases. Sensitive receptors include residences, schools, playgrounds, childcare centers, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes.

The project site is currently vacant. The project site is bounded by existing commercial and retail uses to the west, existing multi-family residential units to the east, W. Mission Road and the SPRINTER rail line to the north, and Armorlite Drive to the south. Existing multi -family residential units are located across Armorlite Drive to the south.

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Table 3.2-3. Two Year Ambient Air Quality Summary Near the Project Site (Camp Pendleton or Carmel Mountain Ranch Stations)
Pollutant(1) Averaging
Time CAAQS NAAQS 2021 2022
Days
Exceeded
Over 2 Years
O3
(ppm)
1 hour 0.09 ppm No Standard 0.07 0.08 0
8 hour 0.070 ppm 0.070 ppm 0.06 0.07 0
PM10
(µg/m(3)
24 hour 50 µg/m3 150 µg/m3 PM10 Data Not Available for Monitoring Sites near Project Site. Annual(2) 20 µg/m3 No Standard PM2.5(3)
(µg/m3)
24 hour No Standard 35 µg/m3 23.5 14.9 N/A
Annual(2) 12 µg/m3 15 µg/m3 8.5 7.6 N/A
NO2
(ppm)
Annual(2) 0.030 ppm 0.053 ppm 0.013 0.013 N/A
1 hour 0.18 ppm 0.100 ppm 0.059 0.059 N/A
CO(3)
(ppm)
1 hour 20 ppm 35 ppm 3.0 2.2 N/A
8 hour 9 ppm 9 ppm 1.8 1.2 N/A
Source: LDN 2024.

Notes: parts per million = ppm
(1) SO2 is only monitored at the El Cajon Monitoring Station. Within the entire County of San Diego, SO2 emissions within the County are essentially zero for all metrics including the average, maximum 24 hour and 1-hour standards. The highest 1-hr measurement identified is 0.004 ppm and the most restrictive standard (CAAQS for SO2) is 0.25 ppm.
(2) Annual arithmetic mean
(3) Data was collected from Carmel Mountain Ranch station which began in 2019. All other data presented was collected at the Camp Pendleton Monitoring Station.

Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, w ith an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. The criteria air pollutants that are monitor ed by the USEPA are ozone (O
3), carbon monoxide (CO), nitrogen dioxide (NO 2),
particulate matter less than or equal to 10 microns or 2.5 microns in diameter (PM10, and PM2.5) sulfur dioxide (SO2), and lead (Pb). These pollutants, as well as toxic air contaminants (TACs), are discussed in the following text. In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility -reducing particles are also regulated as criteria air pollutants. E xamples of sources and effects of these pollutants are identified below:

Ozone (O3): A strong smelling, pale blue reactive toxic chemical gas consisting of three oxygen atoms.

It is a product of the photochemical process involving the sun's energy. O 3 exists in the upper atmosphere O3 layer, as well as at the earth’s surface. O 3 at the earth's surface causes numerous adverse health effects, including lung inflammation, tissue damage, and impaired lung functioning, is a major component of smog, and can damage materials such as rubber, fabrics, and plastics.

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It should be noted that Oxides of Nitrogen (NOx) is a family of poisonous, highly reactive gases. These gases form when fuel is burned at high temperatures. NOx pollution is emitted by automobiles, trucks, and various non-road vehicles (e.g., construction equipment, boats, etc.) as well as industrial sources such as power plants, industrial boilers, cement kilns, and turbines. NOx often appears as a browning gas. It is a strong oxidizing agent and plays a major role in the atmospheric reactions with Volatil e Organic Compounds (VOCs) which produce ozone on hot summer days (LDN 2024).

Carbon Monoxide (CO): Carbon monoxide is a colorless, odorless, tasteless, and toxic gas resulting from the incomplete combustion of fossil fuels. CO interferes with the blood's ability to carry oxygen to the body's tissues and results in numerous adverse health effects includi ng fatigue, headaches, confusion, and dizziness.

Nitrogen Dioxide (NO2): NO2 is formed when nitrogen (N 2) combines with oxygen (O 2). Its life span in the atmosphere ranges from one to seven days. NO2 is typically created during combustion processes and is a major contributor to smog formation and acid deposition. NO2 may result in numerous adverse health effects, including respiratory damage. It absorbs blue light, resulting in a brownish -red cast to the atmosphere and reduced visibility.

Particulate Matter Less Than or Equal to 10 Microns in Diameter (PM 10): A major air pollutant consisting of tiny solid or liquid particles of soot, dust, smoke, fumes, and aerosols. The size of the particles (equal to 10 microns or smaller, about 0.0004 inch or less in diameter) allows them to easily enter the lungs where they may be deposited, resulting in adverse health effects, including allergies, asthma, and respiratory illness. PM
10 also causes visibility reduction.

Particulate Matter Less Than or Equal to 2.5 Microns in Diameter (PM 2.5): A similar air pollutant consisting of tiny solid or liquid particles which are 2.5 microns or smaller (which are often referred to as fine particles). These particles are formed in the atmosphere from primary gaseous emissions that include sulfates formed from SO
2 released from power plants and industrial facilities and nitrates that are formed from NOx released from power plants, automobiles, and other types of combustion sources.

The chemical composition of fine particles depends mostly on location of the emissions, time of year, and weather conditions. The adverse health effects of PM2.5 are similar to those of PM10.

Sulfur Dioxide (SO2): Typically, strong smelling, colorless gas that is formed by the combustion of fossil fuels. SO2 and other sulfur oxides contribute to the problem of acid deposition as well as adverse health effects including respiratory constriction and, with continued exposure, increased incidents of pulmonary symptoms.

Lead (Pb): Lead in the atmosphere occurs as particulate matter. Lead has historically been emitted from vehicles combusting leaded gasoline, as well as from industrial sources. With the phase -out of leaded gasoline, large manufacturing facilities are the sources of the greatest amount of lead emissions. Lead has the potential to accumulate over time and cause gastrointestinal, central nervous system, kidney, and blood diseases upon prolonged exposure. Lead is also classified as a probable human carcinogen.

Sulfates: Sulfates are salts of sulfuric acid and occur as microscopic particles (aerosols) resulting from fossil fuel and biomass combustion. The increase the acidity of the atmosphere and form acid rain.

Vinyl Chloride: Also known as chloroethene, vinyl chloride is a toxic, carcinogenic, colorless gas with a sweet odor. It is an industrial chemical mainly used to produce its polymer, polyvinyl chloride (PVC).

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Hydrogen Sulfide (H2S): A colorless, toxic, and flammable gas with a recognizable smell of rotten eggs, H2S occurs naturally in crude petroleum, natural gas, volcanic gases, and hot springs. Exposure to low concentrations of hydrogen sulfide may cause irritation to the eyes, nose, or throat. It may also cause difficulty in breathing for some asthmatics. Brief exposures to high concentrations of H2S (greater than 500 parts per million) can cause a loss of consciousness and possibly death.

Visibility Reducing Particles: These are particles in the air that obstruct visibility.

Non-Criteria Air Pollutants
Toxic Air Contaminants. A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects. A toxic substance released into the air is conside red a TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two -step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two- step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires facilities emitting toxic substances to provide local air pollution co ntrol districts with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources, location of resulting hotspots, notification of the public exposed to significant risk, and development of effective s trategies to reduce potential risks to the public over 5 years.

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

CARB classified “particulate emissions from diesel -fueled engines” (i.e., diesel particulate matter [DPM]) as a TAC in August 1998. DPM is part of a complex mixture that makes up diesel exhaust.

Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks.

DPM is emitted from a broad range of diesel engines: on -road diesel engines of trucks, buses, and cars and off-road diesel engines including locomotives, marine vessels, and heavy -duty construction equipment, among others. Approximately 70% of all airborne cancer risk in California is associated with DPM. To reduce the cancer risk associated with diesel particulate matter, CARB adopted a diesel risk reduction plan in 2000, which recommends many control measures to reduce the risks associated with DPM (CARB 2000).

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

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Federal
Federal Clean Air Act
The federal Clean Air Act, passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The U.S. Environmental Protection Agency is responsible for implementing most aspects of the Clean Air Act, including setting National ambient air quality standards (NAAQS) for major air pollutants, setting hazardous air pollutant standards, approving state attainment plans, setting motor vehicle emission standards, issuing stationary source emission standards and permits, and establishing acid rain control measures, stratospheric O 3 protection measures, and enforcement
provisions. Under the Clean Air Act, NAAQS are established for the criteria pollutants O3, CO, NO2, SO2, PM10, PM2.5, and lead and shown in Table 3.2-4.

The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The NAAQS for CO, Lead and those based on annual averages or arithmetic mean are not to be exceeded more than once per year. NAAQ S for O3, NO2, SO2, PM10, and PM2.5 are based on statistical calculations over 1 - to 3-year periods, depending on the pollutant. The Clean Air Act requires the USEPA to reassess the NAAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a State Implementation Plan (SIP) that demonstrates how those areas will attain the standards within mandated time frames. These plans must include pollution control means that demonstrate how the standards will be met as expeditiously as possible. The NAAQS were amended in July 1997 to include an additional standard for O 3, and to adopt a standard
for fine particulates (PM2.5). In June 2002, a stringent statewide PM2.5 standard was adopted. In 2012, the PM2.5 standard was lowered further based on air quality monitoring data.

Table 3.2-4. Ambient Air Quality Standards
Pollutant Average
Time
California Standards(1) National Standards(2)
Concentration(3) Method(4) Primary(3)(5) Secondary(3)(6) Measurement Method(7)
Ozone
(O3)(8)
1 Hour 0.09 ppm
(180 µg/m3) Ultraviolet
Photometry

Same as Primary
Standard
Ultraviolet
Photometry
8 Hour 0.070 ppm
(137 µg/m3)

0.070 ppm
(137 µg/m3)
Respirable
Particulate
Matter
(PM10)(9)
24 Hour 50 µg/m3
Gravimetric or Beta
Attenuation
150 µg/m3
Same as Primary
Standard
Inertial Separation
and Gravimetric
Analysis
Annual
Arithmetic
Mean
20 µg/m3
Fine
Particulate
Matter
(PM2.5)(9)
24 Hour No Separate State Standard 35 µg/m3 Same as Primary Standard Inertial Separation
and Gravimetric
Analysis
Annual
Arithmetic
Mean
12 µg/m3 Gravimetric or Beta
Attenuation 12.0 µg/m3 15 µg/m3
Carbon
Monoxide
(CO)
8 hour 9.0 ppm
(10mg/m3)
Non-Dispersive
Infrared
Photometry (NDIR)
9 ppm (10
mg/m3)
- Non-Dispersive
Infrared Photometry
1 hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
8 Hour
(Lake
Tahoe)
6 ppm
(7 mg/m3)

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Pollutant Average
Time
California Standards(1) National Standards(2)
Concentration(3) Method(4) Primary(3)(5) Secondary(3)(6) Measurement Method(7)
Nitrogen
Dioxide
(NO2) (10)
Annual
Arithmetic
Mean

0.030 ppm
(57 µg/m3) Gas Phase
Chemiluminescenc
e

0.053 ppm
(100 µg/m3) (8)
Same as Primary
Standard Gas Phase
Chemiluminescence
1 Hour 0.18 ppm
(339 µg/m3)

0.100 ppm(8)
(188/ µg/m3) -
Sulfur
Dioxide
(SO2) (11)
Annual
Arithmetic
Mean
-
Ultraviolet
Fluorescence

0.030 ppm(10)
(for Certain Areas) -
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararoosaniline
Method)9
24 Hour 0.04 ppm
(105 µg/m3)

0.14 ppm(10)
(for Certain Areas)
(See Footnote 9)
-
3 Hour - 0.5 ppm
(1300 µg/m3)
1 Hour 0.25 ppm
(655 µg/m3)
75 ppb
(196 µg/m3) -
Lead(12) (13)
30 Day
Average 1.5 µg/m3
Atomic Absorption
- -
Calendar
Quarter - 1.5 µg/m3
Same as Primary
Standard
High Volume
Sampler and Atomic
Absorption
Rolling 3-
Month
Average
- 0.15 µg/m3
Visibility
Reducing
Particles
8 Hour See footnote 13
No National Standards
Sulfates 24 Hour 25 µg/m3 Ion
Chromatography
Hydrogen
Sulfide 1 Hour 0.03 ppm
(42 µg/m3)
Ultraviolet
Fluorescence
Vinyl
Chloride(12)
24 Hour 0.01 ppm
(26 µg/m3)
Gas
Chromatography

1. California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Reg ulations.

2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded m ore than once a year.

The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24 -hour average concentration above 150 µg/m3 is equal to or less than one. For PM2.5, th e 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.

3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a re ference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a referen ce temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

4. Any equivalent procedure which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air quality standard may be used.

5. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public heal th.

6. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

7. Reference method as described by the EPA. An “equivalent method” of measurement may be used but must have a “consistent relat ionship to the reference method” and must be approved by the EPA.

8. On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm.

9. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3 . The existing natio nal 24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3 , as was the annual secondary standard of 15 μg/m3 . The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standard s is the annual mean, averaged over 3 years.

10. To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.

11. On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1 - hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except

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Pollutant Average
Time
California Standards(1) National Standards(2)
Concentration(3) Method(4) Primary(3)(5) Secondary(3)(6) Measurement Method(7)
that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

12. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse he alth effects determined.

These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

13. The national standard for lead was revised on October 15, 2008 to a rolling 3 -month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

14. In 1989, the ARB converted both the general statewide 10 -mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statew ide and Lake Tahoe Air Basin standards, respectively.

Source: CARB 2016, http://www.arb.ca.gov/research/aaqs/aaqs2.pdf ppm = parts per million
µg/m3 = micrograms per cubic meter
mg/m3= milligrams per cubic meter

National Ambient Air Quality Standards (NAAQS)
To gauge the significance of the air quality impacts of the proposed project, those impacts, together with existing background air quality levels, must be compared to the applicable ambient air quality standards. These standards are the levels of air quality considered safe, with an adequate margin of safety, to protect public health and welfare. Primary standards set limits for the protection of public health, including those people most susceptible to further respiratory distress such as asthmatics, children, and the elderly, or sensitive receptors. Secondary standards set limits to protect public welfare and include protection against decreased visibility and damage to animals, crops, vegetation, and buildings. Research has shown that chronic exposure to O 3 at levels that just marginally meet
clean air standards may nevertheless have adverse health effects. State and federal agencies, therefore, have promulgated a more stringent 8 -hour O
3 standard that better reflects human health
response to more chronic exposure, shown in Table 3.2-4. USEPA set the 2008 ozone standard to 75 parts per billion (ppb) and required all areas of the country to meet this monitored concentration by July 20, 2018. The areas that were not able to demonstrate compliance with this standard have now been classified as an ozone nonattainment area. USEPA revised the standard to 70 ppb in 2015 but some areas, including San Diego County, have still not met the 2008 standard and their attainment status changed in level of severity.

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

CARB has established CAAQS, which are generally more restrictive than the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before a basin can attain the standard. Air quality is considered “in attainment ” if pollutant levels are continuously below the CAAQS and violate the standards no more than once each year. The CAAQS for O 3, CO, SO2
(1-hour and 24-hour), NO2, PM10, and PM2.5 and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. Additionally, sulfates, vinyl chloride,

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hydrogen sulfide, and visibility-reducing particles are also regulated as criteria air pollutants in California. The CAAQS currently in effect in California are also shown in Table 3.2 -4 and include the most recently adopted federal standards for chronic (8-hour) O3 exposure and for ultra-small diameter particulate matter of 2.5 microns or less in diameter (PM2.5). Current attainment designations for the SDAPCD are presented in Table 3.2-2.

California Clean Air Act
The California Clean Air Act , signed into law in 1988, requires all areas of the state to achieve and maintain the CAAQS by the earliest practical date. Air pollution from commercial and industrial facilities is regulated by local air quality management districts, whereas mobile source s of air pollution are regulated by CARB and the USEPA. All air pollution control districts have been formally designated as “attainment” or “nonattainment” for each state air quality standard, as shown in Table 3.2-2. Areas in California where ambient air concentrations of pollutants are higher than the state standard are considered to be in “non-attainment” status for that pollutant. If there are inadequate or inconclusive data to make a definitive attainment designation, districts are considered “unclassified.” Local
San Diego Air Pollution Control District
Although CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources. The project i s located within the SDAB and is subject to SDAPCD guidelines and regulations. In San Diego County, O3 and particulate matter are the pollutants of main concern, because exceedances of the CAAQS for those pollutants are experienced here in most years.

In January 2021, SDAPCD sent a request to the US EPA to reclassify San Diego County from Serious Nonattainment to Severe Nonattainment for the 2008 ozone NAAQS and from Moderate to Severe Nonattainment for the 2015 ozone NAAQ S. The USEPA granted this request in April 2021. SDAPCD prepared and submitted to the USEPA, via CARB, ozone attainment plans identifying control measures and associated emissions reductions necessary to demonstrate attainment of the 75 -ppb 2008 standard by July 20 , 2027, and attainment of the 70-ppb 2015 standard by August 3, 2 033.

Reclassification imposes additional requirements under the Clean Air Act (for example, transportation control strategies and measures to offset emissions increases from vehicle miles traveled) that will help ensure the area has the tools needed to att ain the standard. The 2020 Plan for Attaining the National Ozone Standards (SDAPCD 2020) addresses all requirements for both ozone standards.

SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The Regional Air Quality Strategy (RAQS) for the SDAB was initially adopted in 1991 and most recently updated in 2022. The RAQS outlines SDAPCD’s plans, and control measures designed to attain the CAAQS for O

3. The RAQS details how the region will manage and reduce O 3 precursors (NOx and VOCs) by identifying measures and regulations intended to reduce these contaminants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, includin g those under the authority of CARB and USEPA. Incentive programs for reduction of emissions from heavy -duty diesel vehicles, off-road equipment, and school buses are also established in the RAQS.

The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the reduction of

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emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the development of thei r general plans. Projects that produce less growth than predicted by SANDAG would generally conform to the RAQS. Projects that create more growth than projected by SANDAG may create a significant impact if the project produces unmitigable air quality emissions or if the project produces cumulative impacts.

City of San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan identifies one goal and several policies regarding air quality. Those policies that are applicable to the project are listed below:
• Goal COS-4: Improve regional air quality and reduce greenhouse gas emissions that contribute to climate change.
o Policy COS-4.1: Continue to work with the USEPA, CARB, SANDAG, and the SDAPCD to meet State and federal ambient air quality standards.
o Policy COS-4.5: Encourage energy conservation and the use of alternative energy sources within the community.
o Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
• Policy COS-4.8: Encourage and support the generation, transmission, and use of renewable energy.

The Environmental Justice Element of the City’s General Plan identifies one goal and a policy regarding air quality, listed below:
• Goal EJ -1: Reduce greenhouse gas emissions, enhance air quality, and reduce impacts associated with climate change.
o Policy EJ-1.9: Continue to work with the USEPA, CARB, SANDAG, and the SDAPCD to meet State and federal ambient air quality standards.

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

3.2.3 Thresholds of Significance
The State of California has developed guidelines to address the significance of air quality impacts based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines which provides guidance that a project would have a significant environmental impact if it would:
• Threshold #1: Conflict with or obstruct implementation of the applicable air quality plan; • Threshold #2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard;
• Threshold #3: Expose sensitive receptors to substantial pollutant concentrations;

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• Threshold #4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
To determine whether a project would: (a) result in emissions that would violate any air quality standard or contribute substantially to an existing or projected air quality violation; or (b) result in a cumulatively considerable net increase of PM 10 or PM 2.5 or exceed quantitative thresholds for O 3 precursors, NOx and VOCs, project emissions may be evaluated based on the quantitative emission thresholds established by the SDAPCD, the agency responsible for air quality planning, monitoring, and enforcement within this basin. As part of its air quality permitting process, the SDAPCD has established thresholds in Rule 20.2 for the preparation of Air Quality Impact Assessments (AQIAs) (SDAPCD 2019).

For CEQA purposes, these screening criteria can be used as numeric methods to demonstrate that a project’s total emissions would not result in a significant impact to air quality. Since SDAPCD does not have a thresholds for emissions of VOCs, the use of the Coachella Valley VOC threshold from the South Coast Air Quality Management District (SCAQMD) is acceptable.

The thresholds listed in Table 3.2-5 represent screening-level thresholds that can be used to evaluate whether project-related emissions could cause a significant impact on air quality for both construction and operation. Emissions below the screening-level thresholds would not cause a signi ficant impact.

If emissions exceed these thresholds, modeling would be required to demonstrate that the project’s total air quality impacts result in ground -level concentrations that are below the state and federal Ambient Air Quality Standards (AAQS) , including appropriate background levels. For nonattainment pollutants (PM
10 and PM 2.5 plus O 3, with O 3 precursors NO x and VOCs), if emissions exceed the thresholds shown in Table 3.2 -5, the project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality.

Table 3.2-5. Screening-Level Criteria for Air Quality Impacts Pollutant Total Emissions (Pounds/Day)
Construction Emissions
Respirable Particulate Matter (PM10) 100
Particulate Matter (PM2.5) 55
Nitrogen Oxide (NOx) 250
Sulfur Oxide (SOx) 250
Carbon Monoxide (CO) 550
Volatile Organic Compounds (VOCs) 75
Reactive Organic Gases (ROG) (SCAQMD) 75
Operational Emissions
Respirable Particulate Matter (PM10) 100
Particulate Matter (PM2.5) 55
Nitrogen Oxide (NOx) 250
Sulfur Oxide (SOx) 250

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Pollutant Total Emissions (Pounds/Day)
Carbon Monoxide (CO) 550
Lead and Lead Compounds 3.2
Volatile Organic Compounds (VOCs) (1) 75
Reactive Organic Gases (ROG) SCAQMD(1) 75
Source: LDN 2024.

Note (1) The USEPA uses the term Volatile Organic Compound (VOC) and CARB’s Emission Inventory Branch uses the term Reactive Organic Gases (ROG) to essentially define the same thing. There are minor deviations between compounds that define each term; however, for purposes of the air quality study, they are assumed to be essentially the same due to the fact that SCAQMD interchanges these terms and because CalEEMod directly calculates ROG in place of VOC.

In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as toxic air contaminants (TACs) or Hazardous Air Pollutants (HAPs). SDAPCD Regulation XII establishes accep table risk levels and emission control requirements for new and modified facilities that may emit additional TACs. Under Rule 1210 (adopted in 1996 and revised several times, most recently 2023), emissions of TACs that result in a cancer risk of 10 in 1 million or less and a health hazard index of one or less would not be required to notify the public of potential health risks. If a project has the potential to result in emissions of any TAC or HAP that results in a cancer risk of greater than 10 in 1 milli on, the project would be deemed to have a potentially significant impact and would be required to implement toxics best available control technology (T-BACT) (SDAPCD 2023).

SDAPCD Rule 51 (Public Nuisance) also prohibits emission of any material which causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person (SDAPCD 1976). A project that proposes a use which would produce ob jectionable odors would be deemed to have a significant odor impact if it would affect a considerable number of offsite receptors. Projects that may cause odor conflicts include certain types of commercial uses (e.g., auto body shops, furniture repair), industrial, public (e.g., landfill, wastewater treatment facilities), and agricultural operations (CARB 2005). The impacts associated with construction and operation of the project were evaluated for significance based on the aforementioned significance criteria.

3.2.4 Project Impact Analysis
Threshold #1: Conflict with or obstruct implementation of the applicable air quality plan? As part of the RAQS and SIP planning process, the SDAPCD develops an emission inventory, based on growth projections from SANDAG and existing emissions figures within the SDAB. The SDAPCD then uses the emission inventory to conduct modeling to demonstrate that the SDAB will attain and maintain the state and federal O
3 standards. This inventory could be thought of as an “emissions budget” for the SDAB, accounting for current emissions as well as previously approved projects consistent with current General Plan policies.

Projects that are consistent with the currently adopted General Plan are determined to be consistent with SDAB’s air quality plans, including the RAQS and the SIP. If a project proposes development that is consistent with or less than estimates provided in the General Plan, the project will not conflict with or obstruct implementation of the RAQS or SIP.

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The project site has an existing General Plan Land Use designation of Public/ Institutional (PI), which has a maximum floor area ratio (FAR) of 3.0. The project includes a General Plan amendment request to change the PI designation to Specific Plan Area (SPA) for the proposed mixed-use development, consisting of 165 multifamily units and 5,600 square feet (s.f.) of commercial use. The P-I land use is typically used for any type of public land use , including schools, hospitals, civic centers, etc. With an allowable FAR of 3.0, any facility which could be constructed onsite would be limited to approximately 318,000 s.f. Vehicular trip generation of public institutions like schools or hospitals would result in significantly more traffic than the 1,214 trips that the proposed project would generate and would therefore generate larger quantities of operational air quality emissions. For example, based on SANDAG’s trip generation guide a hospital can generate as many as 25 trips per 1,000 s.f. or over 7,000 trips f or a project of this size (SANDAG 2002). Since the largest component of air quality emissions are typically derived from vehicular trips, development under the proposed project would be considered less intense.

Another potential use for the site could be to install a 160,000 s.f. telecommunications data center or larger if multiple stories are constructed. Data centers are recognized as very high consumers of electrical energy. For example, a 413,000 s.f. data center in Santa Clara was found to consume 665,750 megawatt hours (MWH) or 1.61 MWH/SF/year (LDN 2024). Based on this, a 160 ,000 s.f. building would require at least 257,600 MWH annually. Based on modeling, the proposed project would consume 907 MWH which is about 285 times less energy and significantly less intense (LDN 2024).

Therefore, t he project’s development intensity would decrease from its current General Plan designation. The project is therefore considered consistent with the County’s RAQS and would comply with the state’s SIP. Impacts would be less than significant.

Threshold #2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard? Air quality impacts associated with the proposed project would likely come from two potential sources.

The first is related to project construction, such as impacts related to construction equipment emissions, haul trucks for soils export, grading, and blasting/rock crushing activities . The second is related to operations, such as mobile source emissions from vehicles traveling to and from the proposed project, natural gas emission sources, and area sources. The analyses and findings for these two sources are presented below.

Construction Emissions Analysis
Construction activities are a source of fugitive dust emissions that may have a temporary, but substantial, impact on local air quality. These emissions are generally associated with grading, heavy equipment usage, blasting and rock crushing, and from construction worker commutes. Dust emissions and impacts vary with the level of activity, specific operations conducted, and prevailing winds. For the proposed project, rough grading activities assume site preparation, grading, building construction, paving, and architectural coating.

Construction grading operations for the project are anticipated to include 6,950 cubic yards (cy) of cut material and 4,400 cy of fill material requiring an export of approximately 2,250 cy of fill material once materials shrinkage is considered. The air quality model assumed a default load size of approximately 15 cy per truck for a total of 150 loads (300 trips) during project grading. Assuming 15 work days for materials import and the use of a 15 cy truck, there would be approximately 1 0 truckloads per day during grading. The project would start grading in 2026 with full occupancy in late 2027/early 2028.

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The California Emissions Estimator Model (CalEEMod) 2022.1 was used to calculate the emissions associated with the construction of the project. The AERSCREEN dispersion model was used to determine the concentration for air pollutants at any location near t he pollutant generator as well as to predict the maximum exposure distance and concentrations. The following design features were assumed within the CalEEMod analysis:
• All heavy diesel construction equipment would be classified as Tier 4; and • Compliance with SDAPCD’s fugitive dust rules and fugitive dust control measures which would be provided by the City of San Marcos.

In addition, due to bedrock conditions, the project also may require some blasting and crushing during earthwork/ grading of the project site. During blasting operations, grading operations would temporarily stop and resume once blasting is completed. Per conversations with the project c ivil engineer, it is expected that each blast would be limited to the following. as noted in the project design feature table (Table 2-1):
• Blasts are limited to once per day;
• Blasts are limited to six tons of ammonium nitrate for any given blast operation; and • The area of each blast would be limited to 20,000 s.f. or (100-foot x 200-foot) area.

Blasting operations usually require a chemical material that is capable of extremely rapid combustion resulting in an explosion or detonation. These materials are usually mixtures of several ingredients but are often oxygen deficient as combustion reaction s take place which causes a formation of carbon monoxide and to a lesser extent, nitrogen oxides. For ammonium nitrate and fuel oil (ANFO) mixtures, it is expected that carbon monoxide would be generated in quantities of 67 pounds (lbs) per every ton of explosives and nitrogen oxides would be generated at 17 lbs per the same quantity. Particulate matter will also be generated from blasting and was estimated using US EPA AP-42 (Compilation of Air Emissions Factors from Stationary Sources (Table 13.3-1) 5 methodology (USEPA 1980).

The proposed project would utilize approximately 6 tons of ammonium nitrate per blast which would generate up to 402 lbs (67 lbs/ton * 6 tons) of carbon monoxide and up to 102 lbs (17 lbs/ton * 6 tons) of nitrogen oxides during a blast. These quantities would be additive to the mass grading operations for the entire project site and were added to the worst-case mass grading daily CO and NOx output. Additional particulates derived from each blast is estimated over a 20,000 s.f. area (roughly 100-foot by 200-foot in dimension). Given this, it is estimated that each blast would generate 20.59 lbs/blast. A blasting permit would be requi red from the San Marcos Fire Department which would include required terms and would limit the blasting material to 6 tons per day as this was indicated as the expected blast charge.

The project’s requested approvals include a Conditional Use Permit (CUP 23--0002), which would allow for the use of a temporary rock crusher. The rock crusher assumed to be used during blasting would be similar to the Terex 4242SR 310 HP unit (LDN 2024).

5 Table 13.3-1 is Emission Factors for Detonation of Explosives Emission Factor Rating https://www.epa.gov/sites/default/files/2020-10/documents/13.3_explosives_detonation.pdf

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Table 3.2-6 presents construction-related emissions. As shown in Table 3.2-6, construction emissions for all criteria pollutants would be below the screening level thresholds. Therefore, construction-related air emissions would not violate any air quality standards and impacts are less than significant.

Table 3.2-6. Construction Emissions (Pounds/Day)
Year ROG NOx CO SO2 PM10
(Dust)
PM10
(Exhaust)
PM10
(Total)
PM2.5
(Dust)
PM2.5
(Exhaust)
PM2.5
(Total)
2026 14.3 8.22 31.7 0.07 0.16 9.76 9.92 0.14 3.89 4.03
Blasting
Emissions 102 402 20.59 20.59
Total
Construction With
Blasting
(Maximum)
Emissions

14.3 110.22 433.7 0.07 20.75 9.76 30.51 0.14 3.89 4.03
Screening Level
Threshold 75 250 550 250 - - 100 - - 55
Exceed
Threshold? No No No No - - No - - No
Source: LDN 2024.

Operational Emissions Analysis
Daily project operations would generate emissions from sources such as area, energy, and mobile uses. Area sources include consumer products, landscaping, and architectural coatings as part of regular maintenance. Energy sources would be from uses such as onsite natural gas and electrical use. Mobile source emissions include project traffic generation. Operational emissions were calculated using CalEEMod for both summer and winter scenarios.

The CalEEMod calculations include the following assumptions (LDN 2024):
• The traffic inputs for CalEEMod were adjusted to be consistent with the proposed project traffic study. Based on that study, the proposed project would generate 1,214 net average daily trips (LLG 2024).
• Default trip distances within CalEEMod were utilized. • It was assumed that an average of 10% of the structural surface area will be re-painted each year.
• Since the proposed project would not be installing hearth options, CalEEMod default hearth settings were modified to represent no hearth options.
• CalEEMod includes landscaping and consumer product assumptions which would apply to this project. Consumer product emissions are generated by a wide range of product categories, including air fresheners, automotive products, household cleaners, and personal care products. Emissions associated with these products primarily depend on the increased population associated with residential development (512 residents).

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Table 3.2-7 summarizes project-related operational emissions, including vehicular and fixed -source emissions. As shown, total operational emissions of the project would be below the SDAPCD screening thresholds for all criteria pollutants in both summer and winter. Th erefore, operation-related impacts would not violate any air quality standard and would be less than significant.

Table 3.2-7. Operational Emissions (Pounds/Day)
ROG NOx CO SOx PM10 PM2.5
Summer Scenario
Mobile 4.52 2.82 29.7 0.07 6.30 1.63
Area Source 5.20 0.12 12.90 < 0.005 0.01 0.01
Energy Use 0.02 0.30 0.13 < 0.005 0.02 0.02
Total 9.73 3.24 42.7 0.07 6.34 1.67
Screening Level Threshold 75 250 550 250 100 55
Above threshold? No No No No No No
Winter Scenario
Mobile 4.42 3.10 28.40 0.07 6.30 1.63
Area 3.80 0.22 0.10 0.00 0.02 0.02
Energy 0.02 0.30 0.13 < 0.005 0.02 0.02
Total 8.24 3.40 28.50 0.07 6.33 1.66
Screening Level Threshold 75 250 550 250 100 55
Above Threshold? No No No No No No
Source: LDN 2024.

Notes: Daily pollutant generation assumes trip distances within CalEEMod.

Outputs from CalEEMod include rounding and may not add up exactly.

Threshold #3: Expose sensitive receptors to substantial pollutant concentrations? Sensitive receptors are defined as schools, hospitals, resident care facilities, or day -care centers, as well as residential receptors in the project vicinity. Sensitive residential receptors are adjacent to the project site, less than 100 feet from the eastern property line. The threshold related to sensitive receptors addresses whether the project could expose sensitive receptors to substantial pollutant concentrations of criteria pollutants or TACs. As identified above, if a project has the potential to result in emissions of any TAC that results in a cancer risk of greater than 10 in 1 million or substantial non- cancer risk, the project would be deemed to have a potentially significant impact.

To address the potential for emissions of construction-related TAC emissions to result in exposure of sensitive receptors to substantial pollutant concentrations, a screening health risk assessment was conducted for construction emissions. The risk -driving toxic air contaminant that would be emitted during construction would be diesel particulate matter.

Risks were calculated based on the Office of Environmental Health Hazards Assessment update guidance (OEHHA 2015). Cancer risk is calculated by multiplying the daily inhalation or oral dose, by a cancer potency factor, the age sensitivity factor, the frequency of time spent at home, and the exposure duration divided by averaging time, to yield the excess cancer risk. Based upon the air quality

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modeling, worst-case onsite PM10 from onsite construction exhaust would cumulatively produce 0.006 tons over the construction duration (337 calendar days) or an average of 1.87x10 -4 grams/second (LDN 2024).

Utilizing these figures and based on the AERSCREEN dispersion model, the maximum 1 -hr concentration is 0.537 µg/m3 during the worst-case construction period. The annual concentration is

0.0429 µg/m3. Therefore, the inhalation cancer risk is 6.04 per million over the construction duration.

This risk would be expressed at the point of maximum exposure 50 meters (164 feet) away. As a condition of project approval, the project would be required to utiliz e Tier 4 diesel equipment. Since the threshold is 10 per million exposed with T -BACT installed, the project would have a less than significant impact and would be in compliance with the City’s thresholds. It should be noted that sensitive residential receptors are adjacent to the project site , less than 100 feet from the eastern property line. With the use of Tier 4 diesel equipment, the project would not expose sensitive receptors to cancer risk above the threshold (LDN 2024).

There are known chronic health risks associated with diesel exhaust which are considered non-cancer risks. Non-Cancer risks or risks defined as chronic or acute are also known with respect to diesel particulate matter and are determined by the hazard index . To calculate hazard index, diesel particulate matter concentration is divided by its chronic Reference Exposure Levels (REL). Where the total equals or exceeds one, a health hazard is presumed to exist. RELs are published by the Office of Environmental H ealth Hazard Assessment. Diesel Exhaust has a REL of 5 μg/m 3 and targets the respiratory system (LDN 2024). The hourly concentration of 0.537 µg/m 3 divided by the REL of 5 µg/m3 yields a Health Hazard Index of 0.107, which is less than one. Therefore, based on thresholds for non-cancer risks, non-cancer health risks are also considered less than significant. Therefore, toxic air contaminant impacts associated with the project would be less than significant.

Carbon Monoxide (CO) Hotspot Analysis
Air quality emissions from the operation of the proposed project, including project generated traffic would not exceed air quality significance thresholds established by the City of San Marcos. In addition, the project traffic study indicated that under no scenario (existing, near term or long term) would the project have significant effects on nearby intersections and segments because the project traffic does not exceed the City’s LOS D thresholds (LLG 2024). Given this, the project would not have the potential to increase CO hot spots at any of the nearby intersections or roadway segments.

Threshold #4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Construction
Construction activities associated with development of the project site could generate trace amounts of substances such as ammonia, carbon dioxide, hydrogen sulfide, methane, dust, organic dust, and endotoxins. Any generation of odors related to these subs tances would occur intermittently during construction. Construction activities may also generate odors associated with diesel equipment at various locations. Odors would be strongest at the source and would quickly dissipate. The short term and intermittent duration of any odor emissions would ensure construction -related impacts are less
than significant.

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Operation
Future development on the project site includes multi -family residences and commercial retail uses.

These uses would not meet typical uses generating odors which CARB outlines in their Land Use Handbook which include: sewage treatment plants, landfills, recycling facilities, waste transfer stations, refineries, biomass operations, autobody shops, coati ng operations, fiberglass manufacturing, foundries, rendering plants and livestock operations. Since the project does not propose these types of uses or any other uses which would result in operational odors, impacts would be less than significant.

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

As part of the RAQS and SIP planning process, the SDAPCD develops an emission inventory, based on growth projections from SANDAG (which are based on land use designations) and existing emissions figures within the SDAB. The SDAPCD then uses the emission inventory to conduct modeling to demonstrate that the SDAB will attain and maintain the state and federal O 3 standards. This inventory
could be thought of as an “emissions budget” for the SDAB, accounting for current emissions as well as previously approved projects consistent with current General Plan policies. Projects that are consistent with the currently adopted General Plan are determined to be consistent with SDAB’s air quality plans, including the RAQS and the SIP. If a project proposes development that is consistent with or less than estimates provided in the General Plan, the project will not conflict with or obstruct implementation of the RAQS or SIP. Provided a project’s emissions are consistent with the projections within the RAQS and SIP, the pro ject would not result in a cumulatively considerable impact on O 3 within the SDAB.

As discussed in Section 3.2.4, Threshold #1, a potential use for the site under its current land use and zoning designation could be to install a 16 0,000 s.f. telecommunications data center or larger if multiple stories are constructed . Data centers are recognized as very high consumers of electrical energy. A 160,000 s.f. building would require at least 257,600 MWH annually. Based on modeling, the proposed project would consume 907 MWH which is about 285 times less energy and significantly less intense (LDN 2024) . From an energy usage standpoint even though, electrical energy is not directly estimated in this air quality analysis, a reduction in energy would generate fewer offsite air quality emissions which could be expected within the utility provider’s electrical generation.

The proposed project is, therefore, considered less intense in terms of air quality than would otherwise be allowed within the P-I General Plan land use. In addition, the project conforms to all local air district significance thresholds. For nonattainment pollutants (PM 10 and PM2.5 plus O3, with O3 precursors NOx
and VOCs), if emissions exceed the thresholds shown in Table 3.2-5, the project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality. As shown in Tables 3.2 -6 and 3.2 -7, air quality

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emissions generated by the project would be lower than the SDAPCD screening thresholds. Also, since the project would not generate significant direct or cumulative construction or operational impacts, the project would be consistent with the County’s RAQS and would comply with the state’s SIP.

Cumulative localized impacts would potentially occur if a construction project were to occur concurrently with another off -site project. Based on discussions with the City, no other large construction projects are expected to occur simultaneously and within the immediate vicinity (up to

0.5 miles) to the proposed project. Further, it is unknown whether the cumulative projects under review will be approved or not, and, if approved, when actual construction would begin, it would be speculative to estimate any potential overlap of the proposed project. However, future projects would be subject to CEQA and would require an air quality analysis and, where necessary, mitigation, if the project would exceed the SDAPCD significance thresholds. Criteria air pollutant emissions associated with construction activity of future projects would be reduced through implementation of control measures required by SDAPCD. Cumulative PM
10 and PM 2.5 emissions would be reduced because all future projects would be subject to SDAPCD Rule 55, Fugitive Dust, which sets forth general and specific requirements for all construction sites in the SDAPCD.

Based upon the air quality modeling, with the use of Tier 4 diesel equipment, the project would not expose sensitive receptors to cancer risk above the threshold Additionally, no odor impacts were identified. Implementation of the project is not expected t o contribute to any cumulative health risks or annoyance from odors. Cumulative impacts would be
less than significant.

3.2.6 Mitigation Measures
Based upon the analysis presented in Sections 3.2.4 and 3.2.5, project and cumulative air quality impacts would be less than significant. Therefore, no mitigation measures are necessary.

3.2.7 Conclusion
Implementation of the proposed project would not violate any air quality standard or contribute substantially to an existing or projected air quality violation during construction or operation, nor would the project conflict with or obstruct implementation of the RAQS or SIP. Additionally, sensitive receptors would not be exposed to substantial pollutant concentrations or significant health risk, nor would a substantial number of people be exposed to objectionable odors.

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3.3 Biological Resources
Introduction
This section provides a biological resources impact analysis for the proposed project. The analysis in this section is based upon the following report prepared by Dudek, which is included as Appendix D of the Environmental Impact Report (EIR):
• Biological Resources Technical Report for the Armorlite Lofts Project. Prepared by Dudek, October 2024 (Dudek 2025 2024)
In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to interfere with or impact state or federally protected wetlands, wildlife corridors and nursery sites. Section 5. 3, Environmental Effects Found Not to be Significant – Biological Resources, of the EIR provides additional information on these topics.

Table 3.3 -1 summarizes the project - and cumulative -level impact analysis by threshold for the proposed project.

Table 3.3-1. Biological Resources Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1: Have a substantial adverse effect either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive or special status species in local or
regional plans, policies, or regulations or by
the California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service.

Significant Impact Less than
Significant
Mitigated to Less
Than Significant
#2: Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations, or by the
California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service?
Significant Impact Less than
Significant
Mitigated to Less
Than Significant
#3: Conflict with any local policies or
ordinances protecting biological resources,
such as tree preservation policy or ordinance.

Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#4: Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan.

Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation

3.3.1 Existing Conditions
The 2.44-acre project site is currently undeveloped, vacant land located on Armorlite Drive, east of North Las Posas Road and south of W. Mission Road. The project site is enclosed by chain-link fencing along the north, south and western property boundary and open cable railing situated atop a small

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retaining wall along the eastern property boundary. A gated driveway onto the site is located on Armorlite Drive, and a second gated driveway in the northwestern portion of the property provides vehicular access via the adjacent AT&T facility to the west. Well -used foot paths and a hole in the chain-link fencing along the northern property limits indicate informal walk-through access across the property. Other signs of site disturbance include pet waste and miscellaneous trash and litter. The site is generally flat with two small, paved drive aisles and slopes downward along its edges. Elevations on site range from 562 to 575 feet above mean sea level.

The project site is situated in a developed area of the City with the mixed use residential to the east and south (Palomar Station and Marc San Marcos) ; a drive -thru restaurant and AT&T facility to the west; and the North County Transit District railroad right -of-way, W . Mission Road, and additional commercial development to the north.

Dudek conducted a review of historical aerial photographs of the project site and general vicinity, to help determine if ephemeral basins or vernal pools may currently be on the project site or may have been present in the past. Historical aerial photograp hs of the project site were available from as far back as 1938 to the present. No evidence or aerial signatures of vernal pools or ephemeral basins were documented during these years. Note that the lack of evidence or aerial signatures of vernal pools and ephemeral basins does not necessarily mean that these features were never present on the project site during these years, but it is likely that if these features were present for a sustained period of time that they would have most likely been detected during this analysis (Dudek 2025 2024).

The available historical aerial photographs prior to 2012 showed a significant amount of disturbed land (primarily disturbed Diegan coastal sage scrub and bare ground) across the project site. The parcel may have been used as an informal dirt parking area or subject to off-road vehicle use as aerial photographs show bare areas and dirt roads b ecoming established over time. An aerial photograph from 1994 shows commercial development immediately west of the project site. By late 2005, it appears the project site was at least partially fenced, coinciding with a steady increase of new coastal sage scrub habitat from that point onwards likely resulting from diminished human disturbances on the site. Construction of the mixed -use residential (Palomar Station), abutting the east side of the project site began in 2013. A retaining wall constructed along the eastern boundary of the project site as part of the Palomar Station development suggests the existing topography of the site is at least partially, if not entirely, natural and comprised of native rather than imported soils. By 2021, aerial photographs show the majority of coastal sage scrub habitat in the project site to be disturbed.

However, the aerial photograph from July 2021 shows more evidence of project site disturbance, with two intersecting, perpendicular lines having been graded within the p roject site, exposing more soil and creating more bare ground. The project site remains undeveloped to the present.

Dudek conducted an initial biological reconnaissance visit, habitat assessment, vegetation mapping, aquatic resources assessment, 24-hour post rainfall site visits, focused coastal California gnatcatcher (Polioptila californica californica) surveys, and focused special-status plant surveys between 2021 and 2023.The results of these assessments are summarized below.

Vegetation Communities, Land Cover and Habitat Assessment Assessment Methodology
To locate and characterize natural vegetation communities, including habitats for special -status species, within the project site , Dudek conducted biological field surveys in June 2023, including a biological reconnaissance survey and general habitat assessment. Vegetation communities and land covers on site were mapped in the field directly onto a digital aerial photograph –based field map of

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the project study area. Following completion of the fieldwork, all vegetation polygons were transferred to a topographic base and digitized using ArcGIS, and a geographic information system (GIS) coverage was created. Once in ArcGIS, the acreage of each vegetation community and land cover present in the project study area was determined. Vegetation community classifications followed the Preliminary Descriptions of the Terrestrial Natural Communities of California ( Holland 1986), as modified for San Diego County in Draft Vegetation Communities of San Diego County (Oberbauer et al. 2008). Vegetation mapping was originally conducted within the project site on June 11, 2021. Vegetation mapping was updated on May 25 and July 12, 2023, in conjunction with the botanical surveys.

Vegetation Communities
The project site consists of mostly undeveloped lands, with a mix of native and non-native vegetation communities. In total, three vegetation communities and/or land cover types were identified within the project site based on general physiognomy and speci es composition, including two native or naturalized vegetation types and one non -natural land cover. The Multiple Habitat Conservation Program (MHCP) organizes vegetation into habitat group types: Group A- Wetland Communities, Group B - Rare Upland, Group C- Coastal Sage Scrub, Group D - Chaparral, Group E- Annual Grassland, and Group F - Other (SANDAG 2003).

Table 3.3 -2 shows the vegetation communities observed on the project. These communities are mapped in Figure 3.3-1 and discussed further below.

Table 3.3-2. Vegetation Community/Land Cover Types within Project Site Habitat Group Vegetation Community/
Land Cover Type Sensitive? Total Onsite (Acres)
C Diegan Coastal Sage Scrub Yes 2.13
E Non-Native Grassland Broadleaf-
Dominated Yes 0.12
F Disturbed Habitat No 0.20
Total(1) 2.44
Source: Dudek 2025 2024.

Notes: (1) Numbers may not sum due to rounding
Diegan Coastal Sage Scrub
Diegan coastal sage scrub habitat occupies 2.13 acre on site. Diegan coastal sage scrub is a native vegetation community that is composed of a variety of soft, low, aromatic shrubs, characteristically dominated by drought -deciduous species such as California sagebrush ( Artemisia californica), California buckwheat ( Eriogonum fasciculatum ), and sages (Salvia spp.), with scattered evergreen shrubs, including lemonade berry (Rhus integrifolia) and laurel sumac (Malosma laurina). The average height of coastal sage scrub reaches three to four feet.

Diegan coastal sage scrub occurs throughout most of the project site. In the northern portion of the site, the Diegan coastal sage scrub is dominated by California sagebrush (Artemisia californica). Other shrubs include black sage ( Salvia mellifera), white sage ( S. apiana), coyotebrush ( Baccharis pilularis), and California buckwheat (Eriogonum fasciculatum). The Diegan coastal sage scrub is disturbed by the presence of non -native species, such as black mustard ( Brassica nigra), horehound ( Marrubium vulgare), and some anthropogenic trash. The Diegan coastal sage scrub in the southern portion of the site includes a higher cover of black sage and white sage and is generally denser than the northern

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portion of the site. The City considers Diegan Coastal Sage Scrub a sensitive community, falling under Habitat Group C.

Non-Native Grassland- Broadleaf Dominated
Non-native grassland—broadleaf dominated habitat occupies 0.12 acres on site. Non-native grassland consists of dense to sparse cover of non -native invasive broadleaf species. This designation is used when non -native, invasive broadleaf species make up more than 50% cover of the vegetation community. In San Diego County, the presence of black mustard and shortpod mustard ( Hirschfeldia incana) are common indicators of this community. In some areas, depending on past disturbance and annual rainfall, some mustards are more abundant than others.

Non-native grassland–broadleaf dominated is disturbed on site and consists mostly of black mustard.

Less commonly occurring species include stinkwort ( Dittrichia graveolens) and red brome ( Bromus madritensis). Non-Native Grassland – Broadleaf Dominated is considered a sensitive community by the City, falling under Habitat Group E.

Disturbed Habitat
Disturbed habitat occupies 0.20 acre on site. Disturbed habitats are areas that have been physically disturbed and are no longer recognizable as a native or naturalized vegetation association. These areas may continue to retain a soil substrate. If vegetat ion is present, it is almost entirely composed of non-native vegetation, such as ornamentals or ruderal exotic species. Examples of these areas may include graded landscapes, graded firebreaks, graded construction pads, temporary construction staging areas, off-road-vehicle trails, areas repeatedly cleared for fuel management, and areas that are repeatedly used in ways that prevent revegetation (e.g., parking lots, worn trails that have persisted for years).

Disturbed habitat occurs in the fenced off portion in the northwestern portion of the site that consists of gravelly substrate, as well as mulch. There are a few scattered immature shrubs and non -native forbs still present in this area. The other area of disturbed habitat is the road that extends from the southwestern edge of the site north through about half of the property. Some gravel has been applied and the road is maintained enough to prevent significant plant development. Disturbed habitat is not considered a sensitive community by the City. Disturbed habitat falls under Habitat Group F.

Aquatic Resources Assessment
Assessment Methodology
A jurisdictional aquatic resource assessment was conducted within the project site on November 4, 2022 by Dudek biologist Brock Ortega to determine the extent of aquatic resources that may be under the jurisdiction of the United States Army Corps of Engineers (USACE) pursuant to Section 404 of the federal Clean Water Act, Regional Water Quality Control Board (RWQCB) pursuant to Clean Water Act Section 401 and the Porter –Cologne Act, and California Department of Fish and Wildlife (CDFW) pursuant to Sections 1600– 1603 of the California Fish and Game Code. The assessment was conducted in accordance with the methods prescribed in the 1987 Corps of Engineers Wetland Delineation Manual, the 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0), and the Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States: A Delineation Manual.

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During the assessment, the site was walked and evaluated for evidence of an OHWM, surface water, saturation, wetland vegetation, and nexus to a traditional navigable water of the United States. In addition, any aquatic resources were anecdotally identified using the Cowardin method of wetlands classification, which defines wetland boundaries by the presence of at least one parameter (i.e., hydric soils, hydrophytic vegetation, or hydrology). Aquatic resources were documented by visually assessing and mappin g any hydrophytic vegetation and/or the presence or absence of surface hydrology indicators (e.g., drift lines, drainage patterns, scour etc.). Soil samples were not taken during this effort.

In addition, site visits to check for the presence of surface water or ponding of at least 3 centimeters (cm) were conducted within 24 hours after each rain event (approximately 15 visits) during the 2022- 2023 wet season. Visits to a nearby reference site (within one mile of the project site) where vernal pools were present were also conducted.

Aquatic Resources
Although the site falls within the northwestern corner of a polygon that is identified as a Vernal Pool Major Amendment Area (as shown in the City’s Draft SAP), it has been extensively disturbed over the years by anthropogenic influences such as past construction grading as well as utility excavation and exploration, and historic aerial photographs show that the parcel may have been used as an informal dirt parking area or subject to off-road vehicle use in the past. While some minor ponding was observed within the project site during visits within 24 hours after rainfall events, during none of the visits did ponding meet the 3 cm threshold that would trigger initiation of wet -season protocol surveys for San Diego fairy shrimp. By comparison, the rainfall wa s sufficient to establish inundation (pools greater than 3 cm deep) at the nearby reference site where known vernal pools have filled and remained inundated beyond the 24-hour post-rainfall assessment period. Therefore, observations show that the site is not suitable for ponding or fairy shrimp, and that there are no other aquatic resources that would be under the jurisdiction of aquatic resource agencies (Dudek 2025 2024).

Critical Habitat
Critical habitat, as defined by the U.S. Fish and Wildlife Service (USFWS), are (1) specific areas that are either occupied by a species at the time of its listing that contain the physical or biological features that are essential to the conservation of e ndangered and threatened species and that may need special management or protection and/or (2) include areas that were not occupied by the species at the time of listing but are essential to its conservation.

San Diego Fairy Shrimp
San Diego fairy shrimp critical habitat designated in 2007 encompasses nearly the entire project site as well as a large portion of the existing Palomar Station development to the east and south. There is also San Diego fairy shrimp critical habitat designated within a vernal pool reference site southeast of the project site, as well as within two additional parcels west of S. Las Posas Road, on opposite sides of Linda Vista Drive, within the one -mile vicinity of the project site, all designated in 2007. However, field study observations in 2023 show that the site does not support suitable ponding or habitat for fairy shrimp. Therefore, the site does not contain the physical or biological features essential to the conservation of the species (i.e., primary c onstituent elements, such as vernal pools or supporting topographic features) (Dudek 2025 2024).

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Thread-leaved Brodiaea
The closest critical habitat for thread-leaved brodiaea is located approximately 0.2-miles northwest of the project site, between W. Mission Road and N . Las Posas Road, designated in 2011. Additional thread-leaved brodiaea critical habitat designated in 2011 overlaps the same two parcels containing critical habitat for San Diego fairy shrimp located on opposite sides of Linda Vista Drive within one mile of the project site. However, no critical habitat for thread-leaved brodiaea was identified on the project site and thread-leaved brodiaea was not observed during focused surveys for special-status plants in May and July 2023. Although there is suitable coastal sage scrub vegetation, soils are not clay so it was determined to have a low potential to occur (Dudek 2025 2024).

Spreading Navarretia
Critical habitat for spreading navarretia was designated in 2010 within the same vernal pool mitigation area discussed above, as well as in the same parcels west of S. Las Posas Road on opposite sides of Linda Vista Drive. However, no critical habitat for spreading navarretia was identified on the project site and spreading navarretia is not expected to occur as no suitable vegetation is present ( Dudek 2025 2024).

There is no critical habitat for coastal California gnatcatcher within the site or within a 1-mile buffer Plant Species Assessment
Seventy-five vascular plant species consisting of 35 native species (47%) and 40 non -native species (53%) were recorded during rare plant surveys conducted for the project study area.

Special-Status Plant Survey Methodology
Prior to special-status plant surveys, Dudek evaluated plant records in the U.S. Geological Survey 7.5- minute San Marcos quadrangle and the surrounding Morro Hill, Bonsall, Pala, San Luis Rey, Valley Center, Encinitas, Rancho Santa Fe, and Escondido quadra ngles to determine target species. In addition, Dudek’s knowledge of biological resources and regional distribution of each species, as well as elevation, habitat, and soils present within the project site were evaluated to determine the potential for various special-status plant species to occur (Dudek 2025 2024).

On May 25, 2023 and July 12, 2023, focused surveys for special-status plants were conducted on site by Dudek biologist Kathleen Dayton. This survey was conducted at the appropriate phenological stage to detect and identify target species. Reference checks were conducted for key target species. Thread- leaved brodiaea ( Brodiaea filifolia ) and Orcutt’s brodiaea ( Brodiaea orcuttii ) were observed just starting to bloom on May 10, 2023, in San Marcos. Orcutt’s brodiaea (Brodiaea orcuttii) was observed again in ea rly bloom on May 17, 2023, and still in bloom on June 27, 2023. Southern tarplant (Centromadia parryi ssp. Australis) was observed in full bloom on reference sites on July 11, 2023.

Field survey methods conformed to California Native Plant Society (CNPS) Botanical Survey Guidelines; Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities; and General Rare Plant Survey Guidelines. Surveys were conducted by walking meandering transects throughout the project site to detect special-status species. All plant species were identified and recorded in Appendix A of the biological resources technical report, which is Appendix D of the EIR.

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Sensitive Plant Species Observed or With Potential to Occur Endangered, rare, or threatened plant species, as defined in the California Environmental Quality Act (CEQA) Guidelines Section 15380(b) (14 CCR 15000 et seq.), are referred to as “special-status plant species” in the biological technical report and includ e (1) endangered or threatened plant species recognized in the context of the California Endangered Species Act (CESA) and the federal Endangered Species Act (FESA), and (2) plant species with a California Rare Plant Rank (CRPR) 1 through 3. The biological technical report also includes CRPR 4 plant species (Dudek 2025 2024).

No special-status plants were observed on site. Appendix C of the biological resources technical report (Appendix D of the EIR) provides a list of all special-status plant species with their habitat requirements and potential to occur on the project site. It also provides evaluations for each of the special -status species’ occurrence in the vicinity of the project site and its potential to occur in the project site based on known geographic range, habitat associations, preferred soil substrate, life form, e levation, and blooming period. No special-status plants were observed on site, and none have a moderate or high potential to occur (Dudek 2025 2024).

Wildlife Species
A total of 16 wildlife species were observed at the project site, all of which consisted of native species.

A cumulative list of wildlife species observed during 2022 and 2023 surveys is provided in Appendix B of the biological resources technical report, which is Appendix D of the EIR.

Sensitive Wildlife Species Observed or With Potential to Occur Species defined as “special-status wildlife species” in the biological resources technical report include endangered and threatened wildlife species recognized in the context of the California and federal Endangered Species Acts; Species of Special Concern (SSC) assigned by CDFW to species whose population levels are declining, have limited ranges, and/or are vulnerable to extinction due to continuing threats; Fully Protected species protected by CDFW and Watch List species candidates for higher sensitivity statuses; and Birds of Conservation Concern designated by USFWS to migratory and non-migratory bird species that adhere to the 1988 amendment to the Fish and Wildlife Conservation Act that mandates USFWS to “identify species, subspecies, and populations of all migratory nongame birds that, without additional conservation actions, are likely to become candidates for listing under the Federal Endangered Species Act of 1973.

Appendix D of the biological resources technical report lists the special-status wildlife species known to occur within the U.S. Geological Survey (USGS) San Marcos 7.5 -minute quadrangle map and the eight quadrangle maps surrounding the project site—Morro Hill, Bonsall, Pala, San Luis Rey, Valley Center, Encinitas, Rancho Santa Fe, and Escondido. Based on a review of the potential species to occur within the region, habitat conditions identified within project site, as well as results of focused surveys, no special-status wildlife species have a moderate to high potential to occur within the project site.

Coastal California Gnatcatcher
Focused surveys for the coastal California gnatcatcher ( Polioptila californica californica) (a federally listed threatened species and a CDFW Species of Special Concern) were conducted within the project site between October 2022 and February 2023 by Dudek biologist Kamarul Muri (Permit # TE - 813545). The surveys were conducted in conformance with the currently accepted protocol of the U.S.

Fish and Wildlife Service (USFWS 1997) for projects that are not within an NCCP jurisdiction.

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A tape of recorded California gnatcatcher vocalizations played approximately every 50 to 100 feet was used to induce responses from potentially present gnatcatchers. If a gnatcatcher was detected, the recorded playback would be immediately terminated to minimize potential for harassment. Aerial coverage of the area in the ESRI Field Maps mobile application was used to navigate the site and map any gnatcatchers detected. Binoculars (10 x 42) were used to aid in detecting and identifying bird species. Weather conditions, time of day, and season were appropriate for the detection of gnatcatchers.

Although suitable coastal sage scrub habitat capable of supporting coastal California gnatcatcher (Polioptila californica californica ) occurs throughout the study area, none were heard or observed during the focused, protocol level surveys for this species. As such, this species is not expected to occur within the project site (Dudek 2025 2024). Appendix E of the biological resources technical report includes the focused California gnatcatcher survey report (Appendix D of the EIR).

Due to lack of suitable habitat, no other focused special -status wildlife species surveys were conducted within the project site (Dudek 2025 2024).

Nesting Birds
The habitats within the project site, which include Diegan coastal sage scrub, provide suitable nesting habitat for a variety of nesting bird species that are protected under the Migratory Bird Treaty Act and Fish and Game Code 3503.5.

Roosting Bats
Due to its small size, location within an urbanized setting, and lack of suitable habitat including rocky outcrops and cliffs, caves, mines, trees, and structures such as buildings, bridges, or other anthropogenic features, the project site is not likely t o provide suitable roosting habitat for special - status bats. Additionally, no active roosts or sign of active roosting (i.e., guano or staining) were detected during any of the site visits between 2021 – 2023.

Crotch’s Bumble Bee
Crotch’s bumble bee (Bombus crotchii) is a candidate for listing as endangered under the California Endangered Species Act (CESA). The species was listed as a candidate on September 30, 2022, with the final listing determination expected in summer 2025.

The site is small and located within an urbanized setting as it is surrounded by commercial and residential developments on all sides. Additionally, although potentially suitable coastal sage scrub habitat is present, the site shows evidence of anthropogen ic disturbance and past grading activities and is largely depauperate, lacking many of the diverse floral resources preferred by Crotch’s bumble bee such as milkweeds, lupines, medics, phacelias, clarkias, poppies, and larkspurs. Furthermore, the closest k nown records of this species occur in the Lake Calavera area, approximately 5.5 miles northwest from the site (CDFW 2025). Therefore, the proposed project site is not likely to support foraging or nesting of this species.

Habitat Connectivity and Wildlife Corridors
Wildlife corridors are linear features that connect large patches of natural open space and provide avenues for the migration of animals. Habitat linkages are small patches that join larger blocks of habitat and help reduce the adverse effects of habitat fragmentation. To function effectively, a wildlife

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corridor must link two or more patches of habitat for which connectivity is desired, and it must be suitable for the focal target species to achieve the desired demographic and genetic exchange between populations.

The 2.44-acre 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 MBTA 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 any large wildlife movement through urban landscape. In addition, the site is not located within a Biological Core Linkage Area. As such, the isolated project site is not expected to provide for wildlife movement or serve as an important habitat linkage for wildlife traversing the region (Dudek 2025 2024).

3.3.2 Regulatory Setting
Federal
United States Army Corps of Engineers – Clean Water Act Recognizing the potential for continued or accelerated degradation of the Nation's waters, the U.S.

Congress enacted the Clean Water Act (CWA), formerly known as the Federal Water Pollution Control Act (33 U.S.C. 1344). The objective of the CWA is to maintain and restore the chemical, physical, and biological integrity of the waters of the United States. Section 404 of the CWA authorizes the Secretary of the Army, acting through the Chief of Engineers, to issue permits for the discharge of dredged or fill material into the waters of the United States, including wetlands. The term “wetlands” (a subset of waters of the United States) is defined in Title 33 of the Code of Federal Regulations, Section 328.3(c)(1), as “those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” In the absence of wetlands, the limits of USACE jurisdiction in non- tidal waters, such as intermittent streams, extend to the ordinary high water mark (OHWM), which is defined in Title 33 of the Code of Federal Regulations, Section 328.3(c)(4).

United States Fish and Wildlife Service – Endangered Species Act The United States Fish and Wildlife Service (USFWS) is responsible for enforcing the federal Endangered Species Act (ESA), Migratory Bird Treaty Act, and Wildlife Coordination Act, and reviews and comments on applications for Section 404 CWA permits submitted to the USACE. If the proposed project is determined to have an adverse effect on a species that is federally listed as threatened or endangered, consultation with the USFWS would be required. The federal Endangered Species Act defines an endangered species as “any species that is in danger of extinction throughout all or a significant portion of its range.” A threatened species is defined as “any species that is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” If the proposed project may result in “take” of a federally listed species, an incidental take permit would be required. “Take” is defined in the ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.”

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United States Fish and Wildlife Service – Migratory Bird Treaty Act The Migratory Bird Treaty Act (MBTA) (16 USC 703 et seq.) is a federal statute that implements treaties with several countries on the conservation and protection of migratory birds. The number of bird species covered by the MBTA is extensive and is listed in 50 CFR 10.13. The regulatory definition of “migratory bird” is broad and includes any mutation or hybrid of a listed species and includes any part, egg, or nest of such bird (50 CFR 10.12). Migratory birds are not necessarily federally listed endangered or threatened birds under the ESA. The MBTA, which is enforced by USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migratory bird or attempt such actions, except as permitted by regulation. The applic able regulations prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, except under a valid permit or as permitted in the implementing regulations (50 CFR 21.11).

State
California Fish and Game Code
Sections 3511 (Birds), 4700 (Mammals), 5050 (Reptiles and Amphibians), and 5515 (Fish) of the California Fish and Game Code provide that designated fully protected species may not be taken or possessed without a permit. Incidental take of these species is not authorized by law.

Pursuant to Section 3503.5 of the California Fish and Game Code, it is unlawful to take, possess, or destroy any birds of prey; or to take, possess, or destroy any nest or eggs of such birds. Birds of prey refer to species in the orders Falconiformes and Strigiformes.

Nests of all other birds (except English sparrow [ Passer domesticus] and European starling [Sturnus vulgaris]) are protected under Sections 3503 and 3513 of the California Fish and Game Code.

Pursuant to Section 1602 of the California Fish and Game Code, CDFW regulates all diversions, obstructions, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake that supports fish or wildlife. Diversion, obstruction, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake that supports fish or wildlife requires authorization from CDFW by means of entering into an agreement pursuant to Section 1602 of the California Fish and Game Code.

California Endangered Species Act
The CDFW administers the California Endangered Species Act (CESA), which prohibits the “take” of plant and animal species designated by the California Fish and Game Commission as endangered or threatened in California. Under CESA Section 86, take is defined as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” CESA Section 2053 stipulates that state agencies may not approve projects that will “jeopardize the continued existence of any endangered species or threatened species, or result in the destruction or adverse modification of habitat essential to the continued existence of those species, if there are reasonable and prudent alternatives available consistent with conserving the species or its habitat which would prevent jeopardy.” CESA defines an endangered species as “a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant which is in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease.” CESA defines a threatened species as “a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that, although not presently threatened with extinction, is likely to become an endangered species in the foreseeable future in the

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absence of the special protection and management efforts required by this chapter. Any animal determined by the [California Fish and Game] Commission as rare on or before January 1, 1985, is a threatened species.” A candidate species is defined as “a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the Commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for which the Commission has published a notice of proposed regulation to add the species to either list.” CESA does not list invertebrate species.

CESA authorizes the taking of threatened, endangered, or candidate species if take is incidental to an otherwise lawful activity and if specific criteria are met. These provisions also require CDFW to coordinate consultations with USFWS for actions involving federally listed species that are also state- listed species. In certain circumstances, CESA allows CDFW to adopt a CESA incidental take authorization as satisfactory for CEQA purposes based on finding that the federal permit adequately protects the species and is consistent with state law.

On July 10, 2023, Senate Bill 147 (SB147) was signed into law and amends the Fish and Game Code to allow a 10 -year permitting mechanism for a defined set of projects within the renewable energy, transportation, and water infrastructure sectors. Currently, this project does not fall within those categories and therefore would not be authorized to take of “fully protected” species that are protected under the provisions of the California Endangered Species Act California Fish and Game Code.

California Fish and Game Code
Sections 3511 (Birds), 4700 (Mammals), 5050 (Reptiles and Amphibians), and 5515 (Fish) of the California Fish and Game Code provide that designated fully protected species may not be taken or possessed without a permit. Incidental take of these species is not authorized by law.

Pursuant to Section 3503.5 of the California Fish and Game Code, it is unlawful to take, possess, or destroy any birds of prey; or to take, possess, or destroy any nest or eggs of such birds. Birds of prey refer to species in the orders Falconiformes and Strigiformes.

Nests of all other birds (except English sparrow [ Passer domesticus] and European starling [Sturnus vulgaris]) are protected under Sections 3503 and 3513 of the California Fish and Game Code.

Pursuant to Section 1602 of the California Fish and Game Code, CDFW regulates all diversions, obstructions, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake that supports fish or wildlife. Diversion, obstruction, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake that supports fish or wildlife requires authorization from CDFW by means of entering into an agreement pursuant to Section 1602 of the California Fish and Game Code.

Porter-Cologne Water Quality Control Act
The Porter –Cologne Water Quality Control Act (Porter –Cologne Act) protects water quality and the beneficial uses of water. It applies to surface water and groundwater. Under this law, the State Water Resources Control Board (SWRCB) develops statewide water quality plans, and the Regional Water Quality Control Boards (RWQCBs) develop regional basin plans that identify beneficial uses, water quality objectives, and implementation plans. The RWQCBs have the primary responsibility to implement the provisions of statewide plans and basin plans. Waters regulated under the Porter – Cologne Act include isolated waters that are not regulated by USACE. RWQCBs regulate discharging waste, or proposing to discharge waste, within any region that could affect a “water of the state” (California Water Code, Section 13260[a]). Waters of the state are defined as “any surface water or

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groundwater, including saline waters, within the boundaries of the state” (California Water Code, Section 13050[e]). Developments with impacts on jurisdictional waters must demonstrate compliance with the goals of the Porter – Cologne Act by developing Stormwater Pollution Prevention Plans, Standard Urban Stormwater Mitigation Plans, and other measures to obtain a Clean Water Act Section 401 certification. If a Clean Water Act Section 404 permit is not required for a project, the RWQCB may still require a permit (i.e., Waste Discharge Requirement) for impacts to waters of the state under the Porter–Cologne Act.

California Environmental Quality Act
CEQA (California Public Resources Code Section 21000 et seq.) and the CEQA Guidelines (14 CCR 15000 et seq.) require identification of a project’s potentially significant impacts on biological resources and feasible mitigation measures and alternatives that could avoid or reduce significant impacts. CEQA Guidelines Section 15380(b)(1) defines endangered animals or plants as species or subspecies whose “survival and reproduction in the wild are in immediate jeopardy from one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, disease, or other factors” (14 CCR 15000 et seq.). A rare animal or plant is defined in CEQA Guidelines Section 15380(b)(2) as a species that, although not currently threatened with extinction, exists “in such small numbers throughout all or a significant portion of its range that it may become endangered if its environment worsens; or … [t]he species is likely to become endangered within the foreseeable future throughout all or a significant portion of its range and may be considered ‘threatened’ as that term is used in the federal Endangered Species Act.” Additionally, an animal or plant may be presumed to be endangered, rare, or threatened if it meets the criteria for listing, as defined further in CEQA Guidelines Section 15380(c). CEQA also requires identification of a project’s potentially significant impacts on riparian habitats (such as wetlands, bays, estuaries, and marshes) and other sensitive natural communities, including habitats occupied by endangered, rare, and threatened species.

California Native Plant Protection Act
The Native Plant Protection Act of 1977 (CFGC Sections 1900–1913) directed CDFW to carry out the legislature’s intent to “preserve, protect and enhance rare and endangered plants in this State.” The Native Plant Protection Act gave the Fish and Game Commission the power to designate native plants as “endangered” or “rare,” and prohibited take, with some exceptions, of endangered and rare plants. When CESA was amended in 1984, it expanded on the original Native Plant Protection Act, enhanced legal protection for plants, and created the categories of “threatened” and “endangered” species to parallel FESA. The 1984 amendments to CESA also made the exceptions to the take prohibition set forth in Section 1913 of the Native Plant Protection Act applicable to plant species listed as threatened or endangered under CESA. CESA categorized all rare animals as threatened species under CESA, but did not do so for rare plants, which resulted in three listing categories for plants in California: rare, threatened, and endangered. The Native Plant Protection Act remains part of the California Fish and Game Code, and mitigation measures for impacts to rare plants are specified in a formal agreement between CDFW and project proponents.

Natural Community Conservation Planning
CDFW's Natural Community Conservation Planning ( NCCP) program is an effort by the State of California, and numerous private and public partners, that takes a broad-based ecosystem approach to planning for the protection and perpetuation of biological diversity. An NCCP identifies and provides for the regional or areawide protection of plants, animals, and their habitats, while allowing compatible and appropriate economic activity.

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

The City of San Marcos began preparing a draft of the City Subarea Plan of the MHCP in December 1999 and although the City’s Draft Subarea Plan has not yet been approved by the USFWS and CDFW, the plan is a component of the adopted MHCP, and is currently being used as a guide for open space design and preservation within the City. The intent of the City’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as focused planning areas (FPAs), have been designated with parcel -level preserve goals which would contribute to achieving local and regional conser vation goals while minimizing adverse effects on property rights and property values.

The proposed project site is situated within an urbanized area, surrounded by existing residential and commercial developments, and does not act as a wildlife corridor. It is not designated as a Biological Core and Linkage Area or MHCP Focused Planning Area.

Local
San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of biological resources. The following goals and policies apply to the project:
• Goal COS -1: Identify, protect, and enhance significant ecological and biological resources within San Marcos and its adaptive Sphere of Influence. o Policy COS-1.1: Support the protection of biological resources through the establishment, restoration, and conservation of high quality habitat areas. o Policy COS-1.2: Ensure that new development, including Capital Improvement Projects, maintain the biotic habitat value of riparian areas, oak woodlands, habitat linkages, and other sensitive biological habitats.
• Goal COS-2: The City is committed to conserving, protecting, and maintaining open space, agricultural, and limited resources for future generations. By working with property owners, local organizations, and state and federal agencies, the City can limit th e conversion of resource lands to urban uses.
o Policy COS -2.1: Provide and protect open space areas throughout the City for its recreational, agricultural, safety, and environmental value. o Policy COS-2.2: Limit, to the extent feasible, the conversion of open space to urban uses and place a high priority on acquiring and preserving open space lands for recreation, habitat protection and enhancement, flood hazard management, water and agricult ural resources protection, and overall community benefit.

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

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

3.3.3 Thresholds of Significance
CEQA Guidelines define “significant effect on the environment” as a “substantial or potentially substantial adverse change in the environment.” CEQA Guidelines further indicate that there may be a significant effect on biological resources if the project would:
• Threshold #1: Have a substantial adverse effect either directly or through habitat modifications, on any species identified as a candidate, sensitive or special status species in local or regional plans, policies, or regulations or by the California Department of Fish a nd Wildlife or U.S. Fish and Wildlife Service.
• Threshold #2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? • Threshold #3: Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance.
• Threshold #4: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

As noted above, it was determined that there would be less than significant impacts related to state and federally protected wetlands, wildlife corridors and nursery sites. Section 5.3, Environmental Effects Found Not to be Significant – Biological Resources, of this EIR provides additional information on these topics. The Initial Study is included in Appendix B.1.

3.3.4 Project Impact Analysis
The proposed project is expected to permanently impact the entire project site through grading and development of the project . Figure 3.3 -1 illustrates the distribution of biological resources on the project site and the extent of the proposed impacts. Table 3.3-2 present the types and acreage of each vegetation community/land cover type within the project site. The project includes off -site water, wastewater, and stormwater infrastructure improvements as detailed in Chapter 2 Project Description.

These improvements would all be constructed within the existing right -of-way of Armorlite Drive. No biological resources impacts would occur as a result of these improvements. As a condition of project approval, the applicant/developer/property owner shall pay Public Facility Fees, a portion of which go towards City-wide habitat conservation efforts.

Threshold #1: Have a substantial adverse effect either directly or through habitat modifications, on any species identified as a candidate, sensitive or special status species in local or regional plans,

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policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Special - Status Plants Species and Critical Habitats
No rare or special -status plant species were observed within the project site during either of the focused rare plant surveys conducted in May 2023 and July 2023. The proposed project site does not support any special-status plant species, and none are con sidered as having a moderate or high potential to occur. There is critical habitat for both thread -leaved brodiaea and spreading navarretia designated near the project site. However, no critical habitat for either plant species was identified on the projec t site, nor were they observed during focused surveys for special -status plants. Thread- leaved brodiaea and spreading navarettia were determined to have low to no potential to occur.

Therefore, construction of the project would not result in significant impacts to any special-status plant species.

Special - Status Wildlife Species
No special-status wildlife was observed within the project site during the biological surveys conducted in 2022 and 2023. Based on a review of the potential species to occur within the region, habitat conditions identified within the project site, as well as results of general and focused surveys in 2022 and 2023, no special -status wildlife species have a moderate to high potential to occur within the project site. Focused surveys for the coastal California gnatcatcher ( Polioptila californica californica) (a federally listed threatened species and a CDFW Species of Special Concern) were conducted within the project site between October 2022 and February 2023.

California Gnatcatcher was not observed during these focused surveys. While coastal sage scrub vegetation on site is superficially suitable for California gnatcatcher, based on the overall habitat structure and the presence of primary constituent species such as California sagebrush, the available habitat patch on site is small, is substantially degraded by physical disturbances and non -native species, and lies in an urbanized setting isolated on all sides from larger, intact habitat areas. As such, this species is not expected to occur within the project site. Therefore, the proposed project would not result in direct or indirect impacts to any special-status wildlife species.

Nesting Birds
The project site contains habitat (disturbed Diegan coastal sage scrub, non -native grassland, and disturbed land), which could potentially provide opportunities for avian spec ies to nest on site. The proposed project has the potential to impact active bird nests nesting birds or other wildlife if vegetation. is removed or ground disturbing activities occur during the breeding and nesting season (typically February 1 to September 15). Impacts on nesting birds or other wildlife are prohibited by the MBTA and the California Fish and Game Code. Clearing, grubbing and construction activities, if conducted during the breeding and nesting season, could directly or indirectly impact spec ies protected under the MBTA. This represents a significant impact (Impact BIO -1) and mitigation is required.
• Impact BIO-1: There is p otential to impact avian species protected under the Migratory Bird Treaty Act and California Fish and Game Code 3503.5 and other wildlife if tree removal, vegetation removal, or other construction activities occur during the nesting season.

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Indirect Impacts
Indirect impacts are physical changes to the environment which are not immediately related to a project but may occur at some point in the future due to conditions introduced with implementation of the project. Indirect impacts during construction may incl ude dust, anthropogenic trash, and accidental transport of non -native plant species into the project site by vehicles, equipment, or foot traffic. Therefore, the project has the potential to result in significant indirect impacts to sensitive habitat (Impact BIO-2) and mitigation is required.
• Impact BIO-2 The proposed project has the potential to result in indirect impacts to sensitive species due to dust, trash, and accidental transport of non-native plant species into the project site, and invasive plant species, and noise and lighting effects.

Threshold #2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Sensitive Vegetation Communities
Table 3.3-3 presents the amount and type of vegetation community/land cover type that would be impacted by development of the proposed project. As shown in Table 3.3-3, and shown on Figure 3.3- 1, the entire 2.44- acre project site is expected to be permanently impacted. This would result in permanent impacts to 2.13 acres of Diegan coastal sage scrub, permanent impacts to 0.12 acres of non-native grassland-broadleaf dominated, and permanent impacts to 0.20 acre of disturbed lands.

Permanent impacts to the disturbed habitat totaling 0.20 acre would not be significant because this land cover is not considered sensitive, it is non -native, and provides little biological resource value.

Table 3.3-3 includes required mitigation ratios and acreage.

Table 3.3-3. Vegetation Community/Land Cover Impacts
Habitat
Group
Vegetation
Community/
Land Cover Type
Total
Onsite
(Acres)
Sensitive?
Project
Impact
(Acres)
Mitigation
Ratio
Required
Mitigation
(acres)
C Diegan Coastal Sage
Scrub 2.13 Yes 2.13 1:1 2.13
D
Non-Native
Grassland-Broadleaf
Dominated

0.12 Yes 0.12 0.5:1 0.06
F Disturbed Habitat 0.20 No N/A N/A 0
Total(1) 2.44 N/A 2.25 N/A 2.19
Source: Dudek 2025 2024.

Notes: (1) Numbers may not sum due to rounding
N/A = not applicable
Direct permanent impacts to Diegan coastal sage scrub and non-native grassland communities would be considered a significant impact (Impact BIO-3) and require mitigation. • Impact BIO-3 The proposed project would impact 2.13 acres of Diegan coastal sage scrub and 0.12 acres of non -native grassland-broadleaf dominated for a total of 2.25 acres of impact.

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Critical Habitats
As discussed in Threshold #1, critical habitat was identified for thread-leaved brodiaea and spreading navarretia in proximity to the project site. However, no critical habitat for either plant species was identified on the project site, nor were they observed during focused surveys for special-status plants.

Thread-leaved brodiaea and spreading navarettia were determined to have low to no potential to occur. Therefore, construction of the project w ould not result in significant impacts to thread -leaved brodiaea and spreading navarettia critical habitat.

San Diego Fairy Shrimp
San Diego fairy shrimp critical habitat designated in 2007 encompasses nearly the entire project site as well as a large portion of the existing Palomar Station development to the east and south. There is also San Diego fairy shrimp critical habitat designated within a vernal pool reference site southeast of the project site, as well as within two additional parcels west of South Las Posas Road, on opposite sides of Linda Vista Drive, within the one-mile vicinity of the project site, all designated in 2007.

In addition to the jurisdictional aquatic resource assessment that was conducted within the project site, site visits to check for the presence of surface water or ponding of at least 3 cm were conducted within 24 hours after each rain event (approximately 15 visits) during the 2022-2023 wet season.

Visits to a nearby reference site (within one mile of the project site) where vernal pools were present were also conducted. While some minor ponding was observed within the project site during visits within 24 hours after rainfall events, during none of the visits did ponding meet the 3 cm threshold that would trigger initiation of wet-season protocol surveys for San Diego fairy shrimp. By comparison, the rainfall was sufficient to establish inundation (pools gr eater than 3 cm deep) at the nearby reference site where known vernal pools have filled and remained inundated beyond the 24-hour post- rainfall assessment period ( Dudek 2025 2024). Therefore, observations show that the site is not suitable for ponding or fairy shrimp, and no significant impacts to San Diego fairy shrimp would occur (Dudek 2025 2024). Therefore, impacts would be less than significant.

Threshold #3: Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance.

Existing vegetation (disturbed habitat, coastal sage scrub, and non -native grassland) would be removed during project construction and new trees and landscaping would be planted. There is one existing pepper tree on the southwest corner of the project site that would be removed to prepare the site for development. General Plan Policy COS -2.6 requires that any removed trees be replaced at a 1:1 ratio. The proposed landscape plan includes 34 large parking lot trees, 10 medium site trees, 29 small accent trees and 7 pool area palm trees, which greatly exceeds the requirements of Policy COS-

2.6. Proposed tree species to be planted per the landscape plan include golden rain tree, Chinese pistache, fern pine, African sumac, Japanese zelkova, Chitalpa, Marina strawberry tree, gold medallion, Desert Museum palo verde, Brisbane Box, Swan Hill fruitless olive, Mexican palo verde, tree aloe, Eastern redbud, Western redbud, crape myrtle and in the pool area: King Plam and Queen Palm. The landscape plan is included as App endix A.3. The project’s consistency with applicable General Plan goals and policies is discussed in Section 3. 7, Land Use and Planning. As s hown in Table 3.7 -7, the project is consistent with the applicable goals and policies . Therefore, the project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Impacts would be
less than significant.

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Threshold # 4: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

The project is not located within a designated Biological Core Linkage Area or Focused Planning Area of the MHCP and therefore, it is consistent with the conservation policies of the Draft San Marcos Subarea Plan. The MHCP organizes vegetation into habitat group types: Wetland Communities, Rare Upland, Coastal Sage Scrub, Chaparral, Annual Grassland, and Other (SANDAG 2003). As discussed in Threshold #2, the project would impact 2.13 acres of Diegan coastal sage scrub (Habitat Group C) and 0.06 acres of non -native grassland – broadleaf dominated (Habitat Group D), which were identified in Impact BIO-2 and Impact BIO -3. Mitigation measures (MM -BIO-2 and MM -BIO-3) have been identified which would reduce potentially significant biological resource impacts to below a level of significance. With Therefore the project would be found in conformance with the MHCP and would not conflict with an adopted Habitat Conservation Plan, NCCP, or other habitat conservation plans. A less than significant impact is identified, and no mitigation is required.

3.3.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future projects producing related impacts; or (2) a summary of projects contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For the purpose of assessing the proposed project’s cumulative impact with respect to biological resources the cumulative analysis is based upon a list approach. All of the cumulative projects within the city identified in Table 2 -3 are considered in this cumulative analysis.

The biological cumulative impact analysis focuses on those projects that would have a similar type of biological resource impact as the proposed project. The project has the potential to impact nesting birds protected under the MBTA as well as sensitive habitat (Diegan coastal sage scrub and non-native grassland-broadleaf dominated).

The cumulative projects which remove trees or vegetation during the nesting season could also have the potential for impacts to species protected under the MBTA. These impacts are avoided through restrictions on construction timing, or the performance of p re-construction surveys to ensure that nesting birds would not be impacted. This is similar to the mitigation identified for the proposed project and would ensure that cumulative impacts are less than significant. The cumulative projects which remove Diega n coastal sage scrub, non -native grassland-broadleaf dominated , or other sensitive habitat would be required to mitigate their impacts at a ratio consistent with the MHCP and the City’s Draft Subarea Plan. This is similar to the mitigation identified for the proposed project and would ensure that cumulative impacts are
less than significant.

3.3.6 Mitigation Measures
Implementation of the following mitigation measure would be required as a condition of project approval:

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Nesting Birds or Other Wildlife (Impact BIO-1)
MM-BIO-1a Breeding Season Avoidance. To the extent feasible, the applicant/developer shall only remove vegetation The removal of coastal sage scrub from the project impact footprint shall only occur from between September 1 through February 14 to avoid the bird breeding season. Further, to the maximum extent practicable, grading activities associated with construction of the project shall occur September 1 through February 14 to avoid the breeding season. If proje ct construction must occur during the breeding season, mitigation measure MM -BIO-1b shall be implemented.

MM-BIO-1b Nesting Bird Survey(s). Take of birds protected under the Migratory Bird Treaty Act and California Fish and Game Code shall be avoided during the nesting season. To avoid any direct impacts on raptors and/or any migratory birds protected under the Migratory Bird Treaty Act and California Fish and Game Code, removal of habitat that supports active nests on the proposed area of disturbance shall occur outside of the nesting season for these species (February 15 through August 31, annually).

If construction occurs during the nesting season, pre -construction nesting bird surveys must be conducted within 72 hours of construction -related activities. If nesting birds are detected by the biologist, the following buffers shall be established: (1) no work within 300 feet of a non-listed nesting migratory bird nest, and (2) no work within 500 feet of a listed bird or raptor nest. However, the biologist may reduce these buffer widths depending on site -specific conditions (e.g., the width and type of screening vegetation between the nest and proposed activity) or the existing ambient level of activity (e.g., existing level of human activity within the buffer distance) in conjunction with consultation with the City of San Marcos. If construction must take place within the recommended buffer width s above, the project applicant shall contact the City of San Marcos and wildlife agencies (United States Fish and Wildlife Service [USFWS] and California Department of Fish and Wildlife [CDFW] to determine the appropriate buffer.

Additionally, take of a state candidate species is prohibited under the California Endangered Special Act ( CESA). While Crotch’s bumble bee has low potential to occur on site, the pre -construction surveys for Crotch’s bumble bee shall be conducted within the construction footprint prior to the start of ground -disturbing activities occurring during the Crotch’s bumbl e bee nesting period (February 1 through October 31). The survey shall ensure that no nests for Crotch’s bumble bee are located within the const ruction area. The pre -construction survey shall include focused surveys, which shall be based on recommendations described in the Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species, released by CDFW on June 6, 2023, or the most current version at the time of construction.

The surveys shall be performed by a biologist with expertise in surveying for bumble bees and include at least three (3) survey passes that are not on sequential days or in the same week, preferably spaced two ( 2) to four (4) weeks apart. Surveys may occur between 1 hour after sunrise and 2 hours before sunset. Surveys shall not be conducted during wet conditions (e.g., foggy, raining, or drizzling), and surveyors shall wait at least one (1) hour following rain. Optimal surveys are when there are sunny to partly sunny skies and a temperature greater than 60°F.

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Surveys may be conducted earlier if other bees or butterflies are flying. Surveys shall not be conducted when it is windy (i.e., sustained winds greater than 8 miles per hour). Within non-developed habitats, the biologist shall look for nest resources suitable for bumble bee use. Ensuring that all nest resources receive 100% visual coverage, the biologist shall watch the nest resources for up to five (5) minutes, looking for exiting or entering worker bumble bees. Worker bees should arrive and exit an active nest site with frequency, such that their presence would be apparent after five (5) minutes of observation. If a bumble bee worker is detected, then a representative shall be identified to species. Biologists should be able to view several burrows at one time to sufficiently determine if bees are entering/exiting them, depending on their proximity to one (1) another. It is up to the discretion of the biologist regarding the actual survey viewshed limits from the chosen vantage point to determine which would provide 100% visual coverage; this could include a 30- to 50 -foot-wide area. If a nest is suspected, the surveyor can block the entrance of the possible nest with a sterile vial or jar until nest activity is confirmed (no longer than 30 minutes).

Identification shall include trained biologists netting/capturing the representative bumble bee in appropriate insect nets, per the protocol in U.S. National Protocol Framework for the Inventory and Monitoring of Bees. The bee shall be placed in a clear container for observation and photographic documentation, if able. The bee shall be photographed using a macro lens from various angles to ensure recordation of key identifying characteristics. If bumble bee -identifying characteristics cannot be adequately captured in the container due to movement, the container shall be placed in a cooler with ice until the bumble bee becomes inactive (generally within 15 minutes). Once inert, the bumble bee shall be removed from the container and placed on a white sheet of paper or card for examination and photographic documentation. The bumble bee shall be released into the same area from which it was captured upon completion of identification.

Based on implementation of this method on a variety of other bumble bee species, they become active shortly after removal from the cold environment, so photography must be performed quickly.

If Crotch’s bumble bee nests are not detected, no further mitigation is required.

The mere presence of foraging Crotch’s bumble bees shall not require implementation of additional mitigation measures because they can forage up to 10 kilometers from their nests. If nest resources occupied by Crotch’s bumble bee are detected within the project construction area, no construction activities shall occur within 100 feet of the nest, or as determined by a qualified biologist through evaluation of topographic features or distribution of floral resources. The nest resources shall be avoided for the dur ation of the Crotch’s bumble bee nesting period (February 1 through October 31). Outside of the nesting season, it is assumed that no live individuals would be present within the nest because the daughter queens (gynes) usually leave by September, and all other individuals (original queen, workers, males) die. The gyne is highly mobile and can independently disperse to outside of the construction footprint to surrounding open space areas that support suitable hibernacula resources.

A written survey report shall be submitted to the City Planning Division Director within 30 days of the last survey pass. The report shall include survey methods,

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weather conditions, and survey results, including a list of insect species observed and a figure showing the locations of any Crotch’s bumble bee nest sites or individuals observed. The survey report shall include the qualifications/resumes of the surveyor(s) and approved biologist(s) for identification of photo vouchers and a detailed habitat assessment. If Crotch’s bumble bee nests are observed, the survey report shall also include recommendations for avoidance, and the location information shall be submitted to the California Natural Diversity Database at the time of, or prior to, submittal of the survey report.

If Crotch’s bumble bee is detected within the project site, the applicant/developer shall consult with CDFW regarding the need to obtain an Incidental Take Permit.

Any measures determined to be necessary through the Incidental Take Permit process to offset impacts to Crotch’s bumble bee may supersede measures provided in this document.

In the event that an Incidental Take Permit is needed, mitigation for direct impacts to Crotch’s bumble bee shall be fulfilled through compensatory mitigation at a minimum 1:1 nesting habitat replacement of equal or better functions and values to those imp acted by the project, or as otherwise determined through the Incidental Take Permit process. Mitigation shall be accomplished through on -site preservation of suitable habitat and/or in accordance with CDFW guidance for off- site locations. The funding sourc e shall be in the form of an endowment to help the qualified natural lands management entity that is ultimately selected to hold the conservation easement(s). The endowment amount shall be established following the completion of a project-specific Property Analysis Record to calculate the costs of in -perpetuity land management. The Property Analysis Record shall take into account all management activities required in the Incidental Take Permit to fulfill the requirements of the conservation easement.

Indirect Impacts to Sensitive Wildlife Species (Impact BIO-2) MM-BIO-2a Construction Best Management Practices. The project applicant shall ensure that the following conditions are implemented during project construction to minimize potential environmental impacts due to project implementation:

1. Impacts from fugitive dust shall be avoided and minimized through watering and other appropriate measures consistent with the Construction General Permit Order 2009-009-DWQ.

2. Employees shall strictly limit their activities, vehicles, equipment, and construction materials to the project site.

3. To avoid attracting predators, the project site shall be kept clean of debris. All food-related trash items shall be enclosed in sealed containers and regularly removed from the site.

4. Pets of project personnel shall not be allowed on the project site.

MM-BIO-2b Landscaping. The applicant shall ensure that development landscaping habitat does not include exotic plant species that may be invasive to native habitats in the region. Exotic plant species not to be used include any species listed on the

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California Invasive Plant Council’s “Invasive Plant Inventory” List. In addition, landscaping should not use plants that require intensive irrigation, fertilizers, or pesticides.

MM-BIO-2c Biological Monitor Requirements and Duties. A qualified biologist shall be on site per the discretion of the City during initial clearing/grubbing and during grading to ensure compliance with all project -imposed mitigation measures. The biologist shall be available during pre -construction and constr uction phases to review grading plans, address protection of potential biological resources, monitor ongoing work, and maintain communications with the project’s engineer to ensure that any issues are appropriately and lawfully managed.

The qualified biological monitor shall also be responsible for the following duties:

1. Periodically monitor the work area to ensure that work activities do not generate excessive amounts of dust.

2. Halt work, if necessary, and confer with the USFWS, CDFW, U.S. Fish and Wildlife Service, and City of San Marcos to ensure the proper implementation of species and habitat protection measures. The biologist shall report any violation to USFWS and the City within 24 hours of its occurrence.

3. Submit a final report to the City within 60 days of p roject completion that includes the following:(1) as -built construction drawings for grading with an overlay of any active nests; (2) photographs of habitat areas during pre - construction and post-construction conditions; and (3) other relevant summary information documenting that authorized impacts were not exceeded and that general compliance with the avoidance/minimization provisions were achieved.

Direct Impacts to Sensitive Vegetation Communities (Impact BIO-3) MM-BIO-3 Off-Site Mitigation: The permanent loss of 2.13 acres of Diegan Coastal Sage Scrub will be mitigated at a minimum 1:1 ratio and the permanent loss of 0.12 acres of non-native grassland will be mitigated at a minimum 0.5:1 ratio. The amount of mitigation acreage required for non -native grassland may be reduced if up-tiered (i.e., coastal sage scrub) habitat is available for purchase.

Section 5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on-site mitigation, off-site acquisition, in-lieu fees, and mitigation credits. Since on-site mitigation is not an option due to the project design, the impacted 2.13 acres of Diegan coastal sage scrub and 0.06 acres of non-native grassland will be mitigated by the project applicant through off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City’s Planning Division Director and wildlife agencies prior to issuance of the grading permit.

3.3.7 Conclusion
Based on the presence of suitable avian nesting habitat, pre -construction clearance surveys for nesting birds will would be conducted to ensure that no impacts on nesting birds that are afforded

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protection under the MBTA or the Fish and Game Code occur (see mitigation measures MM -BIO-1a and MM-BIO-1b). Mitigation measures MM-BIO-1a and MM-BIO-1b require a preconstruction survey if construction is proposed during the nesting season. If nesting birds are found, avoidance measures would be implemented to minimize impacts. With the implementation of mitigation measures MM-BIO- 1a and MM-BIO-1b, direct impacts on nesting birds would be less than significant.

Indirect impacts during construction may include dust, anthropogenic trash, and accidental transport of non-native plant species into the project site by vehicles, equipment, or foot traffic. Implementation of mitigation measures MM-BIO-2a, which includes industry -standard best management practices (BMPs), including dust control, good housekeeping procedures, and measures to protect the site from establishment of invasive species would be required for the project to obtain a grading permit.

Implementation of these measures during construction, including consistency with the Construction General Permit Order 2009-009- DWQ, would reduce any potential short -term indirect impacts to a level that is less than significant. In addition, the implementation of mitigation measure MM-BIO-2b, would ensure that the proposed project’s landscaping plan does not include exotic plant species that may be invasive and/or harmful to native habitats in the region, as well as prohibit the use of plants that require intensive irrigation, fertilizers, or pesticides. Implementation of mitigation measures MM- BIO-2c will ensure compliance with all p roject-imposed mitigation measures with the presence of a biological monitor on site.

Direct permanent impacts to Diegan coastal sage scrub and non-native grassland communities would be significant and require mitigation. The proposed project would result in the purchase of 2.19 acres of sensitive upland vegetation communities ( mitigation measure MM-BIO-3). Implementation of mitigation measure MM-BIO-3 would provide for the required 1:1 mitigation ratio for impacts to coastal sage scrub and 0.5:1 mitigation ratio for non-native grassland.

All other biological resources impacts were determined to be less than significant.

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Figure 3.3-1. Vegetation Communities and Land Cover Types

Source: Dudek 2025 2024.

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Figure 3.3-2. Proposed Impacts to Vegetation Communities and Land Cover Types

Source: Dudek 2025 2024.

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3.4 Cultural Resources
Introduction
This section identifies the cultural resources on the project site and analyzes the potential impacts of the proposed project on cultural resources. Cultural resources considered in this analysis include archaeological ( precontact Native American [ prehistoric] and non -Native American historic -era) resources, historical resources, unique archaeological resources, and human remains. Tribal Cultural Resources are analyzed separately in Section 3.12 of the Environmental Impact Report (EIR). 6 The analysis in this section is based upon the following report prepared by ASM Affiliates:
• Archaeological Survey Report for Armorlite Lofts Project, San Marcos, CA prepared by ASM Affiliates (July 2024).

Due to the confidential nature of the archaeological report, it is not included as a technical appendix to the EIR. The archaeological resources inventory report included a record search, literature review, correspondence with Native American contacts, and field survey. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s web site.7
Table 3.4-1 summarizes the project- and cumulative-level cultural resources impacts, by threshold.

Table 3.4-1. Cultural Resources Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
#1 – Cause substantial adverse change
in the significance of a historical resource
as defined in Section 15064.5
Significant Impact Less than
Significant
Less Than
Significant With
Mitigation
#2 – Cause a substantial adverse change
in the significance of an archaeological
resource pursuant to Section 15064.5.

Significant Impact Less than
Significant
Less Than
Significant With
Mitigation
#3 – Disturb any human remains,
including those interred outside of
dedicated cemeteries.

Significant Impact Less than
Significant
Less Than
Significant With
Mitigation

3.4.1 Existing Conditions
This section provides information on the natural setting, archeological context, and ethnographic context of the project site. It also provides information on the outreach and consultation efforts with local Tribes, as required by existing regulations and the results of the site visit.

6 Full references for documents cited in this section are included in Chapter 7, References, of this EIR. 7 http://www.san-marcos.net/work/economic-development/general-plan

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Natural Setting
The project site lies on the coastal plain of San Diego County in the Coastal Province and western Peninsular Range Province. The coastal strip has a 130 kilometer (km) long shoreline and is comprised of raised Pleistocene marine and non-marine terraces ranging from 20 to 5 km in width. Cretaceous, Tertiary, and Quaternary marine and non -marine sedimentary deposits define these terraces, which have been extensively modified by erosion (ASM 2024).

Drainages of varied catchment size are closely spaced along the coast, and lagoons have formed at the mouths of many of these rivers. The southern third of the San Diego County coastline is dominated by Tijuana Lagoon, San Diego Bay, and Mission Bay, while the central portion includes six main drainages, mostly with small catchments and associated lagoons. The northern third of the county's coastline extends from the San Luis Rey River to San Mateo Creek and encompasses Marine Corps Base Camp Pendleton and three of the county's four largest drainage catchments. The San Marcos area is part of the central coastal plain.

The coastal plain is characterized by a Mediterranean semiarid steppe climate (Bowman 1973; Hines 1991:4). Precipitation ranges from 225 to 400 millimeters (mm) per year and is concentrated in the winter (from December to April). The prominent vegetation throughout the coastal plain area is coastal sage scrub (Munz 1974), and important associated species include buckwheat, black sage, white sage, sugar bush, squaw bush, and laurel sumac. In the valley floors, freshwater marsh species include cattail, spike-rush, and bulrush, while common salt marsh plants include pickleweed, salt grass , and sea lavender. Willow, cottonwood, and sycamore trees are common in valley floor riparian habitats.

Site-Specific Natural Setting
The project site is generally flat. Elevations range from 575 above meal sea level (amsl) in the central knoll on the site to approximately 562 feet amsl along Armorlite Drive. Based upon the biological resources study prepared for the project (Dudek 2025 2024), the project site contains Diegan coastal sage scrub, non-native grassland, and disturbed habitat. Rare plant surveys were conducted in 2023 and no rare plants were observed on the project site.

Archaeological Context
Archaeological fieldwork along the southern California coast has yielded a diverse range of human occupation extending from the terminal Pleistocene into the Ethnohistoric period. A variety of different regional chronologies, often with overlapping terminology, have been used in coastal southern California, and they vary from region to region. Today, the prehistory of San Diego County is generally divided into three major temporal p eriods: Paleoindian, Archaic, and Late Prehistoric. These time periods are characterized by patterns in material culture that are thought to represent distinct regional trends in the economic and social organization of prehistoric groups.

Paleoindian Period
The antiquity of human occupation in the New World has been the subject of considerable debate over the last few decades. A widely accepted model is that humans first entered the western hemisphere between 12,000 and 15,000 years B.P. While there is no firm evidence of human occupation in coastal southern California prior to 12,000 B.P., dates as early as 23,000 B.P. and even 48,000 B.P. have been reported. The amino acid racemization technique used to date these sites has been largely discredited, however, by more recent accelerator radiocarbon dating of early human remains along

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the California coast . Despite intense interest and a long history of research, no widely accepted evidence of human occupation of North America dating prior to 15,000 B.P. has emerged (ASM 2024).

The Paleoindian period begins with Clovis occupation, a widespread phenomena in North America.

Noted for its distinctive tool kit characterized by fluted points, Clovis occupation dates to the end of the Pleistocene, from 11,200 B.P. to 10,600 B.P. The Pal eoindian period in San Diego County is considered to date to the terminal Pleistocene and the early Holocene, from at least 10,000 B.P. to 8500/7500 B.P. Although no Clovis sites are documented in the region, occasional isolated fluted points have been recovered. A variety of terms have been proposed for Paleoindian assemblages in the southern California region. Rogers, the first to temporally order the archaeological assemblages of the region, introduced and later discarded the terms Scraper-Makers, Malpais and Playa to label early lithic industries of the region . Rogers then coined the term San Dieguito, still widely used today, to refer to the earliest artifact assemblages in San Diego County. San Dieguito assemblages are composed almost entirely of flake d stone tools, including scrapers, choppers, and large projectile points. Until recently, the near absence of milling tools in San Dieguito sites was viewed as the major difference between Paleoindian economies and the lifeways which characterized the later Archaic period (ASM 2024).

The terminal Pleistocene San Dieguito adaptation occurred within a climatic period of somewhat cooler and moister conditions than exist presently. The range of possible San Dieguito economic adaptations and the interpretation of the San Dieguito complex as a big game hunting tradition are based primarily on materials from the Harris Site . Subsequently, it was hypothesized that differences between San Dieguito and the subsequent La Jolla artifact assemblages may reflect functional differences rather than temporal or cultural variability (ASM 2024).

Archaic Period
The Archaic period (similar to the Encinitas tradition and the Millingstone horizon) began between 9,000 and 8,500 years ago and ended between 1,300 and 800 years ago. A distinction is often made between coastal shell midden sites (La Jolla complex) and inland non -shell midden sites (Pauma complex). Shell middens are generally characterized by flaked cobble tools, basin metates, manos, discoids, and flexed burials. Three temporal phases have been distinguished within the Archaic period (ASM 2024).

Initial Archaic exploitation of the San Diego area littoral zone is generally considered to have entailed sizable semisedentary populations focused around resource -rich bays and estuaries . Shellfish were interpreted as a dietary staple; plant resources (both nuts and grasses) were also an important dietary component, while hunting and fishing were less important. This adaptive strategy remained largely unchanged for several thousand years. The La Jolla Complex reached its population and cultural climax between 7000 and 4000 years ago when there was a plentiful supply of shellfish in the lagoons along the coast. Major changes in human adaptations occurred after 4,000 years ago when estuarine silting was considered to have become so extensive as to cause a decline in associated shellfish populations.

A major depopulation of the coastal zone has been postulated, wit h settlements shifting inland to a river valley orientation, intensifying exploitation of terrestrial small game and plant resources, possibly including acorns . The coast was abandoned or only seasonally occupied, with a possible slight increase in coastal occupation after 1,600-1,200 years ago (ASM 2024).

Late Prehistoric Period
The Late Prehistoric period is generally considered to have begun between 1,300 and 800 years ago or the equivalent of between A.D. 700 and 1250. Local regional cultural complexes have been

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distinguished between the northern area (San Luis Rey complex), southern coastal area (Yuman complex), and the southern inland area (Cuyamacha complex). In general, this period was characterized by the appearance of small pressure -flaked arrow points (Cott onwood Triangular and Desert Side-notched points) indicative of bow and arrow technology, the appearance of ceramics, the replacement of flexed inhumations with cremations, the possible appearance of the mortar and pestle, and an emphasis on inland plant f ood collecting and processing, especially of acorns . The precise timing of the introduction of these items is still debated due to the poor chronological resolution and bioturbation at multicomponent sites . In addition, recent research is revealing the persistence of inhumations throughout most of the late Holocene in northern coastal San Diego (ASM 2024).

Explanations for the origin of the Late Prehistoric period vary. Kroeber speculated that Uto -Aztecan- language speakers migrated from the deserts to the southern coast of California at least 1,000-1,500 years ago. Some archaeologists have embraced this hypo thesis and correlated it with the origins of the Late Prehistoric period. Rogers initially discussed the Luiseño and Kumeyaay under the rubric of the Mission Indians, and distinguished them from earlier shell -midden and scraper -maker cultures.

Rogers later argued for continuity in occupation from the Archaic to the Late Prehistoric period, and distinguished three phases of shell middens. He argued that the Kumeyaay culture of 500 years ago was the result of earlier migration of Yuman populations from the coast to the Colorado River (perhaps as the result of an influx of Shoshone populations in northern San Diego County), adaptation to this new riverine setting and adopting traits from adjacent populations in the Southwest, and subsequent movement back to the coast at the onset of the Late Prehistoric period. Subsequently, scholars have emphasized several cultural processes to explain Late Prehistoric cultural developments including: a chronological gap, cultural continuity and the addition of new traits, a population replacement or that several factors were at play (ASM 2024).

The San Luis Rey complex in the northern inland area was generally applied to the north coast region.

It has been suggested the San Luis Rey I phase began around A.D. 1400 and included small triangular arrow points, manos, portable metates, mortars, pestles, Olivella beads, and stone pendants. The San Luis Rey II phase differed only in the addition of ceramics and pictographs around A.D. 1750. It was further hypothesized that the lower portions of the San Luis Rey drainage had sedentary villages with limited use of marine resources. The Late Prehistoric period has been paradigmatically linked with the subsequent ethnohistoric record, and direct historical analogies assume considerable adaptive stability for populations, linguistic groups, and their territori al extent as documented by Europeans (ASM 2024).

Ethnohistorical Context
The Post-Contact period began in A.D. 1769 with the Spanish establishment of the Mission San Diego de Alcalá. Yet Spanish explorers first encountered Native Americans in the San Diego area in A.D. 1542 when Cabrillo landed at Point Loma along San Diego Bay , and local inhabitants would have been negatively affected by protohistoric transmission of diseases via sea visits and through contact with Native Americans in the Baja California regio n. Portolá’s A.D. 1769 expedition from San Diego to Monterey documented a series of Native American coastal villages in the San Diego area, typically situated along the region's major drainages . The subsequent establishment of the San Juan Capistrano Mission in 1776 and the San Luis Rey de Francia Mission in 1798 further impacted traditional coastal settlement systems. Acculturation, assimilation, and the introduction of Old World diseases greatly disrupted and reduced Native American populations, and by the early 1800s traditional coastal villages were largely abandoned . As a result, we know very little about traditional coastal life, except what can be gleaned from mission records. Nineteenth and twentieth -century ethnohistoric reconstructions provide only minimal insight into coastal adaptations – particularly with

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respect to such issues as cultural complexity, population densities, and regional interaction – and are built from the perspective of remnant inland populations and their occasional seasonal exploitation of a littoral zone dominated and largely controlled by European settlers (ASM 2024).

From north to south, coastal San Diego was occupied by the Juaneño, Luiseño, and Kumeyaay Native American groups. The Juaneño and Luiseño are Uto-Aztecan speakers whose territory ranged from Agua Hedionda Lagoon (or possibly Batiquitos Lagoon) in the south to Aliso Creek in Orange County, to near Santiago Peak in the northeast, and to the Palomar Mountain area in the southeast. They are linguistically and culturally related to the Gabrielino and the Cahuilla. The terms Juaneño and Luiseño are derived from a ssociation with the San Juan Capistrano and San Luis Rey missions respectively, along the coast (ASM 2024).

During this period, the Luiseño people had a fairly rigid social structure and a moderately high population density. Maximum population estimates at Spanish contact range from 5,000 to 10,000 .

With a territory extending for almost 4,000 square kilometers ( km²), maximum population density estimates range from 1.25 to 2.5 persons per km² . It is estimated that the Luiseño included approximately 50 villages of 200 individuals each, while others, using Portolá expedition observations, indicated that village size was closer to 60. Recent research with mission records suggests that village size varied significantly in the eighteenth century, with larger villages such as Topome along the Santa Margarita River consisting of multiple clans (ASM 2024).

The Luiseño are divided into several autonomous lineages or kin groups based on patrilineal descent groups and a patrilocal residential pattern. Each Luiseño lineage is based around an autonomous village that held collective ownership over a well- defined territory for hunting and gathering, and violations of trespass were punished. Village territories may have ranged from as little as 10 km² near the coast along major drainages such as the San Luis Rey River to as much as 100 km² elsewhere. A variety of sho rter-term residential camps (such as for acorn gathering) and specialized localities occurred within each village territory. There are varied estimates for the length of the annual stay at the main village, and it has been suggested a bipolar pattern with two permanent base camps, one in a major valley and another in the mountain region (ASM 2024).

Notably, strong differences in social status, ascribed leadership roles, and elaborate ritual paraphernalia existed. Leadership include s hereditary chiefs and council members who ha ve specialized knowledge and authority over specific religious, economic, and warfare issues. Leaders conduct elaborate ceremonies; ritual and ceremonial specialists maintained ceremonial knowledge in secrecy and passed on the knowledge to only one heir . These leaders and specialists made use of fenced-in ceremonial structures, located in the village center (ASM 2024).

Economic activities t ake place on the community and the extended household level, and varied significantly between coastal and inland areas. Community-wide efforts included fire management for game drives, and systematic use of fire to facilitate grasslands and increase yields of key plants and animals. Such burning was regularly mentioned in early Spanish accounts. Acorns, gathered in upland areas, have been considered the most important food source. Seeds from grasses, manzanita, sage, sunflowers, lemonade berry, chia, and other plants were also used, along with various wild greens and fruits. Deer, antelope, small game, and birds were exploited. Coastal marine animals utilized as food included sea mammals, fish, crustaceans, and mollusks. Near-shore fishing was done from light balsa reed or dugout canoes. Some accounts indicate that coastal communities exploited local shellfish in the winter and during times of stress the interior Luiseño traveled to the coast to obtain shellfish, fish, and even some land mammals. It has been noted that most inland groups also had fishing and

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gathering locations on the coast which they visited annually when the tides were low or when the inland resources were scarce, typically from January through March (ASM 2024).

Rigid gender division of labor did not exist, but women generally collected plant resources and men hunted. Houses were dispersed throughout villages. Lowland village houses were conical structures covered with tule bundles, and other structures included sweathouses, ceremonial enclosures, ramadas, and acorn granaries. Domestic implements included wooden utensi ls, baskets, ceramic cooking and storage vessels, and milling tools. Hunting implements included bow and arrow, curved throwing sticks, nets, and snares. Nets and hooks made of shell and bone were used for fishing (ASM 2024).

Project-Specific Ethnohistoric Context
Villages were often located in sheltered areas in valley bottoms, along streams, or along coastal strands near mountain ranges. Along with being located near water sources, keeping in mind that modern development has drastically changed the presence and frequency of water sources. While no placenames or villages were identified as being directly associated with the project site there are several in the larger vicinity of the project site (Oxendine 1983). Many place names have multiple possible spellings and meanings derived from different sources. Nearby place names include Panakara and Mehel-om-pom-pauvo to the south and multiple habitation areas along the San Luis Rey River watershed to the north including Wiasamai, Wagauma, Kwalam and Tomkav (ASM 2024).

In addition to placenames there are several habitation areas in the larger vicinity of the project site.

SDI-5633 was identified as a habitation or specialized area. A data recovery at SDI -5633 placed the occupation of the site circa A.D. 1170 to A.D. 1690 . The site also contains evidence of an earlier occupation, likely during the Archaic Period, based on the presence of large milling tools and Coso obsidian. It was identified as a habitation area used primarily for hunting and for projectile point production and milling of plant seeds. W-1556 / SDI-5641, located nearly one mile east of the project site, is recorded as a habitation site consisting of an artifact laden midden soil overlooking the San Marcos Valley flood plain. The site contained an extensive artifact deposit with hearths, milling features, and human remains. SDI -11068A/B, located more than two miles northeast of the project site, contained large amount of shell fragments and fish bone, bedrock milling features, also contains a high number of ceramics and ceramic types, bow pipes, effigies and a wide variety of milling implements (ASM 2024).

Other major habitation areas within the region include SDI -9822 located more than four miles northeast of the project site included a red pictograph that also contained pecking. SDI -12,209, located nearly five miles to the southeast contains a habitation a rea with significant subsurface deposits and a rock art panel, showing this habitation area was an important location (ASM 2024).

Historical Context
Although the earliest historical exploration of the San Diego area can be traced to 1542 with the arrival of the first Europeans, particularly the exploration of San Miguel Bay by Juan Rodriguez Cabrillo, the widely accepted start of the historical period is 1769 with the founding of the joint Mission San Diego de Alcalá and Royal Presidio. On July 20, 1769, Father Juan Crespí arrived in the San Luis Rey River Valley with the Portolá expedition to Monterey. His report back to his superiors declaring it an i deal location for a mission led to the eventual founding of Mission San Luis Rey de Francia, the eighteenth California mission. The mission was formally dedicated June 13, 1798. Named for King Louis IX of France, this mission became known as the ‘King of Missions’ due to its size and success. At its height, San Luis Rey became one of the most populous and successful of the missions. In 1824, it had an

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Indian neophyte population of 3,000, and the extensive mission lands supported 1,500 horses, 2,800 sheep and 22,000 cattle (ASM 2024).

Mexico won independence from Spain in 1821, and, with it, the process of dismantling of the mission system began to unfold. The 1833 Secularization Act passed by the Mexican Congress ordered half of all mission lands to be transferred to the Indians and th e other half to remain in trust and managed by an appointed administrator. These orders were never implemented because of several factors that conspired to prevent the Indians from regaining their patrimony. By 1835, the missions, including Mission San Luis Rey, were secularized. The remaining lands of San Luis Rey were sold in 1846 to José Cota and José A. Pico by Pío Pico, Governor of California, and the Luiseño converts who had lived around the mission were removed to nearby Pala (ASM 2024).

Before secularization of the missions, San Marcos was one of the cattle -grazing tracts claimed by Mission San Luis Rey. During the 1840s, when many land grants or ranchos were issued, Governor Juan Bautista Alvarado granted the 8,877-acre Rancho Los Vallecitos de San Marcos (the Little Valleys of St. Mark) to Don José María Alvarado in 1840. Don José married Lugarda Osuna, daughter of the owner of San Dieguito Rancho, Don Juan María Osuna (ASM 2024).

In 1846, shortly after the Battle of San Pasqual, Don José and ten other rancheros were captured and taken to a ranchería at Agua Caliente where they were slain. Lugarda later married Luis Machado, the owner of Rancho Buena Vista. It is unclear who owned Rancho Los Vallecitos de San Marcos in the years following her marriage, but, in 1851, Lorenzo Soto filed a claim for the rancho with the newly established United States Land Commission. Soto officially acquired the 8875.83 acres on March 1, 1883. Cave J. Couts, a former Army officer and owner of the adjacent Rancho Guajome and Buena Vista, later came into possession of the ranch (ASM 2024).

The transcontinental railroad was completed in November 1885, resulting in an unprecedented real estate boom for San Diego City and the surrounding County. The population of San Diego soared in the mid-1880s from a total population of 5,000 in 1885 to 40,000 in 1889. Settlers poured into San Diego, lured by real estate promotions offering a salubrious climate, cheap land, and the potential to realize great profits in agriculture and real estate. Speculators formed land companies and subdivided townsites throughout the county. The real estate boom also stimulated demand for agricultural land in the county, and the number of farms increased from 696 to 2,747 between 1880 and 1890. This boom brought homesteaders to the San Marcos area. San Marcos was typical of the small agricultural communities that grew up in the hinterland of San Diego, characterized generally by widely dispersed settlements that were united by a common school district, post office, church, and general store (ASM 2024).

Major Gustavus French Merriam, from Topeka, Kansas, made the first permanent American settlement in the San Marcos area. Merriam homesteaded 160 acres in the north Twin Oaks Valley and began wine and honey production. German and Dutch immigrants began moving into the area in the early 1880s. In 1883, a few miles south of the settlement, John H. Barham founded the first town in the area, calling it Barham. By 1884, the town of Barham had a post office, blacksmith, feed store, and a weekly newspaper . William Webster Borden published the town’s first newspaper called Our Paper and later The Plain Truth (ASM 2024).

In 1887, Cave Couts’s widow sold San Marcos Ranch to O. S. Hubbell, and he sold it to the San Marcos Land Company headed by Jacob Gruendike, a San Diego Banker, and his associate W. G. Jacobs. The San Marcos Land Company had been formed with the intention of developing a townsite. The company laid out a townsite near the intersection of Grand Avenue and Rancho Santa Fe Road with 5 - to 10-

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acre plots. A number of houses were built in addition to a hotel, post office, and several stores. In 1892, there were 87 registered voters. In the late 1880s, the Santa Fe Railroad announced that it was going to lay tracks going through the valley. To the disappointment of the citizens, the tracks were laid one mile away from the center of the town. The old town was abandoned in 1901, and many of the buildings were moved to the intersection of Mission and Pico. By 1905, the new town had every convenience, including rural mail delivery and telephone service. In 1889, the first school in the area, which was started in Barham in 1880, moved to San Marcos. Later that same year, the Richland School was built, becoming the second school in San Marcos. San Marcos remained a quiet rural town through the first half of the twentieth century (ASM 2024).

Agriculture dominated the local economy from the late 1800s until the mid-1900s, and that economy was dependent on dairies and poultry production . However, during the late 1920s, a new business envisioned and created by northern Californians was developed in San Marcos. Donly Gray, an olive grower and nurseryman, sold Mulberry bushes at his nursery in Marysville. After studying the market for silk an d its production using mulberry bushes, he sought out financial backing to develop a silkworm production oper ation. Glenn Hurst, a San Francisco businessman, and his collective of businessmen provided the financial capital for the silkworm project, and they organized as the American Silk Inc. in 1926. After considering locations within Southern California, they decided on San Marcos and purchased 367 acres of land at present -day Mission Road and Mulberry Drive. In 1926, Donly Gray led the efforts for planting 45,000 mulberry trees to feed ravenous silkworms. The following year the company opened its 50,000-square-foot silkworm mill, where workers incubated and hatched worm eggs imported from France, Italy, Turkey, Egypt, and Sudan. The facility was the largest building in San Marcos, and, at one point, 100 employees worked in the building. Although the company began making silk stockings in 1930, the effects of the Great Depression and competition from Asia and Europe meant the enterprise did not get much farther than an experimental phase. Despite an attempt to restart the operations in the mid -1930s, the operations were not revived, and the company was bankrupt Dairies and poultry farms continued to be the economic mainstay of the unincorporated area (ASM 2024).

Population growth in San Marcos, and many other unincorporated areas in the county, had been constrained by the lack of water resources in the region. The arrival of Colorado River water in the city in 1956, supplementing the existing local water supply, was a big boon to the area. After the arrival of water, several small businesses started, and the population rapidly increased to 2,500. In an effort to safeguard its water rights from Escondido, the town of San Marcos, with a population of 3,200 residents, was incorporated on January 28, 1963. Through the 1960s, the City grew by a few thousand new residents, but, in the 1970s, San Marcos was flourishing as the third -fastest growing city in the state with a population of 17,479 by 1980. During the 1980s, San Marcos almost doubled its population to 33,800.

Land-Use History of Project Area
The project site was part of the 8,877-acre Rancho Los Vallecitos de San Marcos (the Little Valleys of St. Mark) granted to Don José María Alvarado in 1840 and was confirmed to Lorenzo Soto on March 1, 1883 (General Land Office 1883). The earliest-available aerial images of the property, dating to 1938, appear to show undeveloped land southeast and southwest of a road in general the same alignment as North Las Posas Road and West Mission Road, respectively, and the railroad tracks south of West Mission Road. No changes appear until 1964, at which point three constructed buildings are present west of the property . Subsequent aerial photographs show development surrounding the Project area. Evidence of foot trails and possible grading a ppears in aerials from 2000 onwards and in 2014, buildings are present to the southeast of the project site. As of 2018, most of the project site

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remains undeveloped except for a small northern portion near the rail line that parallels West Mission Road along its southwest side (ASM 2024).

Records Search
A records search request was submitted to the South Coastal Information Center (SCIC) of the California Historical Resources Information System (CHRIS) on May 31, 2023 in order to assess the presence or absence of cultural and historic resources within the project site and a one -mile radius.

The records search results identified that 35 previous cultural resources studies have been conducted within one mile of the project area. Of the 35 previous studies, one cultural resource, CA -SDI-5633, was previously recorded within the project site, which is discussed in more detail below. Additionally, one historic address was previously recorded within the one-mile search radius. This historic address is outside of the project area.

CA-SDI-5633
SDI-5633 was originally recorded by the Museum of Man as W-1573. It was next recorded in 1977 as SDI-5633. The 1977 recording noted disturbances from cultivation, Mission Road, and the railroad.

Information about the character of this resource is restricte d from public distribution and is only generally summarized herein; however, the specific information that led to the impact assessment in this EIR was taken into account.

SDI-5633 was surveyed and tested in 1990 (Gallegos and Pigniolo 1990). This study covered the entire current project area. Gallegos and Pigniolo excavated 26 shovel test pits (STPs) and two 1x1 meter test units as well as completing a surface artifact distribution map in order to identify the site boundary and identify the p resence of subsurface deposits. SDI -5633 was recommended as an important archaeological resource under CEQA under former Criteria B, D, and E, in that it can provide information which is both of demonstrable public interest and useful in addressing scientifically consequential archaeological research questions, is at least 100 years old and possesses substantial stratigraphic integrity, and involves important research questions that histo rical research has shown can be answered only with archaeological methods (Gallegos and Pigniolo 1990: 5 -2). It was recommended that the site should be avoided or mitigated with a data recovery program of 2 to 3 percent sample.

In 1996 additional testing within the railroad Right-Of-Way (ROW) at the northern edge of the site was conducted by Ogden Environmental, Inc. Seven STPs were excavated. Additional testing took place by Gallegos and Associates in 2001 and the site was recommended eligible for listing in the National Register of Historic Places (NRHP).

In 2002, Gallegos and Associates undertook a data recovery program (Gallegos and Associates 2002).

Gallegos and Associates also noted a high level of disturbance for the site, likely from agricultural use, bioturbation, and the historic construction of the Northern San Diego Railroad.

The data recovery program was designed to address research questions. The data recovery methods included manual and mechanical excavation. Native American monitoring was provided by the San Luis Rey Band of Mission Indians. Arch aeological monitoring also took place in SDI -5633 during construction of the SPRINTER Rail Project in 2005 -2006 (Guerrero et al. 2007). This work was conducted within the railroad right -of-way only and no cultural materials were discovered during the monitoring.

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In 2023, ASM Affiliates, Inc. (ASM 2023) resurveyed the project site. Based on a review of the reporting from the previous archaeological work within SDI-5633, ASM agreed with the previous evaluation, that SDI-5633 is eligible for the CRHR under Criterion 4, and that the site yielded important information to the prehistory of the local area. Previous documentation notes that the site has a high level of disturbance through agricultural use so would have little to no additional scientific value; however, the site was recommended as significant despite this disturbance due to the previous recovery of human remains at the site which are significant to Tribal values. Therefore, SDI-5633 is a historical resource under CEQA.

Archival Research
In addition to the SCIC records search, ASM conducted an on -line review of historical aerial photographs of the project area and general vicinity, to help determine the possible development and land use of the project area in the past. The earliest-available aerial images of the property, dating to 1938 show the presence of the railroad tracks and Mission Avenue to the north and Las Posas Road to the west. The project area appears undisturbed and bedrock may be present in the center of the project area. No changes are visible on the 1947 and 1953 aerial photographs. The 1964 aerial photograph shows development to the west and possibly grading or vegetation removal within the project area. Armorlite Drive to the south is present starting in 1981. Grading or v egetation removal may have taken place in 1989 and 1990 and in 2000. Modern development surrounds the project area.

Tribal Correspondence and Coordination
Following is a summary of the coordination between ASM and culturally affiliated tribes during information gathering.

On May 9, 2023, a Sacred Lands File search request was sent to the NAHC. The NAHC responded on June 15, 2023, and was negative, meaning that no sacred lands were recorded by Native American tribes or individuals on the property or in the vicinity. The NAHC response provided 33 Tribal contacts which may have more infor mation on the Project area. ASM sent information requests letters to the Tribal contacts on June 16, 2023.

To date responses have been received from the Jamul Indian Village, Pechanga Band of Indians, the San Luis Rey Band of Mission Indians, the Rincon Band of Luiseño Indians, and the San Pasqual Band of Mission Indians.

On June 16, 2023, Lisa Cumper, Tribal Historic Preservation Officer of the Jamul Indian Village, responded that she requests all reports for the project and the exact address as the Tribal database shows that it is a sensitive area. She also defers to a closer tribe, specifically Cami Mojado of the San Luis Rey Band of Mission Indians.

On June 16, 2023, Cami Mojado of the San Luis Rey Band of Mission Indians responded that she requests the same information.

On June 16, 2023, Paul Macarro, Cultural Coordinator of the Pechanga Band of Indians responded that the Project area is within their Ancestral Territory, and are interested in participating in the Project.

The Project area is within a mapped archaeological site and will result in direct impacts to Ancestral human remains and associated grave goods. The Tribe requested government to government consultation.

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On July 6, 2023, Shuuluk Linton, Tribal Historic Preservation Office Coordinator, Rincon Band of Luiseño Indians, responded that the Rincon Band has specific concerns that the project may impact tangible Tribal Cultural Resources, the project site is cultu rally sensitive and the Rincon Band would like to consult directly with the lead agency.

On July 31, 2023, Angelina Gutierrez, Tribal His toric Preservation Office, Deputy THPO/ Monitor Supervisor, San Pasqual Band of Mission Indians, responded that they would like to engage in formal government-to-government consultation under CEQA so that San Pasqual can have a voice in the development of the site and mitigate any adverse impacts.

In addition to ASM reaching out to Tribes as part of the report preparation, the City provided notice to Tribes pursuant to AB 52 and consulted with Tribes. More information on the City’s government -to- government consultation with Tribes is included in Section 3.12, Tribal Cultural Resources.

Archaeological Resources
An intensive -level survey of the project area was conducted on May 26, 2023, by ASM Associate Archaeologist Michelle Hamilton. Ms. Hamilton surveyed the entire project area in transects spaced approximately 15 m apart wherever possible. Saving Sacred Sites Native American monitor Cami Mojado assisted in the survey.

Ground surface visibility within the project area was poor due to dense vegetation consisting of black, white, and California sage, buckwheat, mustards, and a single pepper tree found in the middle of the project area. Modern trash was present across the project area. Evidence of previous grading and vegetation were visible. The project area is currently surrounded by modern development, including train tracks, roads, and residential and commercial developm ent. As much of the survey area was covered in dense vegetation which limited movement and obscured the ground surface, efforts were primarily focused on examining bedrock outcrops for evidence of milling and available visible soils .

Site recording included the definition of site boundaries and documentation of features. Detailed sketch maps were made, demonstrating the relationship of the site’s locations to topographic features and other landmarks. ASM then completed California State DPR 523 site records for submittal to the SCIC and assignment of primary numbers and site trinomials. Recording efforts included the plotting of the site on a USGS 7.5-minute quad map. Digital photographs were taken to document specific features of the site, as well as the general character of the survey area.

3.4.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to cultural resources, including state and local guidelines.

Federal/State
Native American Heritage Values
Federal and state laws mandate that consideration be given to the concerns of contemporary Native Americans with regards to potentially ancestral human remains associated funerary objects, and items of cultural patrimony. Consequently, an important element in assessing the significance of the study site has been to evaluate the likelihood that these classes of items are present in areas that would be affected by the proposed Project.

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The category termed “Traditional Cultural Properties” in discussions of cultural resource management performed under federal auspices is also potentially relevant to prehistoric sites. According to Patricia L. Parker and Thomas F. King (1998), “Traditional” in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. The traditional cultural significance of a historic property, then, is significance derived from the role the property plays in a community’s historically rooted beliefs, customs, and practices. Examples of properties possessing such significance include the following:

1. A location associated with the traditional beliefs of a Native American group about its origins, its cultural history, or the nature of the world;

2. A rural community whose organization, buildings and structures, or patterns of land use reflect the cultural traditions valued by its long-term residents;

3. An urban neighborhood that is the traditional home of a particular cultural group, and that reflects its beliefs and practices;

4. A location where Native American religious practitioners have historically gone, and are known or thought to go today, to perform ceremonial activities in accordance with traditional cultural rules of practice; and/or

5. A location where a community has traditionally carried out economic, artistic, or other cultural practices important in maintaining its historic identity.

State
Native American Historic Cultural Sites
The Native American Historic Cultural Sites law addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Nati ve American skeletal remains are discovered during construction of a project; and establishes the NRHC to resolve disputes regarding the disposition of such remains. In addition, the Native American Historic Resource Protection Act makes it a misdemeanor punishable by up to one year in jail to deface or destroy an Indian historic or cultural site that is listed or may be eligible for listing in the California Register of Historic Resources (CRHR).

California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act), enacted in 2001, required all state agencies and museums that receive state funding and that have possession or control over collections of human remains or cultural items, as defined, to complete an inventory and summary of these remains and items on or before January 1, 2003, with certain exceptions. The California Repatriation Act also provides a process for the identification and repatriation of these items to the appropriate tribes.

Health and Safety Code 7050.5
This code establishes that any person who knowingly mutilates, disinters, wantonly disturbs, or willfully removes any human remain in or from any location without authority of the law is guilty of a misdemeanor. It further defines procedures for the discov ery and treatment of Native American remains.

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Local
San Marcos General Plan Conservation and Open Space Element The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of archaeological, and historic resources. The following goals and policies apply to the project:
• Policy COS -2.5: Continue to review future development proposals to ensure that cultural resources (including prehistoric, historic, paleontological, and SB 18 Tribal resources) are analyzed and conserved in compliance with CEQA requirements. • Goal COS -11: Continue to identify and evaluate cultural, historic, archaeological, paleontological, and architectural resources for protection from demolition and inappropriate actions.
o Policy COS-11.1: Identify and protect historic and cultural resources including individual properties, districts, and sites (e.g., archaeological sites) in compliance with CEQA. o Policy COS -11.2: Prohibit the demolition or removal of a historic structure without evaluation of the condition of the structure, the cost of rehabilitation, and the feasibility of alternatives to preservation in place including but not limited to relocati on, or reconstruction offsite, and/or photo-preservation.
o Policy COS-11.3: Identify opportunities for adaptive reuse of historic sites and buildings to preserve and maintain their viability.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.7, Land Use and Planning. As detailed in Table 3.7-7, the project is/is not consistent with the applicable General Plan goals and policies pertaining to cultural resources.

San Marcos Archaeological and Historical Resources Consultant Guidelines The City of San Marcos published guidelines for archaeological and historical resources consultants in January 2024. The guidelines are generally meant to aid third party consultants who prepare archaeological or architectural history inventories, surveys, evaluations, and other technical documents. These guidelines include information pertaining to the minimum qualifications, records searches, tribal outreach, pedestrian surveys, reporting, research design, findings, discussion and evaluations, management conclusions, references, and appendices of inventories, surveys, evaluations, and other technical documents (City San Marcos 2024). ASM prepared the archaeological resources inventory report in accordance with these guidelines.

3.4.3 Thresholds of Significance
The determination of significance for cultural resources is based on CEQA Guidelines Appendix G .

Impacts to cultural resources would be significant if the proposed project would:
• Threshold #1: Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.
• Threshold #2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

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• Threshold #3: Disturb any human remains, including those interred outside of dedicated cemeteries.

3.4.4 Project Impact Analysis
The project site is vacant , with indications of past agricultural use that has since gone fallow . The entire project site would be graded to prepare the site for future development. Grading depths are anticipated to range from 3 to 7 feet depending on the area of the project site. The grading plan is included in Appendix A.2. Ground disturbing activities can result in impacts to archaeological resources if they are present on the project site.

As part of the project design, an area would be set aside on the project site for repatriation of cultural resources. This area would be subject to a conservation easement and would be protected by a deed restriction.

The following analysis discusses the potential for the proposed project to impact cultural resources.

Threshold #1: Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

As detailed in Section 15064.5(a) of the CEQA Guidelines, the term "historical resources" shall include the following:
(1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 14 CCR, Section 4850 et seq.)
(2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code, or identified as significant in an historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, mi litary, or cultural annals of California may be considered to be an historical resource, provided the lead agency's determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code, § 5024.1, Title 14 CCR, Section 14 CCR, Section 4852) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage;
(B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

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(D) Has yielded, or may be likely to yield, information important in prehistory or history. (E) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k) of the Public Resources Code), or identified in an historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code sec tions 5020.1(j) or 5024.1.

Based on a review of the reporting from the previous archaeological work within SDI -5633, ASM concurred with the previous evaluation that SDI-5633 is eligible for the California Register of Historical Resources and that the site yielded important information to the prehistory of the local area. Therefore, SDI-5633 was determined to be a historical resource and unique archaeological resource under CEQA.

The proposed project would develop the entire project site, including the portion of the project site that overlaps with archaeological site SDI -5633. Grading activities would be required across the entire project site to prepare for utility infrastructure and building construction. Due to the small size of the property, avoidance and preservation in place are not feasible for the project. A No Project/No Development alternative and No Project/Reduced Development Footprint alternative are analyzed in Section 4.0 of this document.

Mitigation of adverse impacts is required if the proposed project will cause substantial adverse change. Substantial adverse change includes demolition, destruction, relocation, or alteration such that the significance of an historical resource would be impaired. In 2002 a data recovery program was conducted to mitigate the adverse impact to SDI -5633 caused by development of the property , by excavating a 2 -3% sample of the eligible portion of the site (Gallegos and Associates 2002). This previous data recovery program mitigated impact to the archaeological aspect of SDI -5633 (impacts to the tribal cultural resources aspect of the site are analyzed separately in Section 3.13 of this EIR).

The previous data recovery efforts collected and documented the data th at can provide important information in prehistory (CRHR Criterion 4 and NRHP Criterion D). Because development of the project would not differ from the impacts to site SDI-5633 that were mitigated through data recovery, impacts to historical resources by the proposed project would be less than significant.

Threshold #2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

As described above (Threshold #1), The 2002 data recovery program was considered to adequately mitigate adverse effects to the archaeological component of the resource. The level of disturbance from historic uses such as agriculture, construction activities of adjacent parcels, and construction of Mission Road and the railroad line over the years, as well as historic disturbances to the project site and the data recovery mitigation program, suggests that the site lacks integrity. However, should as yet identified human remains be uncovered, the site would be considered significant for Tribal values despite the lack integrity.

Future ground disturbing activities are likely to encounter additional cultural materials associated with Site SDI-5633 that would need to be appropriately treated. In addition, ground disturbing activities may reveal human remains or previously unknown ar chaeological resources that are not reasonably believed to be associated with site SDI -5633, such as archaeological materials associated with historic-era European American presence. Impacts to previously unknown archaeological resources could include dama ge or loss of integrity, and this may result in an adverse change to a historical

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resource of an archaeological nature or to unique archaeological resources. In addition, in the event of the discovery of additional human remains, such an occurrence may cause an adverse impact to historical resource SDI -5633. These represent a
significant impact (Impact CR -1) and mitigation is
required.
• Impact CR-1 Due to grading and ground disturbing activities, the proposed project may uncover previously unidentified archeological resources associated with SDI -5633 or may result in previously unknown archaeological resources associated with other time periods or cultures.

Threshold #2: Disturb any human remains, including those interred outside of dedicated cemeteries.

Gallegos and Associates (2002) and ASM (2023) determined that SDI -5633 has a potential to encounter human remains during project construction. T he handling of unanticipated discovery of human remains is guided by Section 7050.5 of the California Health and Safety Code. If human remains are encountered during project construction, there is a potential for a significant impact
(Impact CR-2) and mitigation is required.
• Impact CR-2 There is a potential for project construction activities to disturb previously unidentified human remains on the project site.

State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. Adherence to State Health and Safety C ode Section 7050.5 is mandated and is reiterated as a mitigation measure in Section 3.4.6.

3.4.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to cultural resources, the cumulative analysis is ba sed upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on cultural resources. All of the cumulative projects identified in Table 2 -3 are considered in this cumulative analysis.

SDI-5633 covers a portion of the project site. Previous data recovery has mitigated impacts to the site, but the project has the potential to encounter other cultural resources. Mitigation was identified to reduce the impact to below a level of significance. Other cumulative projects would be required to assess the potentia l for impact to historical and archaeological resources and provide mitigation measures or avoidance measures to reduce significant impacts to cultural resources consistent with the requirements of CEQA and the City. Implementation of such measures ensure cultural historical and archeological resources are properly handled on a case -by-case basis. Additionally, the lead agency is required to consult with tribes pursuant to the requirements of SB 18 and/or AB 52. The City requires standard conditions of approval related to construction monitoring by an archaeologist to

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ensure there are no inadvertent impacts to archaeological resources. Cumulative impacts would be less than significant.

3.4.6 Mitigation Measures
Archeological Resources (Impact CR-1)
The following cultural resources mitigation measures shall apply for ground disturbing activities during the project construction phase.

MM-CR-1a Archaeological Monitoring: Prior to the issuance of a Grading Permit or ground disturbing activities, the Applicant/Owner or Grading Contractor shall provide written documentation (either as signed letters, contracts, or emails) to the City’s Planning Division stating that a Qualif ied Archaeologist has been retained at the Applicant/Owner or Grading Contractor’s expense to monitor ground disturbing activities associated with project construction.

The Qualified Archaeologist shall be invited to attend all applicable pre - construction meetings with the General Contractor and/or associated subcontractors to present the construction monitoring program. The Qualified Archaeologist shall be present on-site during grubbing, grading, trenching, and/or other ground disturbing activities that occur in areas of native soil or other permeable natural surfaces that have the potential to unearth any evidence of potential archaeological resources. In areas of ar tificial paving, the Qualified Archaeologist shall be present on site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb more than six (6) inches below the original pre-project ground surface to identify any evidence of potential archaeological resources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non-commercial sources that have been determined to be absent of archaeological resources by the Qualified Archaeologist.

The Qualified Archaeologist shall maintain ongoing collaborative coordination with the Native American monitor(s) (mitigation measure TCR -1) during all ground disturbing activities. The requirement for the construction monitoring program shall be noted on all applicable construction documents, including demolition plans, grading plans, etc. The Applicant/Owner or Grading Contractor shall provide written notice to the Planning Division, preferably through e -mail, of the start and end of all ground disturbing activities.

Prior to the release of any grading bonds, or prior to the issuance of any project Certificate of Occupancy, an archaeological monitoring report, which describes the results, analysis, and conclusions of the construction monitoring shall be submitted by the Qualified Archaeologist, along with any Native American monitor’s notes and comments received by the Qualified Archaeologist, to the Planning Division Director for approval. Once approved, a final copy of the archaeological monitoring report shall be ret ained in a confidential City project file and may be

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released, as a formal condition of Assembly Bill (AB) 52 consultation, to consulting Tribes. A final copy of the report, with all confidential site records and appendices, will also be submitted to the South Coastal Information Center after approval by the City.

MM-CR-1b Unanticipated Discovery Procedures: The Qualified Archaeologist may temporarily halt or divert ground disturbing activities if previously unknown archaeological resources are discovered during construction activities. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be associated with Native American culture, it will be conside red a tribal cultural resource and subject to mitigation measures MM-TCR-4 and MM-TCR-5. Non-Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource (subject to MM-TCR-4) and a potentially significant archaeological resource that is associated with Native American culture , then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.

Isolates and clearly non-significant archaeological resources (as determined by the Qualified Archaeologist) will be minimally documented in the field. All unearthed archaeological resources will be collected, temporarily stored in a secure location until analysis and documentation are complete. If a determination is made that the archaeological resources are considered potentially significant by the Qualified Archaeologist, then an adequate artifact sample to address research avenues previously identified for sites in the area will be collected using professional archaeological collection methods.

In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections.

The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project c onstruction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the curation facility that the curation has been completed.

Human Remains (Impact CR-2)
MM-CR-2 Human Remains : As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to ov erlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code Section 5097.98.

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If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two (2) business working days of being notified if the remains are subject to their authority. If the Medical Examiner recognizes the remains to be Native American, and not under their jurisdiction, then they shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

If suspected Native American remains are discovered, the remains shall be kept in situ (in place) until after the Medical Examiner makes its determination and notifications, and until after the Most Likely Descendent is identified, at which time the archae ological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public.

According to California Health and Safety Code, six (6) or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a location free from future disturb ance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

3.4.7 Conclusion
Site SDI-5633 covers a portion of the project site. Previous data recover y mitigated the potential for the project to significantly impacts the site. However, it is likely that additional resources associated with site SDI -5633 will be encountered during grading. This represents a significant impact. This impact would be mitigat ed to below a level of significance through implementation of mitigation measures MM -CR-1a, MM -CR-1b, and MM -CR-2. Specifically, implementation of these mitigation measures provides for the presence of archaeological monitors during ground disturbing activities that would be able to identify any previously unidentified cultural and/ or historical resources, to prevent inadvertent disturbance of any intact cultural deposits that may be present. Should any resources be identified, implementation of MM-CR-1a and MM-CR-1b would ensure proper handling and treatment of such resources by providing for a proper evaluation to determine whether additional archaeological work is necessary. To fur ther ensure impacts to Native American archaeological resources are minimized, implementation of MM-CR-1a, MM-CR-1b and additional measures in Section 3.12, Tribal Cultural Resources, of this EIR provide additional protections for significant resources, and describes the process for proper treatment and handling to ensure impacts are minimized.

Potential impacts to human remains would be mitigated through implementation of mitigation measure MM-CR-2, which specifies that remains shall not be further disturbed until the San Diego County Coroner has determined origins of the remains and final treatment has been agreed to with input of the Most Likely Descendent as necessary. Therefore, with incorporation of these measures, potential impacts to cultural resources would be reduced to below a level of significance.

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3.5 Energy
Introduction
This section describes the existing setting of the project site with respect to energy use and conservation, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed project.

Appendix G and Appendix F of the California Environmental Quality Act (CEQA) Guidelines requires that an environmental impact report (EIR) discuss the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy to ensure that energy implications are considered in project -related decision-making processes. As such, this section analyzes the energy impacts of the proposed project. Specifically, this section summarizes the existing conditions in the project area, discusses the regulatory framework, and discloses estimated energy use during the construction and operational phases of the proposed project. This analysis considers the electricity, natural gas, and transportation fuel (petroleum) demand of the proposed project.

The analysis is based on the following report, which is included as Appendix G of this document8:
• Energy Usage Letter, Armorlite Lofts 225 Development (GPA23 -0002, R23-0001, SDP23- 0003, CUP23-0002), prepared by LDN Consulting, November 4, 2024 (LDN 2024).

Table 3.5-1 summarizes the project- and cumulative-level energy impacts, by threshold.

Table 3.5-1. Energy Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
#1: Result in potentially significant
environmental impact due to
wasteful, inefficient, or unnecessary
consumption of energy resources,
during project construction or
operation.

Less than Significant Less than Significant Less than Significant Without Mitigation
#2: Conflict with or obstruct a state
or local plan for renewable energy or
energy efficiency.

Less than Significant Less than Significant Less than Significant Without Mitigation

3.5.1 Existing Conditions
The environmental setting for the proposed project related to electricity, natural gas, and petroleum, including associated service providers, supply sources, and estimated consumption, is discussed below.

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

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Electricity
California uses more energy than all other states except Texas. However, due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s energy use per capita is less than in almost all other states (except Hawaii). In 2022, California was the nation's fourth- largest electricity producer and accounted for about 5% of all U.S. utility-scale (1-megawatt and larger) power generation. Renewable resources, including hydropower and small -scale (less than 1 - megawatt) customer-sited solar photovoltaic (PV) systems, supplied about half of California's total in- state electricity generation. In 2022, natural gas -fired power plants provided 42% of the state's total net generation. Coal fuels only a small amount of California's in-state net generation, all of it from one industrial cogeneration plant. California imports more electricity than any other state and typically receives between one-fifth and one-third of its electricity supply from outside of the state. In 2022, in- state utility-scale electricity generation equaled about four -fifths of California's electricity sales, and the rest of the state's supply came from out of state. Wildfires in California and surrounding states threaten both imports of electricity and transmission within the state (EIA 2023a). California consumed 251,869,136 megawatt hours (MWH) of electricity in 2022 (EIA 2023b).

San Diego Gas & Electric (SDG&E) provides electric and natural gas services to a population of 1.4 million business and residential accounts. SDG&E distributes energy service through 1.49 million electric meters and 905,000 natural gas meters in a 4,100-square-mile service area that includes San Diego County and southern Orange County (SDG&E 202 4). SDG&E is a subsidiary of Sempra Energy and would provide electricity to the proposed project.

The Path to Net Zero: A Decarbonization Roadmap for California (Roadmap) examines the implications to the State and SDG&E service area of transitioning to a carbon neutral (net zero emissions) economy by 2045, as mandated in the California Climate Crisis Act (See Section 3.5.2 Regulatory Setting below).

Electricity is expected to play a central role in decarbonization. Clear priorities include the need to expand electrification and supplies of solar and wind power, invest in a diverse set of electric generation resources that will help ensure the electric grid is reliable and lastly, to provide much larger volumes of clean fuels (SDG&E 2022a).

Electrification is central to decarbonizing the transportation and building sectors. As such, electricity usage and demand are expected to increase. According to the Roadmap, the State of California can expect a 96% projected increase in electric consumption between 2020-2045 and a 60% projected increase in net peak demand for the same period. SDG&E projects approximately a 100% increase in electric consumption for its service area between 2020 and 2045 and an 85% increase in net peak demand. California had 85 gigawatt (GW) total capacity in 2020 and is projected to need 356 GW of capacity by 2045 (SDG&E 2022b). As described in the California Air Resources Board (CARB) 2022 Scoping Plan for Achieving Carbon Neutrality, the scale of transformation needed over the next decade to avoid the worst impacts of climate change and meet ambitious climate goals is extraordinary. This is why Governor Newsom and th e Legislature invested over $15 billion in climate action through the 2021/2022 California Comeback Plan, and why the 2022 –2023 budget marks the beginning of the California Climate Commitment—the governor’s multi-year plan to invest $54 billion in climate action.

This plan includes $2.1 billion for clean energy investments, such as long duration storage, offshore wind, green hydrogen, and industrial decarbonization (CARB 2022). California is planning to expand and reinforce its electrical grid through inves tment and regional cooperation, increase in -state renewable energy as well as renewable energy imports, increase storage, particularly behind the meter PV storage, work toward changing consumer behavior (e.g., charging electric vehicles during the day when solar energy is available) and investing in development and implementation of technology that allow electric vehicles (EVs) to transmit energy back into the grid (SDG&E 2022a).

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SDG&E believes meeting carbon neutrality will require installing 40 GW of new battery storage as well as 20 GW of dispatchable generation from 100% clean hydrogen generation by 2045. Moreover, in addition to existing natural gas generation, they believe that 4 GW of electricity from natural gas with carbon capture and sequestration will be needed to support reliability as the electric sector decarbonizes. Combined, these flexible resources can provide clean electricity when the sun is not shining, and the w ind is not blowing and ensure that high electricity demand during the summer months can be reliably met (SDG&E 2022a). SDG&E’s 2022 Individual Integrated Resource Plan (IIRP) is designed to meet key statutory requirements related to ensuring system reliability, reducing greenhouse gas (GHG) emissions with the best-fit resources at the lowest possible cost, and satisfying the State’s Renewables Portfolio Standard program goals. To that end, SDG&E is anticipating procuring 56 percent of its power from renewab le resources for the 2021- 2024 RPS Compliance Period, which is well above the State’s 38.4-percent requirement (SDG&E 2022b).

Additionally, within SDG&E’s service area, charging infrastructure will help to enable transportation electrification. SDG&E projects 900,000 electric vehicles ( EVs) will operate in their service area in 2030 and 3,230,000 EVs in 2045. Similarly, 180,000 EV chargers are projected in SDG&E’s service area in 2030 and 640,000 EV chargers are projected in 2045 (SDG&E 2022a).

Natural Gas
California is the nation's second -largest natural gas consumer (after Texas). Total natural gas consumption in 2021 totaled 2,101 billion cubic feet. In 2021, about 33% of the natural gas delivered to California consumers went to the state's industrial sector, and about 31% went to the electric power sector, where it fuels more than two -fifths of the state's total electricity generation. The residential sector, where three in five California households use natural gas for home heating, accounted for 22% of natural gas use, and the commercial sector consumed about 12%. The transportation sector used about 1% as compressed natural gas vehicle fuel. California's natural gas output has declined steadily since 1985, and the state now accounts for less than 1% of the nation's total natural gas reserves and production. California's natural gas production is less than one-tenth of the state's total consumption (EIA 2023a).

The California Public Utility Commission (CPUC) regulates natural gas utility rates and services provided by Pacific Gas and Electric Company (PG&E), Southern California Gas Company , SDG&E, Southwest Gas, and several smaller natural gas utilities. SDG&E provides natural gas service to the Counties of San Diego and Orange and would provide natural gas to the proposed project. SDG&E is a wholesale customer of SoCalGas and currently recei ves all its natural gas from the SoCalGas system (CPUC 2021).

Petroleum
California is the nation's second-largest consumer of refined petroleum products, after Texas, and accounts for about 8% of U.S. total consumption. In 2021, California was the nation's largest consumer of jet fuel and the second-largest consumer of motor gasoline, after Texas. The transportation sector used about 83% of the petroleum consumed in the state. The industrial sector accounted for about 13% of state petroleum use, and the commercial sector consumed about 3%. The residential sector, where about 1 in 27 California households heat with petroleum products, mostly propane, used about 1%. A minimal amount of petroleum is used for electricity generation . Total petroleum consumption was estimated to be 605 million barrels in 2021 (EIA 2023a).

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Technological advances, market trends, consumer behavior, and government policies could result in significant changes in fuel consumption by type and in total. At the federal and state levels, various policies, rules, and regulations have been enacted to i mprove vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation ‐source air pollutants and GHG emissions, and reduce vehicle miles traveled (VMT). Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible.

California requires that motorists use, at a minimum, a specific blend of motor gasoline called CaRFG (California Reformulated Gasoline) to reduce emissions from motor vehicles. California refineries produce cleaner fuels in order to meet state environment al regulations. Refineries in the state often operate at or near maximum capacity because of the high demand for those petroleum products and the lack of interstate pipelines that can deliver those cleaner fuels into the state (EIA 2023a).

Largely as a result of and in response to these multiple factors, gasoline consumption within the state has declined in recent years, and availability of other alternative fuels/energy sources has increased.

The quantity, availability, and reliability of transportation energy r esources have increased in recent years, and this trend may likely continue and accelerate. Increasingly available and diversified transportation energy resources act to promote continuing reliable and affordable means to support vehicular transportation w ithin the state. California is part of the West Coast Green Highway, an extensive network of electric vehicle direct current (DC) fast charging stations located along Interstate 5, and the state has more than 14,000 public electric vehicle charging stations. As of December 31, 2021, California had more than 563,000 registered all -electric vehicles, the most of any state.

California also requires all public transit agencies to gradually transition to 100% zero -emission bus (ZEB) fleets. Beginning in 2029, al l transit agency new bus purchases must be ZEBs (EIA 2023a ).

Further, Executive Order N-79-20 calls for elimination of new internal combustion passenger vehicles by 2035. By setting a course to end sales of internal combustion passenger vehicles by 2035, the Governor’s Executive Order establishes a target for the transportation sector that helps put the state on a path to carbon neutrality by 2045. It is important to note that the Executive Order focuses on new vehicle sales for automakers, and therefore does not require Californians to give up the existing cars and trucks they already own. The primary mechanism for achieving the Zero-Emission-Vehicle target for passenger cars and light trucks is the Advanced Clean Cars II Program discussed below in Section

3.5.2 Regulatory Setting.

As stated above, SDG&E’s Decarbonization Roadmap projects 900,000 EVs will operate in their service area in 2030 and 3,230,000 EVs in 2045. Similarly, 180,000 EV chargers are projected in SDG&E’s service area in 2030 and 640,000 EV chargers are projected in 2045 (SDG&E 2022a).

Gasoline and other vehicle fuels are commercially provided commodities and would be available to the proposed project through commercial outlets.

3.5.2 Regulatory Setting
Federal, state, and local agencies regulate energy use and consumption through various means and programs. On the federal level, the U.S. Department of Transportation, the U.S. Department of Energy, and the U.S. Environmental Protection Agency are three federal agencies with substantial inf luence over energy policies and programs. On the state level, CPUC and California Energy Commission (CEC) are two agencies with authority over different aspects of energy. Relevant federal, state, and local energy-related regulations are summarized below. This information helps to place the impact analysis within its proper regulatory context.

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Federal
Federal Energy Policy and Conservation Act (1975)
The Federal Energy Policy and Conservation Act established the first fuel economy standards for on - road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.

Energy Independence and Security Act (2007)
The Energy Independence and Security Act of 2007 (EISA) aims to increase energy security, develop renewable energy production, and improve vehicle fuel economy. The following are provisions related to energy efficiency:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325) • Building Energy Efficiency (Sections 411–441)
This federal legislation requires ever -increasing levels of renewable fuels (the RFS) to replace petroleum. The U.S. Environmental Protection Agency (EPA) is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains a minimum volume of renewable fuel. The RFS program regulations were developed in collaboration with refiners, renewable fuel producers, and many other stakeholders.

The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel volume mandate in the United States. As required under the act, the original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the EISA, the RFS program was expanded in several key ways that lay the foundation for achieving significant reductions in greenhouse gas ( GHG) emissions from the use of renewable fuels, reducing imported petroleum, and e ncouraging the development and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:
• EISA expanded the RFS program to include diesel, in addition to gasoline. • EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022. • EISA established new categories of renewable fuel, and set separate volume requirements for each one.
• EISA required the U.S. Environmental Protection Agency to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.

Additional provisions of the EISA address energy savings in government and public institutions, research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green” jobs.

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State
The discussion below focuses primarily on those policies, regulations, and laws that directly pertain to energy-related resources . Many policies, regulations, and laws targeted to the reduction of GHG emissions are expected to achieve co -benefits in the form of reduced demand for energy -related resources and enhanced efficiencies in the consumption of energy-related resources.

State of California Energy Action Plan
The CEC and CPUC approved the first State of California Energy Action Plan in 2003. The plan established shared goals and specific actions to ensure that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and actions that are cost-effective and environmentally sound for California's consumers and taxpayers. In 2005, a second Energy Action Plan was adopted by the CEC and CPUC to reflect various policy changes and actions of the prior two years.

At the beginning of 2008, the CEC and CPUC determined that it was not necessary or productive to prepare a new energy action plan. This determination was based in part on a finding that the state’s energy policies have been significantly influenced by the passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed below). Rather than produce a new energy action plan, the CEC and CPUC prepared an “update” that examines the state’s ongoing actions in the context of global climate change.

Integrated Energy Policy Report
Senate Bill (SB) 1389 (2002) requires the CEC to conduct assessments and forecasts of all aspects of energy industry supply, production, transportation, delivery and distribution, demand, and prices.

The CEC shall use these assessments and forecasts to develop energy policies that conserve resources, protect the environment, ensure energy reliability, enhance the state's economy, and protect public health and safety (Pub. Res. Code § 25301(a)).

The CEC adopts an Integrated Energy Policy Report (IEPR, pronounced eye'-per) every two years and an update every other year. The most current report is the 2023 Integrated Energy Policy Report Update which covers a broad range of topics, including accelerated connection of clean energy, California energy demand forecast, potential growth of hydrogen in California, updates on key issues including gas system decarbonization, benefits of the clean transportation program and energy efficiency.

California Renewables Portfolio Standards
Senate Bill 1078 (2002)
This bill established the California Renewables Portfolio Standards (RPS) Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year, culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill relatedly required the CEC to certify eligible renewable energy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover above -market costs of renewable energy.

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Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018) Senate Bill (SB) 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California utilities to generate 33% of their electricity from eligible renewable energy resources by 2020. Specifically, SB X1 -2 set a three -stage compliance period: by December 31, 2013, 20% shall come from renewables; by December 31, 2016, 25% shall come from renewables; and by December 31, 2020, 33% shall come from renewables.

SB 350 (2015) requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.

In addition, SB 350 includes the goal to double the energy efficiency savings in electricity and natural gas final end uses (such as heating, cooling, lighting, or class of energy uses on which an energy - efficiency program is focused) of retail customers through energy conservation and efficiency.

SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030 be secur ed from qualifying renewable energy sources. SB 100 also states that it is the policy of the state that eligible renewable energy resources and zero-carbon resources supply 100% of the retail sales of electricity to California by 2045. This bill requires that the achievement of 100% zero-carbon electricity resources does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.

Greenhouse Gas Reduction
Executive Order (EO) S-3-05 (2005), Assembly Bill 32 (2006) and Senate Bill 32 (2016), In 2005, EO-03-05 set GHG reduction targets for California. The Legislature followed up on this EO by enacting AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32, which extended the horizon year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32 , the California Air Resources Board prepares scoping plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing energy efficiencies and the use of renewable resources and reducing the consumption of petroleum-based fuels (such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co- benefits for energy-related resources.

SB 375 Sustainable Communities and Climate Protection Act (2008) The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinates land use planning, regional transportation plans, and funding priorities to help California meet its GHG emissions reduction mandates. As codified in California Governme nt Code, Section 65080, SB 375 requires metropolitan planning organizations (San Diego Association of Governments) to include a Sustainable Communities Strategy in its regional transportation plan. The main focus of the Sustainable Communities Strategy is to plan for growth in a fashion that will ultimately reduce GHG emissions, but the strategy is also a part of a bigger effort to address other development issues within the general vicinity, including transit and VMT, which influence the consumption of pet roleum-based fuels.

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

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

The 2022 CARB Scoping Plan for Achieving Carbon Neutrality The 2022 Plan lays out a path to achieve targets for carbon neutrality and reduce anthropogenic greenhouse gas emissions by 85 percent below 1990 levels no later than 2045, as directed by Assembly Bill 1279. The actions and outcomes in the plan will achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short -lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and sto rage of carbon. The plan calls for a need to take an unprecedented transformation and aggressively seek reductions to reduce the need of fossil fuels by moving to zero emission transportation, electrifying the cars, buses, trucks, and trains.

The plan rela ys on external controls and requires partnership and collaboration with the federal government, other U.S. states, and other jurisdictions around the world for California to succeed in achieving its climate targets.

California Title 24 Building Energy Efficiency Standards The Title 24 Building Energy Efficiency Standards serve to reduce wasteful, uneconomical, and unnecessary uses of energy for the state. They are designed to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality. They include requirements in the Energy Code (Title 24, Part 6) and voluntary energy efficiency provisions in CALGreen (Title 24, Part 11). The California Energy Commission is responsible for adopting, implementing, and updating these standards every three years.

Energy Code (Title 24, Part 6) Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Because homes and businesses use nearly 70 percent of California’s electricity and are responsible for a quarter of GHG emissions, the CEC was mandated to periodically update and adopt building standards to increase energy efficiency of buildings and reduce GHGs. Part 6 of Title 24 implemented this mandate so that every three years the CEC updates the Energy Co de for new construction and renovations to existing residential and non -residential buildings.

The 2022 Building Energy Efficiency Standards (Energy Code) improve s upon the 2019 Energy Code for new construction of, and additions and alterations to, residential and nonresidential buildings. The 2022 building code went into effect January 1, 2023 and focuses on four key areas in new construction: encouraging electric heat pump technology and use, establishing electric -ready requirements when natural gas is installed, expanding solar PV system and battery storage standards, and strengthening ventilation standards to improve indoor air quality (CEC 2021).

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California Green Building Standards Code (Title 24, Part 11).

In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen and establis hes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and i nterior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low-rise residential and state-owned buildings and schools and hospitals.

The CALGreen 2016 standards required mandatory reduction in indoor and outdoor water use, diversion of demolition waste, mandatory inspections of energy systems, inclusion of electric vehicle charging stations for designated parking spaces and use of low-pollutant-emitting exterior and interior finish materials.

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

State Vehicle Standards
Although the focus of the state’s vehicle standards is on the reduction of air pollutants and GHG emissions, one co-benefit of implementation of these standards is a reduced demand for petroleum- based fuels.

Assembly Bill 1007 (2005)
AB 1007 (2005) required the CEC to prepare a statewide plan (State Alternative Fuels Plan) to increase the use of alternative fuels in California . The CEC prepared the plan in partnership with CARB and in consultation with the other state, federal, and local agencies. The plan assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in- state production of biofuels without causing a significant degradation of public health and environmental quality.

AB 1493 (2002), EO S-1-07 (2007), and EO B-16-12 (2012) In response to the transportation sector accounting for more than half of California’s carbon dioxide (CO2) emissions, AB 1493 was enacted in 2002. AB 1493 requires CARB to set GHG emission standards for passenger vehicles and Executive Order ( EO) S-1-07 sets a declining Low Carbon Fuel Standard to reduce the carbon intensity of California passenger vehicle fuels. EO B -16-12 supports and facilitates the development and distribution of Zero Emissions Vehicles (ZEVs).

Advanced Clean Cars Program (2012 and 2022), EO N-79-20 (2020), and Clean Miles Standard and Incentive Program (2018)
In January 2012, CARB approved the Advanced Clean Cars program, an emissions-control program for model years 2015 through 2025 that combined standards for smog producing pollutants and

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greenhouse gases into one program. The package includes elements to reduce smog -forming pollution, reduce GHG emissions, promote clean cars, and provide fuels for clean cars.

CARB’s latest rule (2022) is known as Advanced Clean Cars II which continues the concept of increasing stringency for fuel -efficiency standards and increasing the number of ZEVs. California enjoys the largest zero-emission vehicle market in the nation with more than 16% of new vehicles sold being zero-emissions or plug -in hybrids. The regulations are two -pronged. First, it amends the Zero - emission Vehicle Regulation to require an increasing number of zero-emission vehicles, and relies on currently available advanced vehicle technologies, including battery-electric, hydrogen fuel cell electric and plug -in hybrid electric -vehicles, to meet air quality and climate change emissions standards.

Second, the Low -emission Vehicle Regulations were amended to include increasingly stringent standards for gasoline cars and heavier passenger trucks to continue to reduce smog -forming emissions.

EO N -79-20 calls for the elimination of new internal combustion passenger vehicles by 2035. By setting a course to end sales of internal combustion passenger vehicles by 2035, the Governor’s Executive Order establishes a target for the transportation sector that helps put the state on a path to carbon neutrality by 2045. It is important to note that the Executive Order focuses on new vehicle sales for automakers, and therefore does not require Californians to give up the existing cars and trucks they already own. The primary mechanism for achieving the ZEV target for passenger cars and light trucks is the Advanced Clean Cars II Program discussed above.

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

In addition to the Advanced Clean Cars II, the Clean Miles Standard regulation will also help enable the goal of 100 percent ZEV sales in 2035 by creating demand for ZEVs. This regulation has aggressive requirements for electric miles that will transition ride -hailing fleets to zero -emission operations starting in 2023 and ramping up through 2030.

AB 2700, Transportation Electrification: Electrical Distribution and Grid Updates (2022) This law will enable more strategic -grid planning and investment to ensure California has the grid it needs to accommodate widespread transportation electrification when needed to meet the state’s carbon neutrality goals. With more -strategic planning and i nvestment, AB 2700 will help ensure the electrification of the transportation sector is cost -effective, facilitates progress towards the state’s goals, and maximizes benefits for all utility customers. S upported by a broad coalition of environmental, equity, labor, fleet, utility, and EV charging organizations, AB 2700 directs utilities to conduct strategic grid planning and investment to ensure the grid is proactively prepared to accommodate all the new electric cars and trucks coming over the next decade thanks to state goals and regulations like the Advanced Clean Cars , Advanced Clean Trucks , and Advanced Clean Fleets rules. It requires fleet data already collected by state agencies to be shared with California utilities, so that they can use that data in their existing grid planning processes to better anticipate electricity demand and propose necessary upgrades.

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Local
SDG&E Integrated Resource Plan
The Integrated Resource Planning (“IRP”) process is the statewide approach to electric resource planning established by SB 350 that is intended to achieve California’s GHG emissions reduction goals for the electric sector in a manner that preserves reliability and ensures reasonable cost. According to SDGE’s 2022 Individual Integrated Resource Plan (IIRP), SDG&E supports the State’s ambitious efforts to reduce GHG emissions and is committed to the State’s vision of a clean energy future. In its study, The Path to Net Zero: A Decarbonization Roadmap for California, SDG&E lays out an implementable strategy for achieving statewide decarbonization while continuing to prioritize grid reliability, affordability, and equity. SDG&E’s IIRP is designed to meet key statutory requirements related to ensuring system reliability, reducing GHG emissions with the best-fit resources at the lowest possible cost, and satisfying the State’s Renewables Portfolio Standard program goals. To that end, SDG&E is anticipating procuring 56 percent of its power from renewable resources for the 2021- 2024 RPS Compliance Period, which is well above the State’s 38.4-percent requirement.

SDG&E’s IIRP submits two Conforming Portfolios that achieve targets of 30 and 25 million metric tons (MMT) for the year 2035. SDG&E’s Conforming Portfolios demonstrate that it is well positioned to achieve the State’s climate and reliability goals under both the 25 MMT and 30 MMT benchmark scenarios. This advantage is due in part to the following:
• SDG&E’s early compliance with RPS requirements, with around 56 percent of its energy mix expected from renewable resources in Compliance Period 4 (2021- 2024); • SDG&E’s aggressive adoption of energy storage; and
• The absence of coal resources in SDG&E’s portfolio.

While SDG&E’s portfolio is primarily made up of solar and natural gas resources, SDG&E’s modeling resulted in planned existing and new resources consisting primarily of solar, storage, and wind resources, with small amounts of demand response and firm, zero -emitting resources (e.g., geothermal). The total capacity of these planned existing and new resources in 2035 is 1,546 MW.

SDG&E is fully compliant with RPS and long-term contracting requirements (SDG&E 2022b).

SDG&E Path to Net Zero: A Decarbonization Roadmap for California The SDG&E Roadmap examines the implications of the transition to net zero emissions for the state and the region that SDG&E serves. It also includes SDG&E’s recommendation for California to achieve carbon neutrality and is the first publicly available analysis to use the industry standard for electric reliability and industry modeling software in modeling how to decarbonize California by 2045. Although the state reduced GHG emissions by ~36 MMT from 2009 to 2019 , it will need to reduce emissions at 4.5 times the pace of historical reductions going forward to reach Net Zero by 2045. The Roadmap aims to advance current research on California’s decarbonization pathways. As many other studies have highlighted, electricity is expected to play a central role in decarbonization. Clear priorities include the need to expand electrification and supplies of solar and wind power, invest in a diverse set of electric generation resources that will help ensure the electric grid is reliable and lastly, to provide much larger volumes of clean fuels.

Electrification is central to decarbonizing the transportation and building sectors under the Roadmap.

It is estimated that electric generation capacity will need to increase to 356 gigawatts (GW) by 2045 in California to meet this increasing demand for clean electricity, approximately four times the capacity

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that existed in 2020. The Roadmap foresees in-state solar and wind generation providing the bulk of this capacity. Wind and solar are excellent resources for providing low -cost clean energy, but to help ensure reliability, the California electric system must also develop more flexible res ources, such as energy storage and clean dispatchable generation. This is especially important as the need for clean, reliable electricity increases from transportation and building electrification. SDG&E believes this will require installing 40 GW of new battery storage as well as 20 GW of dispatchable generation from 100% clean hydrogen generation by 2045. Moreover, in addition to existing natural gas generation, they believe that 4 GW of electricity from natural gas with carbon capture and sequestration will be needed to support reliability as the electric sector decarbonizes. Combined, these flexible resources can provide clean electricity when the sun is not shining, and the wind is not blowing and ensure that high electricity demand during the summer months can be reliably met (SDG&E 2022a).

City of San Marcos General Plan
The City’s General Plan includes various policies related to reducing GHG emissions and the co-benefit of reducing energy consumption. Applicable policies include the following:

Land Use and Community Design Element
• Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. • Policy LU -2.3: Promote landscaping (e.g., native, drought tolerant plants) that minimizes demands on water supply.
• Policy LU -2.7: Promote the installation of trees to reduce the urban heat -island effect and green infrastructure to reduce storm water runoff.
• Policy LU-3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.

Conservation and Open Space Element
• Policy COS -4.5: Encourage energy conservation and the use of alternative energy sources within the community.
• Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
• Policy COS-4.8: Encourage and support the generation, transmission, and use of renewable energy.

Environmental Justice
• Policy EJ -1.13: Encourage energy conservation and the use of alternative energy sources within the community.
• Policy EJ-1.14: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
• Policy EJ-1.15: Encourage and support the generation, transmission, and use of renewable energy.

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

City of San Marcos Climate Action Plan
Consistent with AB 32, the City adopted a Climate Action Plan (CAP) in September 2013 as a long - range plan to reduce GHG emissions and mitigate climate change impacts associated with City government operations and with implementation of the City’s General Plan. An updated CAP was adopted on December 8, 2020. The 2020 CAP builds on the efforts and strategies identified in the City’s 2013 CAP, and establishes GHG emission targets and identifies achievable, locally -based actions to reduce GHG emissions from municipal and community activities. Section 3.6, Greenhouse Gas Emissions provides more details on the CAP as it pertains to specific GHG reduction targets.

According to the CAP, energy use in the City includes electricity and natural gas consumption, which accounted for 39% of the City’s total emissions in 2012. Two strategies that would reduce emissions from electricity and natural gas consumption are increasing building energy efficiency and increasing the use of renewable energy sources. Legislative reductions from State energy efficiency and renewable energy programs will contribute to reducing transportation emissions by increasing the amount of renewable energy available statewide and improving energy efficiency requirements for new developments. At the local level, GHG emissions reductions would be achieved by improving energy efficiency of new developments beyond State requirements, both increasing the amount of renewable energy generated locally, and reducing the amount of non -renewable energy consumed locally. The success of these strategies relies on coordination with local utilities, organizations, and agencies, participation from the community, and administration of new or revised local policies and programs.

The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets. Strategies and measures related to energy include the following:
• Strategy 4: Increase Building Energy Efficiency . Electricity and natural gas consumption in buildings account for a majority of GHG emissions from the energy sector. Although legislative reductions related to State actions will help reduce emissions associated with building energy, additional reductions are achievable by increasing building efficiency in the City. This strategy aims to reduce emissions by reducing energy used by residential consumers through increased energy efficiency. This strategy includes one measure that would reduce the City’s emissions by approximately 1,280 metric tons of carbon dioxide equivalent (MTCO 2e) in 2030.
o Measure E-1: Require New Residential Developments to Install Alternatively-Fueled Water Heaters. Starting in 2022, require all new single-family and multi-family residential projects to install non -natural gas water heaters. Non -natural gas water heater op tions include electric heat pump water heaters, , instantaneous electric, electric tank solar water heater with HPWH backup, or solar water heater with electric tank backup • Strategy 5: Increase Renewable and Zero -Carbon Energy: Over a quarter of the City’s GHG emissions in 2012 were generated through the consumption of fossil fuels for the purpose of electricity generation (i.e., natural gas-fired or coal power plants). Transitioning from fossil fuels to renewable energy electricity generation will reduce emissions and provide a more sustainable source of electricity. The City would reduce emissions by increasing renewable energy generated loc ally and participating in a commun ity choice aggregation or similar program to increase the amount of grid supplied renewable energy. This strategy includes two

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measures that would reduce the City’s emissions by approximately 35,100 MTCO 2e in 2030.

Additional activities that would support this strategy would occur through partnerships with local and regional agencies.
o Measure E-2: Require Installation of PV systems at New Non -Residential Developments.

Starting in 2022, require all new non-residential developments to install PV systems with a minimum of two watts per square foot of gross floor area. o Measure E-3: Increase Grid-Supply Renewable and Zero-Carbon Electricity. Join a program to increase grid -supply renewables and zero -carbon electricity to 95% by 2030 with a maximum customer opt-out rate of 3%.

3.5.3 Thresholds of Significance
According to Appendix G of the State CEQA Guidelines, the proposed project would have a significant impact related to energy if it would:
• Threshold #1: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.
• Threshold #2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

3.5.4 Project Impact Analysis
Threshold #1: Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? The project proposes up to 165 multi-family residential units and 5,600 square feet (s.f.) of retail/ flex use within a five-story building situated on approximately 2.44 gross acres. Additionally, electric vehicle (EV) parking is incorporated in the project parking and includes 13 Level 2 EV spaces, 62 EV ready spaces, and 25 EV capable spaces9. The project seeks a General Plan Amendment and rezone of the project site from Public-Institutional (P-I) to Specific Plan Area (SPA).

The existing General Plan Land Use designation and zoning for the project site is Public Institutional (P-I). This use is typically used for any type of public use such as schools, hospitals, civic centers, and similar uses. The allowable use onsite per the zoning could have a maximum floor area ratio (FAR) of

3.0. Based on this, any facility which could be constructed onsite would be limited to approximately 318,000 s.f. The most likely alternative use for the project site d ue to its location adjacent to a telecommunications facility would be to construct a telecommunications data center, which would be consistent with the General Plan. Realistically, the site could be developed with a 160,000 s.f . data center or larger if multiple stories are constructed. Data centers are recognized as very high consumers of electrical energy. For example, a 413,000 s.f. data center in Santa Clara was found to consume 665,750 MWH or 1.61 MWH/SF/year and 410 daily vehicular trips (LDN 2024). Based on this, a 160,000 s.f. building would require at least 257,600 MWH annually.

9 EV Capable means the building is considered to have the necessary infrastructure to install an EV charging station. EV Ready goes beyond EV capability, establishing the installation of a central wiring system to support multiple charging stations for multiple EVs.

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The Energy Usage Letter prepared for the proposed project includes analysis of energy use during construction and operation of the proposed project as well as a comparison of energy use under the proposed project with energy use anticipated under the General Plan Buildout (Data Center) scenario (LDN 2024). As explained in more detail below, the Energy Usage Letter concluded that implementation of the proposed project would not result in wasteful, inefficient, or unnecessary impacts related to electricity, natural gas or petroleum during construction or operations and impacts would be
less than significant.

Construction
Construction of the proposed project is expected to occur over a 12 -month duration. Grading for the project will consist of approximately 6,950 cubic yards (CY) of cut material and 4,400 CY of fill material, requiring an export of approximately 2,250 CY of material once material shrinkage is considered. For the purposes of a conservative comparison, these construction assumptions are anticipated to be the same for the General Plan Buildout (Data Center) scenario.

Electricity
Temporary electric power usage during construction would stem primarily from electronic equipment, including electrically powered hand tools, lighting, computers and heating, ventilation, and air conditioning inside temporary construction trailers. Electricity used for construction activities would be temporary and would not be considered wasteful, inefficient, or unnecessary consumption of energy resources. Impacts related to electricity consumption during project construction are determined to be
less than significant.

Natural Gas
Natural gas is not anticipated to be required during construction of the proposed project. Any minor amounts of natural gas that may be consumed as a result of construction would be temporary and negligible and would not have an adverse effect on the environment; therefore, impacts would be less than significant.

Petroleum
The majority of the energy used during construction would be from petroleum. Energy usage for construction equipment is best estimated using total horsepower hours (HP -h) and an assumed thermal efficiency of 30%. The most common measure of the energy efficiency of a tractor is referred to as “specific volumetric fuel consumption” (SVFC), which is given in units of gallons per horsepower- hour (gal/hp-h.) SVFC for diesel engines was assumed to be 16.5 hp-h/gal (LDN 2024). Based on the equipment, quantity, work time, and hor sepower, the project would require a total of approximately 489,450 HP-h as shown in Table 3.5-2. Based on 16.5 hp-h/gal, the project would consume roughly 29,663 gallons of diesel for construction. Proper maintenance of all construction equipment per manufacturer recommendations is included as a project design feature.

Construction energy from workers, vendors and haulage are based on the estimated VMT for the total construction duration which is 493,141 miles for the proposed project. In California, the average fuel economy for on-road vehicles is 24.1 miles per gallon or 0.0415 gallon per mile. Based on this, the vehicular trips would consume roughly 20,465 gallons during construction (LDN 2024).

In total, construction of the project is estimated to consume a total of 50,128 gallons of petroleum from off-road equipment (29,663 gallons) and worker vehicle and vendor truck trips (20,465 gallons)

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during the construction phase. On -road vehicles are regulated by state and federal regulations and vehicular fleet efficiencies are improving each year. Additionally, all construction equipment shall be maintained as needed per manufacturer recommendations. The project would be required to comply with CARB’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. As noted above, for the purposes of a conservative comparison, these construction assumptions are ant icipated to be the same for the General Plan Buildout (Data Center) scenario.

Since the projected energy usage of the project and the General Plan Buildout (Data Center) scenario would be essentially the same, the project would not consume more energy than would otherwise be consumed through the construction of the General Plan Buil dout scenario. While construction activities would consume petroleum-based fuels, consumption of such resources would be temporary and would cease upon the completion of construc tion. Further, the petroleum consumed related to construction would be typical of construction projects of similar types and sizes and would not necessitate new petroleum resources beyond what are typically consumed in California. Therefore, because petroleum use during project construction would be temporary and minimal and would not be wasteful or inefficient, impacts related to energy use during construction would be less than significant.

Table 3.5-2. Proposed Construction Phase and Duration Equipment Equipment
Identification
Construction
Days
Quantity
per Day
Hours per
Day
Horsepower
(HP) Load Factor Horsepower
Hours (HP-h)
Site Preparation
Graders
3 1 8 148 0.41 1,456.32
Scrapers 1 8 423 0.48 4,872.96
Tractors/
Loaders/
Backhoes
1 7 84 0.37 652.68
Grading
Graders
20 1 8 148 0.41 9,708.80
Rubber Tired
Dozers 1 8 367 0.4 23,488.00
Tractors/
Loaders/
Backhoes
2 7 84 0.37 8,702.40
Crushing/
Processing
Equipment
1 6 310 0.41 15,252.00
Building Construction
Cranes
220
1 8 367 0.29 187,316.80
Forklifts 2 7 82 0.2 50,512.00
Generator Sets 1 8 14 0.74 18,233.60
Tractors/
Loaders/
Backhoes
1 6 84 0.37 41,025.60
Welders 3 8 46 0.45 109,296.00

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Equipment
Identification
Construction
Days
Quantity
per Day
Hours per
Day
Horsepower
(HP) Load Factor Horsepower
Hours (HP-h)
Paving
Pavers
10 1 8 84 0.37 2,486.40
Paving
Equipment 1 8 81 0.42 2,721.60
Rollers 1 8 89 0.36 2,563.20
Architectural Coating
Air Compressors 80 1 6 37 0.48 8,524.8
Total Horsepower Hours 489,449.96
Total Diesel Fuel (Gal) @ 16.5 hp-h/gal 29,663.63
Source: LDN 2024.

Notes: The equipment list is based upon equipment inventory and estimates within CalEEMod 2022.1.

Operations
Electricity
The operation of the project would require electricity for multiple purposes, including cooling, lighting, appliances, and various equipment. Additionally, the supply, conveyance, treatment, and distribution of water would indirectly result in electricity usage.

The electrical energy usage expected to be utilized by the project was compared to the General Plan Buildout scenario in Table 3.5-3. Based on the results, the project would consume 907,007 kilowatt hours (kWh) per year , which is 257,600,000 kWH (257,600 MWH) less than would be consumed under the General Plan Buildout (Data Center) scenario. California consumed 251,869,136 MWH of electricity in 2022 (EIA 2023b) and consumption is expected to increase as a result of electrification of the building and transp ortation sectors needed to meet ambitio us climate goals. To meet these goals, the State has created a multi -year plan to invest $54 billion in climate action including clean/renewable energy investments, expansion and reinforcement of the energy grid and increasing energy storage (CARB 2022). Reductions from Title 24 of the California Building Code (2019) were accounted for in the calculations and would improve the efficiency of the project in terms of energy consumption. The 2022 Title 24 standards have no t yet been included into CalEEMod 2022.1 but would essentially further reduce energy consumption. The project would also implement applicable City CAP measures that would reduce operational electricity consumption, but those measures were not included in the estimates provided in Table 3.5-3.

In summary, although electricity consumption would increase at the project site due to project implementation, the project would be required to comply with Title 24 and the City’s CAP by implementing energy-efficiency measures. Furthermore, the project wou ld be subject to the Title 24 building code that is adopted at the time building permits are obtained and thus may be subject to a more stringent energy standard than what was assumed herein. Additionally, the project would consume less electricity compare d to the General Plan Buildout (Data Center) scenario. For these reasons, electricity consumption of the project would not be considered inefficient, wasteful, or unnecessary, and impacts would be less than significant.

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Table 3.5-3. Annual Energy Use for Proposed Project and General Plan Buildout (Data Center) Scenario
Energy Source Proposed Project
General Plan Buildout
(Data Center)
Scenario
Difference
Natural Gas Usage (kBTU/Year) 1,192,176 0 1,192,176
Electrical Usage (kWH) 907,007 257,600,000 -256,692,993 Source: LDN 2024.

Notes: kBTU = One thousand British Thermal Units
kWH= Kilowatt Hours
Natural Gas
The natural gas usage expected to be utilized by the project was compared to the General Plan Buildout (Data Center) scenario in Table 3.5-3. Based on the results, the project would be expected to consume 1,192,176 thousand British thermal units (kBTU) per year when compared to the General Plan Buildout scenario. As previously discussed, the project would be subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code of Regulations. Prior to building permit application, the applicant would ensure that project plans would meet Title 24 requirements applicable at that time, as required by state regulations, through their plan review process. Additionally, the project would implement the City’s CAP measure that reduces operational natural gas consumption.

In the event the project decides to go all electric, if it is assumed that the equivalent energy would be required and converted the natural gas energy usage estimated by CalEEMod for each land use from kBTU/year to electrical energy usage (in kWh/year) using a standard conversion rate of 3.412 kBTU/kWh an additional 349,406 kWH would be required. This would mean the project would still require 256,343,587 kWH less than a data center. Since there is not a requirement to use all electric, the natural gas discussion will be the basis of this analysis.

In summary, although natural gas usage would increase due to project implementation compared to existing conditions and the General Plan Buildout (Data Center) scenario, project design features such as installing electric heat pump water heaters within all residential units rather than natural gas water heaters would be implemented, and usage would be decreased through green building standards. For these reasons, the natural gas consumption of the project would not be considered inefficient or wasteful, and impacts would be less than significant.

Petroleum
Vehicle travel to and from the project site would be the largest contributor to petroleum use. The project would generate 1,214 average daily trips (ADT) (LLG 2024). Data centers do not generate many vehicular trips. A 161,000 s.f. data center could generate approximately 161 trips per day, which is 1,053 fewer ADT than the proposed project. Over the lifetime of the proposed project, the fuel efficiency of the vehicles being used by residents is expected to increase. As RPS increases and as electric vehicle operations become more standardized, energy consumption and efficiency will decrease. Additionally, EV parking is incorporated in the project parking plan and includes 13 Level 2 EV spaces, 62 EV ready spaces, and 25 EV capable spaces. As such, the amount of petroleum consumed as a result of vehicular trips to and from the project site during operation would decrease over time.

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In summary, although the project would increase petroleum use during operation compared to existing conditions and the General Plan Buildout (Data Center) scenario, the use would be a small fraction of the annual statewide use (605 million barrels in 2021) and due to efficiency increases, would diminish over time. Given these considerations, the petroleum consumption associated with the project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, and impacts would be
less than significant.

Threshold #2: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Construction
The majority of the energy used during construction would be from petroleum. On-road vehicles are regulated by state and federal regulations , and vehicular fleet efficiencies are improving each year.

Additionally, all construction equipment shall be maintained as needed per manufacturer recommendations. The project would be required to comply with CARB’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. Additionally, the project’s consistency with applicable General Plan goals and policies is discussed in Table 3.7-7 of Section 3.7, Land Use. As detailed in Section 3.7.4, the project is consistent with the applicable General Plan goals and policies pertaining to energy. Therefore, the proposed project would not obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

Operation
Section 3.5.2 includes a description of all the federal, state, and local policies and programs that the project would be required to comply with. The proposed project would follow applicable energy standards and regulations during the construction phases. The proposed project would be built and operated in accordance with all existing, applicable building regulations at the time of construction, including Title 24 Building Standards, Building Energy Efficiency Standards (Energy Code), and California Green Building Standards. Furthermore, the proposed project would be consistent with all actions in the CAP Consistency Review Checklist, many of which reduce the usage of non -renewable energy, as discussed in detail in Section 3.7, Greenhouse Gas Emissions, and Appendix E of this EIR.

Table 3.5-4 describes the CAP measures that are applicable to a multi -family residential project and how the proposed project w ould comply. As shown, the project provides electric vehicle parking, including 13 spaces with Level 2 EV chargers, 25 EV capable spaces and 62 EV ready spaces, which will help meet state goals toward carbon neutrality and elimination of new internal combustion passenger vehicles. Additionally, the project’s consistency with applicable General Plan goals and policies is discussed in Table 3.7-7 of Section 3.7, Land Use. As detailed in Section 3.7.4, the project is consistent with the applicable General Plan goals and policies pertaining to energy. For the reasons stated, the proposed project would not obstruc t a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

Table 3.5-4. Project Consistency with Applicable CAP Checklist Measures CAP Consistency Checklist Measures Project Compliance
Electric Vehicle Charging Stations (Measure T-2)
Will the project install electric vehicle charging
stations (Level 2 or better) in at least five percent of the total parking space provided on-site?
The project proposes a total of 254 on-site parking
spaces including 13 Level 2 EV spaces, 62 EV ready
spaces, and 25 EV capable spaces. The project has
been designed to meet the requirements of Measure
T-2.

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

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

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

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

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

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

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

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

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

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

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

The project has been designed to meet Measure E-2.

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

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

3.5.5 Cumulative Impact Analysis
Potential cumulative impacts on energy would result if the proposed project, in combination with past, present, and future projects, would result in the wasteful or inefficient use of energy. This could result from development that would not incorporate sufficient building energy efficiency features, would not achieve building energy efficiency standards, or would result in the unnecessary use of energy during construction and/or operation. The cumulative projects within the areas serviced by the energy service providers would be applicable to this analysis; this includes existing aging structures that are energy inefficient. Projects that include development of large buildings or other structures that would have the potential to consume energy in an ineffic ient manner would have the potential to contribute to a cumulative impact. Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use.

As described previously, the proposed project would not result in significant environmental impacts due to wasteful, inefficient, or unnecessary use of energy due to various design features and adherence to applicable requirements. Similar to the proposed project, the cumulative projects would be subject to CALGreen, which provides energy efficiency standards for commercial and residential buildings. CALGreen would implement increasingly stringent energy efficiency standards that would require the proposed project and the cumulative projects to minimize the wasteful and inefficient use of energy. In addition, cumulative projects would be required to meet or exceed the Title 24 building standards, further reducing the inefficient use of energy. Future development would also be required to meet even more stringent requirements, including the objectives set in the AB 32 Scoping Plan.

Furthermore, various federal and state regulations, including the Low Carbon Fuel Standard, Advanced Clean Cars Program and Clean Miles Standard would serve to reduce the transportation fuel demand of cumulative projects. In consideration of cumulative energy use, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. Thus, the proposed project would not contribute to a cumulative impact to the wasteful or inefficient use of energy. As such, the proposed project would not result in a cumulatively considerable contribution to a potential cumulative impact.

Impacts are less than significant.

3.5.6 Mitigation Measures
Impacts would be less than significant, and no mitigation measures are required.

3.5.7 Conclusion
The Energy Usage Letter prepared by LDN (2024) included a comparative analysis of energy use that would be consumed by the proposed project and the General Plan Buildout (Data Center) scenario.

The analysis demonstrated that energy use during construction would be temporary and minimal and would likely be the same under either land use scenario. The proposed project would comply with

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regulatory requirements and building standards as well as ensuring that all construction equipment is maintained per manufacturer’s specifications. As such, the proposed project would not result in the wasteful or inefficient use of electricity, and impacts would be less than significant.

The analysis concluded that while operations of the proposed project would consume more natural gas and petroleum at the project site under existing conditions and under the General Plan Buildout (Data Center) scenario, the project would be required to com ply with Title 24 and the City’s CAP by implementing energy efficiency measures, along with provision of EV chargers, EV capable spaces and EV ready spaces. Additionally, the project would use much less electricity when compared to the General Plan Buildout (Data Center) scenario. For these reasons, energy consumption of the project would not be considered inefficient, wasteful, or unnecessary, and impacts would be less than
significant.

The proposed project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing energy consumption, including the City’s General Plan policies. As a result, impacts would be
less than significant.

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3.6 Greenhouse Gas Emissions
Introduction
This section analyzes the potential for the proposed project to have impacts related to greenhouse gas (GHG) emissions. This section analyzes short -term construction impacts and long -term operational impacts and determines whether the proposed project woul d conform to the City of San Marcos Climate Action Plan (CAP). This section is based upon the following report, which is included as Appendix E of the Environmental Impact report (EIR)10:
• Greenhouse Gas Assessment, Armorlite Lofts Residential Development, prepared by LDN Consulting, November 4, 2024 (LDN 2024)
The project’s Climate Action Plan Consistency Review Checklist (CAP Checklist) is included as Appendix G. A discussion of the project’s consistency with the requirements of the CAP Checklist is provided later in this section. The CAP is available on the City’s web site.11 Table 3.6-1 summarizes the project- and cumulative-level GHG impacts, by threshold.

Table 3.6-1. Greenhouse Gas Emissions Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 - Generate greenhouse gas emissions,
either directly or indirectly, that may have
a significant impact on the environment.

Less than Significant Less than
Significant
Less than
Significant Without
Mitigation
#2 - Conflict with an applicable plan,
policy, or regulation adopted for the
purpose of reducing the emissions of
greenhouse gases.

Less than Significant Less than
Significant
Less than
Significant Without
Mitigation

3.6.1 Existing Conditions
Global Climate Change
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth's temperature depends on the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun’s energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere.

The greenhouse effect is the trapping and build-up of heat in the atmosphere near the Earth’s surface.

This natural process contributes to regulating the Earth’s temperature and creates a pleasant, livable environment on the Earth. Human activities that em it additional GHGs into the atmosphere increase

10 Full references for documents cited in this section are included in Chapter 7, References, of this EIR. 11 http://www.san-marcos.net/departments/development-services/planning/climate-action-plan

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the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect, and causing the Earth’s surface temperature to rise.

A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere and contribute to the greenhouse effect. GHGs include, but are not limited to, carbon dioxide (CO
2), methane (CH4), nitrous oxide (N2O), ozone (O3), water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6). Some GHGs, such as CO2, CH4, and N2O, occur naturally and are emitted to the atmosphere through natural processes an d human activities. To simplify greenhouse gas calculations, both CH 4 and N 2O are converted to an equivalent amount of carbon dioxide, or CO 2e. CO2e is calculated by multiplying the calculated levels of CH4 and N2O by a Global Warming Potential (GWP). GWPs for both CH4 and N2 are presented within the 2007 Intergovernmental Panel on Climate Change (IPCC) report as being 25 and 298, respectively (IPCC 2007)12.

A brief description of each GHG relevant to the proposed project follows (LDN 2024):

Carbon Dioxide. CO2 is widely reported as the most important anthropogenic greenhouse gas because it currently accounts for the greatest portion of the warming associated with human activities. Carbon dioxide occurs naturally as part of the global carbon cycle, but human act ivities have increased atmospheric loadings through combustion of fossil fuels and other emissions sources. Natural sinks that remove carbon dioxide from the atmosphere (e.g., oceans, plants) help regulate carbon dioxide concentrations, but human activities can disturb these processes (e.g., deforestation) or enhance them
Methane. CH
4 comes from many sources, including human activities such as coal mining, natural gas production and distribution, waste decomposition in landfills, and digestive processes in livestock and agriculture. Natural sources of methane include wetlands and termite mounds.

Nitrous Oxide. N
2O is emitted during agricultural and industrial activities, as well as during combustion of solid waste and fossil fuels.

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

Federal
The United States Environmental Protection Agency (USEPA) is the federal agency responsible for implementing the federal Clean Air Act (CAA). The Supreme Court of the United States ruled on April 2, 2007, that CO
2 is an air pollutant as defined under the CAA, and that USEPA has the authority to regulate emissions of GHGs.

12 The IPCC 2007 report was updated in 2021 and now recommends adding a 100- year timeline to the GWP discussions (GWP-100). For CH4 the GWP is between 27-30 and the GWP for N2O is 273 (USEPA 2023).

Since CalEEMod is the adopted computer model for calculating GHGs, the earlier GWPs within CalEEMod were utilized.

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Proposed Endangerment and Cause or Contribute Findings for GHG under the CAA On December 7, 2009, USEPA signed two distinct findings regarding GHGs under section 202(a) of the CAA:
• Endangerment Finding: The Administrator finds that the current and projected concentrations of the six key well -mixed GHGs —carbon dioxide (CO
2), methane (CH 4), nitrous oxide (N 2O),
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6)—in the atmosphere threaten the public health and welfare of current and future generations; and • Cause or Contribute Finding: The Administrator finds that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution which threatens public health and welfare. These findings do not themselves impose any requirements on industry or other entities; however, this action is a prerequisite to finalizing USEPA’s proposed GHG emission standards for light -duty vehicles, which USEPA proposed in a joint proposal including the Department of Tr ansportation's (DOT) proposed Corporate Average Fuel Economy (CAFE) standards on September 15, 2009.