Wastewater
Cumulative projects that are within the VWD service area for wastewater services would contribute to the cumulative demand for wastewater services. VWD anticipates the demand of future development through their master planning process. Cumulative projects that are consistent with the land use assumptions made in VWD’s Master Plan would have already had their demand accounted for.
As discussed in Section 3.13. 4 above, VWD has sufficient capacity at this time to account for the proposed project’s estimated increase in wastewater generation. However, VWD identified existing system deficiencies in sewer pipe segments W -8 and W-9, as well as in capacity for solids h andling, liquids handling, ocean disposal and parallel land outfall’s capacity for ultimate build-out wastewater flows. The cumulative projects that result in an increase in density or development over what was accounted for in VWD’s Master Plan would further exacerbate these deficiencies. Per VWD, payment
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of Wastewater Capital Facility fees would go toward projects identified in their 2018 Master Plan including upsizing applicable pipelines and design and construction of a parallel land outfall (VWD 2023). The project applicant for the proposed project and for cumulative projects would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations, which would be utilized to fund the identified projects in the 2018 Master Plan. Thus, with payment of all applicable Wastewater Capital Facility fees to VWD, cumulative impacts to wastewater treatment facilities would be less than significant.
Electrical Power and Natural Gas
Potential cumulative impacts related to energy and natural gas infrastructure would result if the project, in combination with past, present, and future projects, would require or result in the relocation or construction of new or expanded electric power or natural gas facilities, the construction or relocation of which could cause significant environmental effects.
As described in Section 3.13.4, above, the proposed project would have a less than significant impact related to energy and natural gas. Each of the cumulative projects identified in Table 2 -4 would be within the service area of SDG&E. Each of the cumulative projects would be required to analyze their potential for impacts related to the provision of electricity and natural gas services, including the need for new or expanded utility infrastruc ture, and would be required to mitigate potential impacts from expanded infrastructure to below a level of significance. Cumulative projects are also required to comply with the state’s energy efficiency standards and local regulations. Additionally, SDG&E regularly undertakes upgrades and expansions, as needed, throughout their service area to continue to provide reliable electricity and natural service. SDG&E conducts their own CEQA review on these projects. In conclusion, cumulative impacts related to the provision of electrical power and natural gas would be
less than significant.
Solid Waste
Future development projects would generate solid waste to be disposed of at the Sycamore Sanitary Landfill. According to CalRecycle, the facility has a daily permitted capacity of 5,000 tons/day for solid waste (expected to increase to 7,000 tons per day i n 2025, and 9,000 tons per day in 2027). As of February 2021, remaining capacity was 105,064,991 cubic yards or approximately 86 million tons with an anticipated closure date of 2042, likely to be revised and extended to 2054 (County of San Diego 2022). Further, there are five other landfills in the County. This includes Borrego Landfill, with a remaining capacity of 88,750 cy and a closure date of 2046; Miramar Landfill, with a remaining capacity of 11,080,871 cy and a closure date of 2031); Otay Landfill, with a remaining capacity of 11,122,997 cy and closure date of 2030, and two US Marine Corps landfills – Las Pulgas and San Onofre, with remaining capacities of 5,657,717 and 1,057,605 cy and 2060 and 2031 closure dates respectively (County of San Diego 2022).
The proposed project and cumulative projects include 3,085 residential units, approximately 211,600 s.f. of commercial, 555,000 s.f. of office and 104,000 s.f. of industrial. When the CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019b) are applied to the proposed project and the cumulative projects, the total solid waste anticipated to be generated is 48,088 pounds per day (lbs/day) or 24.04 tons/day. This is prior to any diversion from mandatory recycling and green waste/organics program. Assuming a 75% diversion rate, as required by AB 341, the net solid waste generation would be approximately 6.01 tons/day. The Sycamore Sanitary Landfill has a daily permitted capacity of 5,000 tons/day, which is expected to increase to 7,000 tons/day in 2025 and
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9,000 tons/day in 2027. The cumulative projects would result in incremental contribution to the landfill capacity; however, the impact would be less than significant.
3.13.6 Mitigation Measures
Impacts would be less than significant, so no mitigation measures are required.
3.13.7 Conclusion
Development of the proposed project would result in an incremental increase in the need for water, wastewater, stormwater, energy, and solid waste services. However, as outlined in the project impact analysis above, it is determined that water, wastewater, stormwater, energy, and solid waste services would be adequate and
project- and cumulative-level impacts would be less than significant.
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4.1 Introduction to Alternatives
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that an Environmental Impact Report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.”
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6(a) of the CEQA Guidelines).
In developing the alternatives to be addressed in the EIR, the potential alternatives were evaluated in terms of their ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the project identified in Section 3.0, Environmental Analysis, of the EIR.
In determining what alternatives should be considered in an EIR, it is important to acknowledge the objectives of the project, the project’s significant effects, and unique project considerations. These factors are important to the development of alternatives that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs must contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether an alternative is feasible or infeasible is made by the lead agency’s decision‐making body, the San Marcos City Council (see Public Resources Code Section 21081[a] [3]).
4.2 Project Objectives
The following project objectives describe the purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in the EIR:
• Provide multi -family housing opportunities close to major transit, education al facilities, shopping opportunities, employment uses, and trails to optimize alternative mode s of transportation, reduce reliance on automobiles, and potentially reduce greenhouse gas emissions.
• To the extent possible given site constraints, maximize the opportunity to provide housing for the City of San Marcos in the 4.1 to 8.0 dwelling unit density range which is comparable to low- density housing developments in the City of San Marcos. • Cluster development to lessen site impacts and minimize landform modification. • Develop high-quality attainable housing which meets the housing needs of the City of San Marcos and the region.
• Create a development that promotes a high -quality-of-life by providing each dwelling unit its own private patio/yard space and by providing a common recreational open space gathering area.
• Establish development standards and design guidelines that ensure distinctive architecture, landscaping and recreational amenities that complements and enhances the existing
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surrounding neighborhood while providing a desirable living environment for residents within the Specific Plan Area.
• 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 Specific Plan development to promote economic stability.
4.3 Project Alternatives Considered in This EIR
4.3.1 Description of Alternative
The following alternatives are under consideration for this project:
• No Project/No Development Alternative (Section 4.3.3) • No Project/ Existing Plan Alternative (Section 4.3.4) • Reduced Density Alternative (Section 4.3.5)
Alternatives considered and removed from further consideration are summarized in Section 4.4.
4.3.2 Summary of Impacts
Project- and cumulative-level impacts associated with implementation of the proposed project are evaluated in Sections 3.1, Aesthetics, through 3.13, Utilities and Service Systems, of the EIR. As identified in Table 1 -1, in Chapter 1, Executive Summary, co nstruction and/or operation of the proposed project would have the potential to cause the following significant but mitigable environmental impacts:
• Impact BIO-1: The proposed project has the potential to result in direct and indirect impacts to coastal California gnatcatcher.
• Impact BIO-2: Focused surveys found the Diegan Coastal Sage Scrub on site to be occupied by Crotch’s bumble bee. Thus, there is potential for “take” of Crotch’s bumble bee and adverse impacts may occur through the removal of occupied habitat. • Impact BIO -3: The project has the potential to result in direct and indirect impact s to special-status wildlife species including Orange -throated whiptail, coastal whiptail, Southern California rufous -crowned sparrow, Cooper’s hawk, Crotch’s bumble bee, and Bryant’s woodrat.
• Impact BIO-4: The project has the potential to impact nesting birds and raptors that are afforded protection under the California Fish and Game Code and the Migratory Bird Treaty Act.
• Impact BIO -5: The proposed project has the potential to result in indirect impacts to sensitive species due to urban run-off, introduction of meso-predators (e.g., dogs and cats), invasive plant species, and noise and lighting effects. • Impact BIO-6: The proposed project would impact 5.24 acres of Diegan coastal sage scrub and 0.26 acres of disturbed Diegan coastal sage scrub for a total of 5.50 acres of impact.
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• Impact CR-1: Due to grading and ground disturbing activities, the proposed project has the potential to impact unidentified archeological resources on the project site. • Impact CR-2: There is a potential for project construction activities to disturb previously unidentified human remains on the project site.
• Impact N-1: Due to temporary rock drilling and blasting activities during construction, the proposed project has the potential to create noise levels in excess of the 75 dBA standard if rock drilling equipment is staged closer than 160 feet to the nearest property line. • Impact N -2: Due to temporary rock crushing activities, the proposed project has the potential to create noise levels in excess of the exterior daytime standards for single family residential use (60 dBA Leq) and multi -family residential use (65 dBA Leq) if the rock crusher is staged within 400 feet of a single-family residential use. • Impact TCR-1: As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource that is determined, by the City, based on substantial evidence, to be a tribal cultural resource.
All project impacts would be mitigated to below a level of significance.
4.3.2.1 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, disturbed Diegan coastal sage scrub, disturbed habitat, and urban/developed areas (Rincon 2025).
4.3.2.2 Comparison of the Effects of the No Project/No Development Alternative to the Proposed Project
Aesthetics
Under this alternative the project site would remain in its current condition. No grading would occur and no vegetation would be removed. The visual character of the site would not change. The project site is undeveloped and steeply sloped. Elevation ranges from 754 feet above mean sea level in the eastern portion of the project site down to 615 feet in the southwestern portion of the project site. The project site supports Diegan coastal sage scrub, disturbed Diegan coastal sage scrub, disturbed habitat, and urban/developed areas (Rincon 2025). This alternative would not add additional sources of lighting to the project site and vicinity. Compared to the proposed project, this alternative would reduce impacts. No aesthetics impacts would occur under the No Project/No Development Alternative.
Air Quality
Under the No Project/No Development Alternative, air emissions associated with project construction including emissions associated with grading, blasting and rock crushing, site preparation, site finishing and building finishing would not occur. Implementation of this alternative would not introduce any uses that could generate operational air emissions. This alternative would not result in any construction or operational air pollutant emissions. As discussed in Section 3.2.4, impacts to air quality for the
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proposed project would be less than significant and no mitigation would be required. Compared to the proposed project, this alternative would reduce air pollutant emissions. No air quality impacts would occur under the No Project/No Development Alternative.
Biological Resources
The No Project/No Development Alternative would not require any ground -disturbing activities, nor would it include development of the project site. This alternative would avoid potential impacts to coastal California gnatcatcher (Impact BIO-1), Crotch’s bumble bee (Impact BIO-2), other special-status wildlife species and nesting birds (Impact BIO -3 and Impact BIO -4), indirect impact s to sensitive species (Impact BIO -5) and impact to Diegan coastal sage scrub (Impact BIO -6). Since impacts to biological resources would be avoided under the No Project/No Development Alternative, mitigation measures MM -BIO-1 through MM -BIO-6 would not be implemented or required. Compared to the proposed project, this alternative would eliminate the potential biological resources impacts. No biological resources impacts would occur under the No Project/No Development Alternative.
Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.
Therefore, there would be no potential to impact unknown archaeological resources potentially located within the project site (Impact CR -1). Further, there would be no potential to disturb previously unidentified human remains that may be present on the project site (Impact CR-2). As such, mitigation measures MM-CR-1 and MM-CR-2 would not be implemented or required. Compared to the proposed project, the No Project/No Development Alternative would eliminate potential cultural resources impacts. N o impacts to cultural resources would occur under the No Project/No Development Alternative.
Energy
Under the No Project/No Development Alternative, there would be no energy use associated with construction and operation, since no development would occur. While impacts under the proposed project related to energy use were determined to be less than signi ficant, they would be eliminated under this alternative since there would be no energy use. Compared to the proposed project, the No Project/No Development Alternative would eliminate the energy use identified for the project and there would be no energy impacts.
Geology and Soils
Under the No Project/No Development Alternative, the project site would remain in its current state.
Existing topography and on-site soils would not be modified to accommodate proposed development.
While geology and soils impacts were determined to be less than significant for the project, this alternative would eliminate any geology and soils impacts. No geology and soils impacts would occur under this alternative. Compared to the proposed project, the No Project/No Development Alternative would reduce potential impacts related to geology and soils.
Hydrology and Water Quality
Under the No Project/No Development Alternative, no development would occur, and no impervious surfaces would be created. The existing on-site hydrologic conditions, drainage patterns, and drainage volumes would remain unaltered. Water quality would also r emain unchanged. While the proposed project’s hydrology and water quality impacts were determined to be less than significant, this
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alternative would further minimize potential impacts related to hydrology and water quality, and no impact would occur.
Land Use and Planning
Under this alternative, the project site would remain undeveloped and none of the discretionary approvals identified for the project would be required, including the Specific Plan Amendment, adoption of the new Woodward 46 Specific Plan, General Plan Amendment, Site Development Plan, Tentative Subdivision Map and Conditional Use Permit . While the proposed project’s land use and planning impacts were determined to be less than significant, the No Project/ No Development would further minimize potential impacts related to land use and planning, and no impact would occur.
Noise
The project site is currently vacant and does not generate any noise. Under the No Project/No Development Alternative, the project site would remain undeveloped and would not create any new sources of construction or operational noise and vibration . As detailed in Section 3.9, Noise, the project has the potential for construction-related noise impacts due to rock drilling and rock crushing activities. Under this alternative, the potential for noise impacts would be eliminated since no blasting or rock crushing activities would occur. As such, noise impacts under this alternative would be reduced as compared to the proposed project.
Public Services
The No Project/No Development Alternative would not result in an increase in demand for public services, since no residential uses would be developed and there would be no increase in the City’s population. Specifically, the No Project/No Development Alter native would not increase the demand for police and fire protection services, nor would this alternative increase demand for park, school, and library services. As stated in Section 3.10, Public Services, public service impacts for the proposed project would be less than significant. Since this alternative would not result in additional residents on site, impacts on public services would be reduced, compared to the proposed project. No public services impacts would occur under the No Project/No Development Alternative.
Transportation
The No Project/No Development Alternative would not result in the generation of vehicular trips. Under this alternative the minimum 50-foot southbound left-turn pocket on Woodward Street would not be constructed. While the proposed project would have less than significant transportation impacts, this alternative would have no impact related to transportation.
Tribal Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.
Therefore, there would be no potential to impact tribal cultural resources (Impact TCR -1). As such, mitigation measures MM-TCR-1 through MM-TCR-12 would not be implemented or required. No impact would occur, and compared to the proposed project, the No Project/No Development Alternative would result in a reduced level of potential impact to tribal cultural resources.
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Utilities and Service Systems
No development would be constructed under the No Project/No Development Alternative. As such, there would be no increase in demand for water service, wastewater service, stormwater capacity, energy, and solid waste handling services. As discussed in Section 3.13.4, Utilities, project impacts related to utilities and service systems were determined to be less than significant. Because no development would occur under this alternative, the demand for utilities would be eliminated.
Additionally, the sewer line extension within Woodward Street that is required to serve the project would not be needed under this alternative. Thus, impacts to utilities and service systems would be reduced compared to the proposed project. No utilities and service system impacts would occur for the No Project/No Development Alternative.
Conclusion
Since the No Project/No Development Alternative would not develop any residential 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 would not be re alized under this alternative, including providing additional housing units in the City which helps the City meet its Regional Housing Need Allocation numbers. Under this alternative there would not be any payment of the City’s Public Facilities Fees (PFF), which goes toward supporting a variety of services and improvements in the City, including but not limited to Circulation Streets, State Route 78 Interchanges, National Pollutant Discharge Elimination System, Tech Improvements, Parks, and Habitat Conservation. Payment of these fees provide improvements that benefit all residents of the city. Similarly, this alternative would not contribute any school fees. Finally, this alternative would not meet any of the project objectives ( Table
4-1).
4.3.3 No Project/Existing Plan Alternative
Typically, under a No Project/Existing Plan Alternative, the project site would be developed consistent with the site’s existing land use designation. The project site has a General Plan Designation of SPA (Specific Plan Area) and is associated with the Heart of the City Spe cific Plan (HOCSP). The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Mission Road corridor, including the project site, have a sub -plan designation of Richmar Specific Plan. Prio r to the site’s inclusion under the Richmar sub -plan, the underlying designation for the property was Single-Family Detached 2 to 4 du/ac per the HOCSP.
Development criteria for the Richmar Specific Plan have not been adopted by the City and there is no current City effort to do so. Therefore, properties requesting development within this sub-plan area are required to establish individual specific plans. As such, there is no fixed land use or density currently assigned to the project site. The Richmar Specific Plan identifies commercial, office and multifamily residential as land use options within the Richmar planning area.
Due to its location and the adjacent residential land uses, a multifamily residential development, under a Specific Plan, is the most suitable land use for the subject property. City policy requires that a secondary access be provided if more than 50 units are proposed. Given the topographical constraints of the site and the adjacent residential land uses, multifamily residential land use is assumed as the existing land use for this analysis. The project site would not be suitable for commercial or office development given the site topography and adjacent uses. It is also assumed that a maximum of 50 multifamily residential units could be built on the site given the topographical constraints and the lack
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of availability of a secondary/emergency vehicle access point. Under this scenario the site would have a density of 5.9 du/acre and a Specific Plan would be required.
The overall footprint of development for the 50 units (25 buildings with two units each) is assumed to be the same as the proposed project. The units would still be duplexes; however , the units would be smaller. Building heights would be up to 45 feet. Site access would be similar to the proposed project and would be via a driveway from Woodward Street. Grading, blasting and rock crushing as well as fire fuel modification would be required for this alternative.
4.3.3.1 Comparison of the Effects of the No Project/Existing Plan Alternative to the Proposed Project
Aesthetics
The No Project/Existing Plan Alternative would develop 25 two-unit buildings. The site would be modified through grading and retaining wall construction to allow for the access driveway and building pads. Building heights would be maximum of 45 feet. Similar to the proposed project, a Specific Plan would be prepared to establish the development rules and regulations of the land uses under this alternative. Similar to the proposed project, architectural treatments would be used to break up the bulk and scale of the buildings and add visual interest. Enhanced architectural treatments for highly visible buildings would also be incorporated. A landscape concept plan would also be implemented.
Similar to the proposed project, this alternative would incorporate lighting for safety, security and way finding. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. The No Project/Existing Plan Alternative would have a similar level of aesthetics impact as the proposed project and those impacts would be less than significant.
Air Quality
Under the No Project/Existing Plan Alternative, air pollutant emissions associated with project construction including emissions associated with grading, blasting, rock crushing, site preparation, site finishing and building finishing would still occur. Since 25 buildings would be constructed (versus 23 with the proposed project), there would be more emissions associated with construction and architectural coatings under this alternative. Grading activities would be similar to the proposed project since a similar footprint for development is assumed.
Emissions from vehicles going to and from the project site typically account for the largest portion of air quality emissions. Vehicular trips under the No Project/ Existing Plan Alternative would be slightly higher than the proposed project. This alternative would generate approximately 400 average daily trips (ADT) compared to the 368 ADT anticipated for the project, an approximate 9% increase. As such, because this alternative would result in an increase of ADT on site, operational air pollutant emissions would be slightly increased when compared to the proposed project. Operational and construction air pollutant emissions under this alternative would still be less than significant. Similar to the proposed project, impacts related to odors would be less than significant under this alternative. Overall, the No Project/Existing Plan Alternative would increase air quality emissions during both project construction and operation compared to the proposed project, but impacts would continue to be less than significant.
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Biological Resources
Since it would have a similar footprint of disturbance, the No Project/Existing Plan Alternative would have a similar level of biological resources impacts as the proposed project, including potential impacts to coastal California gnatcatcher (Impact BIO -1), Crotch’s bumble bee (Impact BIO -2), other special-status wildlife species and nesting birds (Impact BIO-3 and Impact BIO-4), indirect impacts to sensitive species (Impact BIO-5) and impacts to Diegan coastal sage scrub (Impact BIO-6). Mitigation measures MM-BIO-1 through MM-BIO-6 would still be required under this alternative. Compared to the proposed project, this alternative would result in a similar level of biological resources impacts.
Cultural Resources
The No Project/Existing Plan Alternative would require a similar level of grading as the development footprint would be similar as the proposed project. Therefore, the potential to impact unknown archaeological resources or unidentified humans remains potentially located within the project site would be similar. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1 and MM-CR-2) and would reduce the impacts to below a level of significance. The No Project/Existing Plan Alternative would have a similar level of cultural resources impacts as the proposed project.
Energy
Construction of the No Project/Existing Plan Alternative would include a similar amount of grading and soil hauling as the proposed project. Therefore, construction -related energy use would be similar to that of the proposed project. Operationally, the pro ject would require slightly more energy use since the number of residential units would be slightly increased (50 units vs 46 units) . Additionally, since this alternative would generate slightly more ADT compared to the proposed project, fuel use would also be slightly increased under this alternative. Similar to the proposed project, this alternative would incorporate energy conservation features consistent with the requirements of Title 24 and would not result in the wasteful or inefficient use of energy or a conflict with a state or local plan for energy efficiency. Compared to the proposed project, energy demand would be slightly greater with the No Project/Existing Plan Alternative, but impacts would continue to be less than significant.
Geology and Soils
Under the No Project/Existing Plan Alternative ground -disturbance would be required for the construction of the residential units. Development under this alternative would be required to implement the recommendations from the preliminary geotechnical inves tigation (GeoTek 2019).
These recommendations include general provisions related to earthwork, and design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, an d post -construction considerations. Compliance with the recommendations of the preliminary geotechnical investigation would ensure that seismic and soils hazards would be addressed through project design and impacts related to geological and soils hazards would be less than significant, similar to the proposed project. The No Project/Existing Plan Alternative would have a similar level of geology and soils impacts as the proposed project.
Hydrology and Water Quality
The No Project/Existing Plan Alternative would introduce impervious surfaces at the site in a similar quantity as the proposed project and the existing on-site hydrologic conditions, drainage patterns, and drainage volumes would be similarly modified. It is expected that this alternative would incorporate all
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required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adversely affect surface and groundwater quality, similar to the proposed project. As compared to the proposed project, this alternative would result in similar impacts and the impacts would be less than significant.
Land Use and Planning
Under the No Project/Existing Plan Alternative, the same list of project approvals would be required, including a Specific Plan Amendment to modify the HOCSP to remove the current Richmar Sub -Plan designation on the project, a new Specific Plan to establis h the development rules for the site, a General Plan Amendment to remove the Richmar Sub -Plan designation from the project site, a Site Development Plan, Tentative Subdivision Map and a Conditional Use Permit for a temporary rock crusher.
Development under this alternative would generate more traffic (400 ADT compared to 368 ADT) than the proposed project. The proposed project did not have any inconsistencies with the City’s Mobility Element goal related to level of service (LOS). While this alternative would generate slightly more ADT, it is not anticipated to have any LOS-related issues. Development under this alternative would still be required to participate in Community Facility District: CFD2011 -01 (Congestion Management). This alternative would have a similar level of impact as the proposed project, which is less than significant.
Noise
Grading-related noise under the No Project/Existing Plan Alternative would be similar to the proposed project, since grading activities would still be required, and similar types of equipment would be used.
Noise related to building construction would be similar to the proposed project but would last for a longer duration since two additional buildings would be constructed. The potential for significant impacts related to rock drilling and rock crushing would still be expected under this alternative and implementation of mitigation measures MM -N-1 and MM -N-2 would still be required. Similar to the proposed project, construction noise impacts would be reduced to below a level of significance with implementation of mitigation.
The No Project/Existing Plan Alternative would generate operational noise from residential activities as well as vehicle trips generated by the project. This alternative would generate slightly more ADT than the project ( 400 ADT compared to 368 ADT). Therefore, offsite noise generated by the project would be slightly increased under this alternative compared to the proposed project. Compared to the proposed project, this alternative would generate more noise during construction and operation; however, similar to the proposed project noise impacts would be reduced to below a level of significance with mitigation.
Public Services
Similar to the proposed project, the No Project/Existing Plan Alternative would result in an increase in demand for public services, due to the construction of residential uses. Specifically, this alternative would increase the demand for police and fire protection services over existing conditions. Residential uses are the primary driver for demand for park, library, and school services. This project would increase the amount of residential development by approximately 9% (50 units instead of 46 units), which results in a proportional in crease in the need for services. Development under this alternative would still be required to pay applicable PFF and school fees and participate in community facility districts for fire and police. Compared to the proposed project, this alternative would result in a slightly
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increased demand for fire and police services and increased demand for park, library and school services. Overall, similar to the proposed project, impacts to public services would be less than significant.
Transportation
Under the No Project/Existing Plan Alternative, impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are still anticipated to be less than significant. Development under this scenario would still be required to construct a minimum 50-foot southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane. This alternative would still be required to construct a sidewalk along the project acce ss driveway to connect the development with existing pedestrian infrastructure on Woodward Street. With regard to Vehicle Miles Traveled (VMT), it is assumed that development under this alternative would be screened out of needing further analysis, similar to the proposed project .
Overall, this alternative would generate slightly more VMT since four more residential units would be constructed. The No Project/Existing Plan Alternative would have a slightly increased level of transportation impacts as the proposed project, and those impacts would be less than significant.
Tribal Cultural Resources
The No Project/Existing Plan Alternative would require a similar level of grading as the development footprint would be similar to the proposed project. Therefore, the potential to impact tribal cultural resources would still occur under this alternative . Tribal c ultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM - TCR-1 through MM -TCR-12) and would reduce the impacts to below a level of significance. The No Project/Existing Plan Alternative would have a similar level of tribal cultural resources impacts as the proposed project.
Utilities and Service Systems
The No Project/Existing Plan Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service over existing conditions through the development of new residential uses. Proposed water use estimates and sewer generation rates for residential are based on the proposed density multiplied by the site acreage. Given that development under this alternative would be of the same land use type as the proposed project (Residential 4 -8 du/acre), the projected water demand and wastewater generation under this alternative would be the same as the proposed project. The sewer line extension in Woodward Street identified for the proposed project in the VWD technical memorandum (2023) would also be required for this alternative.
Storm water infrastructure demands are anticipated to be similar to the proposed project as a similar amount of impervious surface would be created. Solid waste generation would be slightly increased under this alternative but still less than significant. Similar to the proposed project, utilities and service system impacts would be less than significant under the No Project/Existing Plan Alternative . This alternative would have a similar level of impact to utilities and service systems as the proposed project.
Conclusion
The No Project/Existing Plan Alternative would result in a slightly more intensive use on the project site, including an increase in trip generation compared to the proposed project (400 ADT compared to 368 ADT). This results in a corresponding proportional increase in air pollutant s and noise from
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vehicles compared to the proposed project. Construction -related air polluta nts are expected to be slightly increased as construction duration would be longer due to additional building construction but a similar amount of grading, blasting, rock crushing and site preparation would be required.
Construction-related noise impacts due to rock drilling and rock crushing would be similar to the proposed project.
Footprint-specific impacts, such as those related to biological resources, cultural resources, and tribal cultural resources, would be similar to the proposed project, as the same amount of site area would be disturbed.
This alternative would slightly increase the number of students generated for San Marcos Unified School District ( SMUSD) and would increase demand for parks, libraries, and solid waste facilities compared to the proposed project. This alternative would have a similar water demand and wastewater generation as the proposed project. This alternative could meet the majority of the project objectives, as detailed in Table 4-1.
4.3.4 Reduced Density Alternative
Under the Reduced Density Alternative, the project site would be developed with single family residential uses at a reduced density of 2 du/acre, resulting in 16 single family homes. Prior to the last comprehensive update of the City’s General Plan, the project site was designated for Single-Family Detached under the HOCSP with a density of 2 to 4 du/acre assigned to it. The Reduced Density Alternative assumes the lower end of the density range given the steep slope of the property and preparation of a Specific Plan would be required. The maximum building height under this alternative would be 35 feet or two stories. Due to the topographical constraints of the site access would be similar to the proposed project and would be via a driveway on Woodward Street. Grading, blasting and rock crushing as well as fire fuel modification would be required for this alternative.
4.3.4.1 Comparison of the Effects of the Reduced Density Alternative to the Proposed Project Aesthetics
The Reduced Density Alternative would develop 16 single- family residences. The site would be modified through grading and retaining wall construction to allow for the access driveway and building pads. Building heights would be a maximum of 35 feet. Similar to the proposed project, a Specific Plan would be prepared to establish the development rules and regulations of the land uses under this alternative. Architectural treatments would be used to provide visual variety to the buildings, including enhanced treatments for highly -visible buildings. The Specific Plan would identify a planting palette and requirements for landscaping for each residence. Similar to the proposed project, this alternative would incorporate lighting for safety, security and way findi ng. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. Since the Reduced Density Alternative would develop single family residences, it would appear to be more visually consistent with the single - family residential development to the north and east. However, overall, development under this alternative would result in a generally similar level of visual change and would add lighting to an area where it does not currently exist. The Reduced Density Alternative would result in a similar level of impact as the proposed project and those impacts would be less than significant.
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Air Quality
Under the Reduced Density Alternative, air pollutant emissions associated with project construction including emissions associated with grading, blasting, rock crushing, site preparation, site finishing and building finishing would still occur. Grading act ivities would be similar to the proposed project, since a similar footprint for development is assumed . Building finishing and coating would be less under this alternative since fewer buildings would be constructed.
Emissions from vehicles going to and from the project site typically account for the largest portion of air quality emissions. Vehicular trips under the Reduced Density Alternative would be lower than the proposed project. This alternative would generate a pproximately 192 ADT compared to the 368 ADT anticipated for the project, an approximate 48% reduction. As such, because this alternative would result in a reduction of ADT on site, operational air pollutant emissions would be reduced when compared to the proposed project. However, operational and construction air pollutant emissions under this alternative would still be less than significant. Similar to the proposed project, impacts related to odors would be less than significant under this alternative. Overall, this alternative would decrease air quality emissions during both project construction and operation compared to the proposed project, and impacts would continue to be less than significant.
Biological Resources
Since it would have a generally similar footprint of disturbance, the Reduced Density Alternative would have a similar level of biological resources impacts as the proposed project, including potential impacts to coastal California gnatcatcher (Impact BIO -1), Crotch’s bumble bee (Impact BIO -2), other special-status wildlife species and nesting birds (Impact BIO-3 and Impact BIO-4), indirect impacts to sensitive species (Impact BIO-5) and impacts to Diegan coastal sage scrub (Impact BIO-6). Mitigation measures MM-BIO-1 through MM-BIO-6 would still be required under this alternative. Compared to the proposed project, this alternative would result in a similar level of biological resources impacts.
Cultural Resources
The Reduced Density Alternative would require a similar level of grading as the development. The location of the residential development would be generally similar to the proposed project .
Development under this alternative would still have the potential to impact unknown archaeological resources or unidentified human remains potentially located within the project site. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1 and MM-CR-2) and would reduce the impacts to below a level of significance. The Reduced Density Alternative would have a similar level of cultural resources impacts as the proposed project.
Energy
Construction of the Reduced Density Alternative would include a similar amount of grading and soil hauling as the proposed project. Therefore, construction-related energy use would be similar to that of the proposed project. Operationally, the project would require less energy use since the number of residential units would be reduced (46 units to 16). Additionally, since this alternative would generate fewer ADT compared to the proposed project, fuel use would also be reduced under this alternative.
Similar to the proposed project, this alternative would incorporate energy conservation features consistent with the requirements of Title 24 and would not result in the wasteful or inefficient use of energy or a conflict with a state or local plan for energy efficiency. Impacts are expected to be less
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than significant. Compared to the proposed project, energy demand would be decreased with the Reduced Density Alternative and impacts would continue to be less than significant.
Geology and Soils
Under the Reduced Density Alternative ground-disturbance would be required for the construction of the residential units. Development under this alternative would be required to implement the recommendations from the preliminary geotechnical investigation (GeoTek 2019). These recommendations include general provisions related to earthwork, and design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, and post -construction considerations. Compliance with the recommendations of the preliminary geotechnical investigation would ensure that seismic and soils hazards would be addressed through project design and impacts related to geological and soils hazards would be less than significant, simi lar to the proposed project. The Reduced Density Alternative would have a similar level of geology and soils impacts as the proposed project.
Hydrology and Water Quality
The Reduced Density Alternative would introduce impervious surfaces at the site in a similar quantity as the proposed project and the existing on-site hydrologic conditions, drainage patterns, and drainage volumes would be similarly modified. It is expected that this alternative would incorporate all required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adversely affect surface and groundwater quality, simi lar to the proposed project. As compared to the proposed project, this alternative would result in similar impacts and the impacts would be less than significant.
Land Use and Planning
Under the Reduced Density Alternative, the same list of project approvals would be required, including a Specific Plan Amendment to modify the HOCSP to remove the current Richmar Sub-Plan designation on the project, a new Specific Plan to establish the development rules for the site, a General Plan Amendment to remove the Richmar Sub -Plan designation from the project site, a Site De velopment Plan, Tentative Subdivision Map, and a Conditional Use Permit for a temporary rock crusher.
Development under this alternative would generate less traffic (192 ADT compared to 368 ADT) than the proposed project. The proposed project did not have any inconsistencies with the City’s Mobility Element goal related to LOS. Therefore, this alternative, since it would generate even fewer ADT, would not have any LOS -related issues. Development under this alternative would still be required to participate in Community Facility District: CFD2011 -01 (Congestion Management). This alternative would have a similar level of impact as the proposed project, which is less than significant.
Noise
Grading- -related noise under the Reduced Density Alternative would be similar to the proposed project, since grading activities would still be required, and similar types of equipment would be used.
Noise related to building construction would be similar to the proposed project but would last for a shorter duration since 7 fewer buildings would be constructed. The potential for significant impacts related to rock drilling and rock crushing would still be expected under this alternative and implementation of mitigation measures MM -N-1 and MM -N-2 would still be required. Similar to the proposed project, construction noise impacts would be reduced to below a level of significance with implementation of mitigation.
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The Reduced Density Alternative would generate operational noise from residential activities as well as vehicle trips generated by the project. This alternative would generate fewer ADT than the project (192 ADT compared to 368 ADT). Therefore, offsite noise generated by the project would be reduced under this alternative compared to the proposed project. Compared to the proposed project, this alternative would generate less noise during construction and operation; however, similar to the proposed project, noise impacts would be reduced to below a level of significance with mitigation.
Public Services
Similar to the proposed project, the Reduced Density Alternative would result in an increase in demand for public services, due to the construction of residential uses. Specifically, this alternative would increase the demand for police and fire protection services over existing conditions. Residential uses are the primary driver for demand for park, library, and school services. This project would reduce the amount of residential development by approximately 65% (16 units instead of 46 units), which results in a proportional decrease in the need for services. Development under this alternative would still be required to pay applicable PFF and school fees and participate in community facility districts for fire and police. Compared to the proposed project, this altern ative would result in a reduced demand for fire and police services and decreased demand for park, library, and school services. Overall, similar to the proposed project, impacts to public services would be less than significant.
Transportation
Under the Reduced Density Alternative, impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are still anticipated to be less than significant.
Development under this scenario would still be required to construct a minimum 50-foot southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane. This alternative would still be required to construct a sidewalk along the project access driveway to connect the development with the existing pedestrian infrastructure on Woodward Street.
With regard to VMT, it is assumed that development under this alternative would not screen out of a VMT analysis since it would not meet the floor area ratio requirement of 0.75 or greater. Given the lower density of development, the floor area ratio of 0.75 would not be achieved under this alternative.
According to San Diego Association of Government (SANDAG) San Diego Region SB 743 VMT Maps, the project site is within an area where the VMT is 101% of the regional mean for VMT (19.3 VMT/capita compared to the regional mean of 18.9 VMT/capita) (SANDAG 2023). In order to avoid a significant VMT impact, development under this alternative would be required to reduce VMT to 85% of the regional mean, or a total of 16%. There is a limit to the amount of VMT reduction that can be applied to a development project. Within the City, with its suburban land use the maximum feasible total reduction combining all VMT -reducing mitigation measures is 15%. Therefore, the Reduced Density Alternative would end up with a significant and unmitigated transportation impact related to VMT under the purposes of CEQA. This results in a greater level of impact compared to the proposed project.
Tribal Cultural Resources
The Reduced Density Alternative would require a similar level of grading as the proposed development.
The location of the residential development would be generally similar to the proposed project and development under this alternative would still have the potential to impact tribal cultural resources.
Tribal cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1 and MM-CR-2) and would reduce the impacts to
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below a level of significance. The Reduced Density Alternative would have a similar level of tribal cultural resources impacts as the proposed project.
Utilities and Service Systems
The Reduced Density Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service over existing conditions through the development of new residential uses. Based upon the w ater/sewer technical memorandum prepared by VWD (2023) and according to assumptions in their 2018 Master Plan, development under this alternative would have a water demand of 15,480 gallons per day (gpd) and a sewer generation of 6,450 g pd. The proposed project would have a water demand of 21,500 gpd and a sewer demand of 11,180 gpd. Therefore, the demand for sewer and water services would be decreased under this alternative compared to the proposed project. However, the sewer line extension in Woodward Street identified for the proposed project in the VWD technical memorandum (2023) would also be required for this alternative.
Storm water infrastructure demands are anticipated to be similar to the proposed project as a similar amount of impervious surface would be created. Solid waste generation would be decreased under this alternative due to fewer residential units.. Overall, compared to the proposed project, water, sewer, and solid waste demand would be less under the Reduced Density Alternative but similar to the proposed project, utilities and service system impacts would be less than significant.
Conclusion
The Reduced Density Alternative would result in a less intensive use on the project site, including a reduction in trip generation compared to the proposed project (192 ADT compared to 368 ADT). This results in a corresponding proportional decrease in air pollutant s and noise from vehicles compared to the proposed project. Grading-related air pollutants are expected to be similar under this alternative since a similar amount of grading, blasting, rock crushing and site preparation would be required.
Fewer a ir pollutants would be generated from building coating and finishes, since seven fewer buildings would be constructed. Construction -related noise impacts due to rock drilling and rock crushing would be similar as the proposed project.
Footprint-specific impacts, such as those related to biological resources, cultural resources, and tribal cultural resources, would be similar as the proposed project, as the same amount of site area would be disturbed.
This alternative would reduce the number of students generated for SMUSD and would reduce demand for parks, libraries, water, sewer, and solid waste services compared to the proposed project.
The Reduced Density alternative could meet the majority of the project objectives, as detailed in Table 4-1, but would not provide multi-family housing in the 4.1-8.0 dwelling unit range.
4.4 Alternatives Considered But Rejected
CEQA Guidelines Section 15126.6(c) provides guidance in selecting a range of reasonable alternatives for the project. An EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. CEQA Guidelines Section
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15126.6(c) provides the following guidance in selecting a range of reasonable alternatives for the project. There are many factors that may be taken into account when addressing the feasibility of the range of potential alternatives for the project, such as site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by the proponent). The alternatives discussion shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significa nt effects. An EIR should also identify any alternatives that were considered by the lead agency but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency's determination.
The EIR need not discuss every alternative to the project. A range of alternatives that are “reasonable” for analysis have been evaluated and are discussed above in Section 4.3, Project Alternatives Considered in this EIR. The following describes other alternatives considered by the City but dismissed from further evaluation in this EIR, and a brief description of the reasons for their rejection.
4.4.1 Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations to the project. There are sites within the city of an approximately equivalent size to the project site that could be redeveloped with a residential project; however, the project applicant does not control another site within the city of comparable land area that is available for development of the proposed project. One of the factors for feasibility of an alternative is “whether the propone nt can reasonably acquire, control or otherwise have access to the alternative site.” Because the city is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is not considered feasible. It should also be noted that the project site is surrounded by development and located adjacent to tra nsportation facilities, existing, transit and utility infrastructure. Further, the HOCSP identified the site for residential development. As such, an alternative location was ultimately rejected from further analysis in the EIR.
4.5 Environmentally Superior Alternative
Table 4 -2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project. As shown in Tables 4-1 and 4-2, the No Project/No Development Alternative would eliminate all of the potentially significant impacts identified for the project. However, the No Project/No Development Alternative would not meet any of the project objectives. Additionally, there is no certainty that the project site would remain undeveloped in perpetuity. CEQA Guidelines Section 15126.6(e)(2) states that 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 No Project/Reduced Density Alternative is the environmentally superior alternative because it would provide a reduced level of impact in some environmental analysis areas including air quality, energy, noise, public services, and utilities/service s ystems. Mitigation measures would still be required to mitigate impacts to biological resources, cultural resources/tribal cultural resources , and noise. However, the Reduced Density Alternative was not selected as it would result in a new significant and unmitigated impact related to transportation (VMT impact).
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Table 4-1. Summary of Alternatives and Project Objectives Objective Proposed Project
(46 units)
No Project/No
Development
No Project/Existing
Plan Alternative
(50 units)
Reduced Density
Alternative
(16 units)
Provide multi-family housing opportunities close to major transit, educational facilities, shopping opportunities, employment uses, and trails to optimize alternative modes of transportation, reduce reliance on automobiles, and
potentially reduce greenhouse gas emissions.
Meets objective Does not meet this
objective
Meets objective Does not meet this
objective
To the extent possible given site constraints, maximize the opportunity to provide housing for the City of San Marcos in the 4.1 to 8.0 dwelling unit density range which is
comparable to low-density housing developments in the
City of San Marcos.
Meets objective Does not meet this
objective
Meets objective Does not meet this
objective
Cluster development to lessen site impacts and minimize landform modification.
Meets 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
Develop high-quality attainable housing which meets the housing needs of the City of San Marcos and the region.
Meets 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
Create a development that promotes a high-quality-of-life by providing each dwelling unit its own private patio/yard space and by providing a common recreational open space gathering area.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
Establish development standards and design guidelines
that ensure distinctive architecture, 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
Could be designed in
a manner that meets
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
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
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Objective Proposed Project
(46 units)
No Project/No
Development
No Project/Existing
Plan Alternative
(50 units)
Reduced Density
Alternative
(16 units)
Finance or contribute a fair share of funding to all
community services and infrastructure needed to support Specific Plan development to promote economic stability.
Meets 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
Table 4-2. Comparison of Impacts of Proposed Project and Alternatives Environmental Topic Proposed Project
No Project/No
Development
Alternative
No Project/Existing
Plan Alternative (50
Units)
Reduced Density
Alternative (16 Units)
Aesthetics LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
Air Quality LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Biological Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
Energy LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Geology and Soils LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
Hydrology and Water Quality LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
Land Use and Planning LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
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Environmental Topic Proposed Project
No Project/No
Development
Alternative
No Project/Existing
Plan Alternative (50
Units)
Reduced Density
Alternative (16 Units)
Noise LTSM No Impact
(Reduced)
LTSM
(Increased)
LTSM
(Reduced)
Public Services LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Transportation LTS No Impact
(Reduced)
LTSM
(Increased)
SU
(Increased)
Tribal Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
Utilities and Service Systems LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Notes: Impact Status: LTS = Less than significant impact; LTSM = Less than significant with mitigation; SU = Significant and Unmitigated
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5.0 Environmental Effects Found not to be Significant
The City of San Marcos completed an Initial Study (IS) for the proposed project in accordance with Sections 21000-21189 of the Public Resources Code and Section 15063 of the California Environmental Quality Act (CEQA) Guidelines. A Notice of Preparation (N OP) was prepared by the City and mailed to applicable agencies, organizations, and neighboring property owners. The NOP is included in Appendix B.2 of this Environmental Impact Report (EIR).13 As required by Section 15128 of the CEQA Guidelines, the following is a discussion of the environmental effects that were considered as a part of the Initial Study but were determined to have “No Impact”, and, therefore, are not discussed in detail in this EIR.
In some instances, complete environmental issue areas were eliminated during the IS process, including agriculture/forestry resources, greenhouse gas emissions, hazards/hazardous materials, mineral resources, population and housing, recreation, and wildfire. In other instances, some of the specific CEQA thresholds were eliminated during the IS process including aesthetics (scenic vistas, scenic resources within a state scenic highway), biological resources (federally protected wetlands, wildlife movement), cultural resources (historical resources), geology and soils (septic systems), hydrology and water quality (groundwater, flood hazards/tsunami/seiche), land use and planning (physically divide and established community), and noise (project vicinity to priv ate airports or within and airport land use plan).
5.1 Aesthetics
Threshold of Significance: Have a substantial adverse impact on a scenic vista.
The project site is located within the Richland Neighborhood in the City. The City has a Ridgeline Protection and Management Overlay Zone to protect natural viewsheds and unique natural resources, minimize physical impacts to ridgelines, and to establish innovative sensitive architectures standards.
The project site is not located in the Ridgeline Protection and Management Overlay Zone. Further, the project site does not include any primary or secondary ridgelines, as identified in Figure 4 -5 of the Conservation and Open Space Element of the General Plan (San Marcos 2012). Therefore, development of the project site would not have a substantial adverse effect on a scenic vista and no impact would occur.
Threshold of Significance: Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway.
The project site is located approximately 0.4 miles north of SR-78. A portion of SR-78 is recognized as a Scenic Highway by California Department of Transportation (Caltrans); however, that portion is not in the project vicinity. The portion identified as a Scenic Highway is approximately 50 miles east of the project site near Anza Borrego (Caltrans 2019). At a local level, SR-78 is designated by the City of San Marcos as a view corridor. The highway corridor provides views of the Merriam Mountains, Mount Whitney, and Double Peak. There are no scenic resources on the project site. The project site is undeveloped and does not support any historic buildings (ASM 2024). In summary, the project would
13 The Initial Study, NOP, and comment letters received on the NOP are included in Appendices B.1, B.2 and B.3 of the EIR.
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not damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. No impact would occur.
A discussion of additional aesthetics significance thresholds is provided in Section 3.1, Aesthetics.
5.2 Agriculture and Forestry Resources
Threshold of Significance : Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use.
The project site is not mapped as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as determined by the Farmland Mapping and Monitoring Program, as shown on Figure 4- 4 (Agricultural Areas) in the San Marcos General Plan (San Marcos 2012). Therefore, the project would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. No impact is identified for this issue area.
Threshold of Significance : Conflict with existing zoning for agricultural use, or a Williamson Act contract.
The project site has a General Plan designation of SPA (Specific Plan Area) and a zoning designation of Specific Plan Area (SPA). The project site does not support zoning for agricultural use. The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space use. In return, landowners receive property tax assessments which are m uch lower than normal because they are based upon farming and open space uses as opposed to full market value. The project site is not located within a Williamson Act contract area. Therefore, the project would not conflict with existing zoning for agricultural use , or a Williamson Act contract, and no impact is identified for this topic.
Threshold of Significance: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)).
Forest land is defined as “land that can support ten percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, b iodiversity, water quality, recreation, and other public benefits” (California Public Resources Code Section 1220(g)). Timberland is defined as “land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees” (California Public Resources Code Section 4526). A Timberland Production Zone is defined as “an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses” (California Public Resources Code Section 51104(g)).
The project site has a General Plan designation of SPA (Specific Plan Area) and a zoning designation of Specific Plan Area (SPA). The proposed project is not located in an area that is zoned for forest land, timber land or for timber production nor is it adjacent to lands that are zoned forest land, timber land
5.0 Environmental Effects Found not to be Significant
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or for timber production. Implementation of the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned timberland production. No impact is identified for this topic.
Threshold of Significance: Result in the loss of forest land or conversion of forest land to non -forest use.
The project site is undeveloped. As described above, t he project site does not support forest lands, nor is there any forest land adjacent to the project site. Therefore, the proposed project would not result in the loss of forest land or the conversion of forest land to non-forest use. No impact is identified for this topic.
Threshold of Significance: Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.
The project would not result in any other changes to the existing environment that would, due to their location or nature, result in the conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. There is no agricultural activity on the project site or in the project vicinity. No impact is identified for this topic.
5.3 Biological Resources
Threshold of Significance: Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Based upon the Biological Resources Report prepared by Rincon (202 5), no natural drainages or wetlands were observed during the surveys or background research. Concrete v-ditches (brow ditches) were identified in the northeast portion of the study area along a chain link fence that runs along the slope and down towards the junction of Woodward Stre et and Vineyard Street. Vegetation has overgrown much of the areas along the man -made ditch. The concrete drainage ditches were constructed and installed by Ryland Homes as part of the Woodward Improvement Plan approved and permitted by the City of San Marcos on January 27, 2000. The construction of the “Type B” brow ditch along the northwestern boundary of the project site (including portions of the project impact area) was constructed on existing mitigated easements by Ryland Homes. An additional concrete v-ditch, constructed and installed by KB homes, is located along the southwest corner at the top of a retaining wall as part of the residential development to the south. The function of the concrete ditches is to safely direct stormwater flow off the road ways and slope as shown in site plans for the Woodward Improvement Plan. These manmade, non-natural, stormwater conveyance ditches originate in upland areas and not in any natural drainages.
The concrete ditches do not provide habitat functions for fish and wildlife. The ditches are intended to capture stormwater runoff and sheet flow from upslope areas and safely convey them for erosion control.. Riparian habitat located to the west of Woodwa rd Street adjacent and associated with San Marcos Creek is within the study area but outside of the project’s boundaries. A formal jurisdictional delineation was not conducted; however, these human -constructed concrete v -ditches were determined to not be jurisdictional, with no evidence of presence of Waters of the US (WoUS) or Waters of the State (WoS) occurring within the project site or project impact area. Human -constructed concrete v-ditches on slopes are typically not considered to comprise WoUS or WoS. No connection
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was identified from these ditches to San Marcos Creek or Twin Oaks Creek. Therefore, no direct or indirect impacts to state or federally protected wetlands have been identified for the implementation of the proposed project. No impact would occur.
Threshold of Significance: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Wildlife movement corridors are defined as areas that connect suitable wildlife habitat areas in a region otherwise fragmented by rugged terrain, changes in vegetation, or human disturbance. Natural features such as canyon drainages, ridgelines, and areas with vegetation cover provide corridors for wildlife travel. The project site is a habitat island, with Woodward Street along the western boundary of the project site which separates it from Twin Oaks Valley Creek to the west, Mission Road south of the project site, and residential development north, south, and east of the project site blocking any significant wildlife movement. There is an Open Space lot directly north of the project site, however the project area and vicinity are not identified as being within or adjacent to a wildlife corridor per Figure 4-2 of the City of San Marcos General Plan (San Marcos 2012). The project area is also not within or adjacent to a Biological Core and Linkage Area (BCLA) as illustrated in Figure 2-3 of the Final Multiple Habitat Conservation Program (MHCP) Plan (SANDAG 2003). Areas identified as Focused Planning Areas (FPAs) within the Multiple Habitat Conservation Plan occur to the north, northeast, east, and west of the project site. These designated preserved native habitats provide local movement (i.e., “stepping stone) rather than regional linkage, for local and migratory species such as birds, including federal, state, and MHCP covered species. No impact is identified for this topic.
A discussion of additional biological resources significance thresholds is provided in Section 3.3, Biological Resources.
5.4 Cultural Resources
Threshold of Significance: Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.
Based upon the cultural resources report prepared for the project (ASM 2024) there are no historical resources on the project site. Therefore, the project would not have the potential to cause a substantial adverse change in historic resources, as defined in Section 15064.5 of the CEQA Guidelines. No impact is identified for this topic.
A discussion of additional cultural resources significance thresholds is provided in Section 3.4, Cultural Resources.
5.5 Geology and Soils
Threshold of Significance: Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of wastewater.
Septic tanks and alternative wastewater disposal systems are not proposed as part of the project. The project would receive wastewater service from Vallecitos Water District (VWD) and would connect to existing sewer infrastructure in Woodward Street (VWD 2023). Therefore, no impact is identified for this issue area.
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A discussion of additional geology and soils significance thresholds is provided in Section 3.6, Geology and Soils.
5.6 Greenhouse Gas Emissions
Threshold of Significance: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
The City adopted a Climate Action Plan (CAP) which was developed to help reduce the City’s greenhouse gas (GHG) emissions (San Marcos 2020). As part of the CAP, the City developed a CAP Consistency Review Checklist (Checklist). The purpose of the Checklist is to implement the GHG reduction measures from the CAP that apply to new discretionary development. New development that demonstrates consistency with relevant CAP strategies would not conflict with the City’s ability to achieve the identified GHG reduction targets through implementation of applicable measures. Projects that are consistent with the CAP, as determined through the use of the CAP Checklist, may rely on the CAP for the cumulative impact analysis of GHG emissions. The CAP Checklist identifies certain sizes and types of projects that would emit fewer than 500 metric tons ( MT) of carbon dioxide equivalent (CO
2e) per year. Projects that emit fewer than 500 MT CO 2e per year would be determined to have a less than significant GHG impact and would not be subject to the measures of the CAP. Multifamily residential projects of 55 dwelling units or less are considered to emit fewer than 500 MT CO2e per year. The project proposes 46 multifamily units. Therefore, it would fall under the 55 multifamily unit criteria and GHG impacts would be less than significan t. The project’s CAP Checklist is included as Appendix F of the EIR.
Threshold of Significance: Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases? Under the City’s CEQA thresholds, the method for determining significance for project -level environmental documents is through the CAP Checklist. The city's CAP is also consistent with state/regional goals. As discussed above, the project would be consistent with the City’s CAP , no conflict is identified and GHG impacts would be less than significant.
5.5 Hazards and Hazardous Materials
Threshold of Significance: Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials? Hazardous materials include solids, liquids, or gaseous materials that, because of their quantity, concentration, or physical, chemical, or infectious characteristics could pose a threat to human health or the environment. Hazards include the risks associated with potential explosions, fires, or release of hazardous substances in the event of an accident or natural disaster, which may cause or contribute to an increase in mortality or serious illness or pose substantial harm to human health or the environment. The proposed project would involve the transport of fuels, lubricants, and various other liquids needed for operation of construction equipment at the site on an as-needed basis by equipment service trucks. Materials hazardous to humans, wildlife, and sensitive environments, including diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets, would be present during project construction. The potential exists for direct impacts to human health from accidental spills of small amounts of hazardous materials from construction equipment; however, the proposed project would be required to comply with Federal, State, and City Municipal Code restrictions which regulate and control those materials handled onsite.
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Compliance with these restrictions and laws would ensure that potentially significant impacts would not occur during project construction.
In addition, as a residential project, the only hazardous materials anticipated for transport or disposal associated with the proposed project during operation are routinely used household products such as cleaners, paint, solvents, motor oil/ automotive products, batteries, and garden maintenance products.
It is anticipated that the use, handling, and disposal of these products would be addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan of the County of San Diego and other Federal, State, and City Municipal Code regulations.
In summary, the project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impacts would be less than significant.
Threshold of Significance: Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The project site is vacant and undeveloped. There are no existing site conditions which would result in a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions that could involve the release of hazardous materials into the environment. No impact is identified for this issue area.
Threshold of Significance: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The project site is not located within 0.25 miles of an existing or proposed school. The closest school is San Marcos Elementary school, which is located approximately 0.5 miles to the southwest. No impact is identified.
Threshold of Significance: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The provisions of Government Code Section 65962.5 are commonly referred to as the Cortese List.
The Cortese List is a planning document used by the state and local agencies to provide information about hazardous materials release sites. Government Code Sec tion 65962.5 requires California Environmental Protection Agency (CalEPA) to develop an updated Cortese List annually, at minimum.
California Department of Toxic Substances Control ( DTSC) is responsible for a portion of the information contained in the Cor tese List. Other California state and local government agencies are required to provide additional hazardous material release information for the Cortese List.
A search of the DTSC EnviroStor site was conducted on May 16, 2023, to see if there are any current or historical environmental cleanups or permitted facilities on or adjacent to the project site. There are no current or past permitted facilities or cleanup activities on the project site (DTSC 2023). The closest listed sites per EnviroStor are:
• TRI-M-CO, 528 E. Mission Road - A leaking underground storage tank (LUST) cleanup site located approximately 0.4 miles east of the project site. The cleanup was completed in 1993 and the case is closed.
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• United States Post Office, 420 N. Twin Oaks Valley Road - A LUST cleanup site located approximately 0.2 miles west of the project site. The cleanup was completed in 2006 and the case is closed.
Due to the distance of these listings from the project site as well as the fact that they have been cleaned up, there would be no impact associated with the project.
Threshold of Significance: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The nearest airport is the McClellan -Palomar Airport in Carlsbad, which is located approximately 6.5 miles to the southwest of the project site. According to Figure 6-5 of the Safety Element of the City’s General Plan, the project site is located within Review Area 2 of the airport influence area. Review Area 2 limits the heights of structures in areas of high terrain. While the project is on an elevated hillside, the site is situated, overall, in the lower elevation portion of the City. According to the Airport Land Use Compatibility Plan (ALUCP) for the McClellan-Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, the project would not result in a safety hazard of excessive noise for people residing or working in the project area. No impact is identified.
Threshold of Significance: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
According to the General Plan Safety Element, the San Marcos Emergency Operations Plan (EOP) governs the operations of the City during a disaster. This plan addresses response to moderate evacuation scenarios, including the identification of evacuation points and general routes (San Marcos 2012). The project would not result in any changes to the transportation network which could impair implementation of or physically interfere with an adopted emergency response plan. No impact would occur.
Threshold of Significance: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? The project site is located in a developed part of the City and is not located where wildlands are adjacent to urbanized areas, nor does the project propose residences mixed in with wildlands. There are two easements on the site associated with vegetation management for fire fuel reduction. One is located along a portion of the site’s eastern boundary and the other is located along a portion of the site’s southern boundary. The project site is located in a Local Responsibility Area, not a State Responsibility area (CAL FIRE 2022). The project site is in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non -VHFHSZ) designation per the California Department of Forestry and Fire Protection (CAL FIRE) San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a San Marcos Fire Protection District (SMFPD) Community Hazard Zone. Impacts would be less than significant.
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5.7 Hydrology and Water Quality
Threshold of Significance: Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.
The project would be served by VWD for water service. VWD water supplies come from the Metropolitan Water District and the San Diego County Water Authority. Both of these agencies use some groundwater for their supplies. The proposed project will be supplied from existing VWD supplies, which would have assumed the use of groundwater. VWD assumed development of the project site in the 2018 Master Plan and VWD has indicated their availability to serve the project (VWD 2023). The project would not develop any new groundwater wells to serve the project. The project site is not located within a sustainable groundwater management area and is not part of a significant groundwater recharge area. Therefore, the project would not substantially deplete groundwater supplies. The project would increase the amount of impervious surfaces on the project site; however, 37% of the proposed development area will revegetated/landscaped. Additional areas on the project site will remain as open space, which will allow for infiltra tion. The project would not interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. No impact is identified for this issue area.
Threshold of Significance: In flood hazards, tsunami or seiche zones, risk release of pollutants due to project inundation.
Per the Federal Emergency Management Agency’s (FEMA’s) Flood Insurance Rate Map Number 06073C0793G the project site is not located within a 100-year flood hazard area (FEMA 2012). The project site is approximately 10 miles inland from the Pacific Ocean and would not be subject to inundation by tsunami. Given that the project site is not located near a large standing body of water, inundation by seiche (or standing wave) is considered negligible. No impact would occur.
A discussion of additional hydrology and water quality significance thresholds is provided in Section
3.7, Hydrology and Water Quality.
5.8 Land Use and Planning
Threshold of Significance: Physically divide an established community.
The project site is currently undeveloped. The project proposes residential uses in an area that is already developed with similar uses. The project would not physically divide an established community.
No impact is identified for this issue area.
A discussion of additional land use and planning significance thresholds is provided in Section 3.8, Land Use and Planning.
5.9 Mineral Resources
Threshold of Significance: Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.
According to the City of San Marcos General Plan Conservation & Open Space Element, the City contains land classified in all four Mineral Resource Zones (MRZ) (San Marcos 2012). California does
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not require that local governments protect land designated as MRZ-1, MRZ-3, or MRZ-4. However, the City is responsible for recognizing lands designated as MRZ -2 and protecting these areas from premature development incompatible with mining. The lands designated as MRZ- 2 include small portions between Double Peak, Mount Whitney, and Franks Peak; and small portions in the northern Sphere of Influence within Twin Oaks Valley Neighborhoo d. These locations do not overlap with the project site; therefore, no loss of known mineral resources would occur. No impact is identified.
Threshold of Significance: Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan The project site is not designated as a locally important mineral resource recovery site on any local general plan, specific plan, or other land use plan (City of San Marcos 2012). Due to the location and the nature of the proposed project, there would be no impact on mineral resources.
5.10 Noise
Threshold of Significance: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
The proposed project is not located within the vicinity of a private airstrip. The public airport closest to the project site is the McClellan -Palomar Airport, located approximately 6.5 miles to the southwest.
According to the ALUCP for the McClellan -Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, people residing or working in the project area would not be exposed to substant ial airport noise.
A discussion of additional noise significance thresholds is provided in Section 3.9, Noise.
5.11 Population and Housing
Threshold of Significance: Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The project site has a General Plan Designation of SPA and is associated with the Heart of the City Specific Plan (HOCSP). The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Missio n Road corridor, including the project site, have a sub-plan designation of Richmar Specific Plan. Prior to the site’s inclusion under the Richmar sub-plan, the underlying designation for the property was Single-Family Detached 2 to 4 du/ac per the HOCSP.
Development criteria for the Richmar Specific Plan has not been adopted by the City; therefore, properties requesting development within this sub -plan area are required to establish individual specific plans. As such, there is no fixed land use or density currently assigned to the project site. The General Plan identifies commercial, office and multifamily residential as land use options within the Richmar Specific Plan Area. Due to its location and the adjacent residential land uses, a multifamily residential development, under a Specific Plan, is the most suitable land use for the subject property.
City policy requires that a secondary access be provided if more than 50 units are proposed. Given the
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topographical constraints and the lack of availability of a secondary/emergency vehicle access point, a maximum of 50 multifamily residential units could be built on the site. This would result in a density of 5.9 du/acre. The project site would not be suitable for commercial or office development given the site topography and adjacent uses. The Specific Plan allows for a density of 5.7 du/acre and the project is proposing 5.4 du/acre. Therefore, the project’s development intensity and density would be slightly less than what is identified in the current General Plan and the project would not result in substantial unplanned population growth in an area, directly or indirectly and no impact is identified.
Threshold of Significance: Displace substantial numbers of existing housing or people, necessitating the construction of replacement housing elsewhere.
There is no existing housing on the project site. Therefore, the project would not remove existing housing. The project proposes 46 multifamily units which would add to the housing stock in the City.
No impact is identified for this issue area.
5.12 Recreation
Threshold of Significance: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration of the facility would occur or be accelerated?
Threshold of Significance: Does the project include any recreational facilities or require the construction or expansion of recreation facilities which might have an adverse physical effect on the environment?
The project proposes residential uses which can result in an increase in demand for neighborhood and regional parks. The project proposes common open space area s, including a tot lot, turf play areas and a sensory garden. These features would be included within the development footprint of the project. This provides an opportunity for residents to recreate on site. Additionally, the project will pay Public Facility Fees (PFF), a portion of which goes toward funding a c ity-wide park and recreation facilities and would offset the future residents demand for such facilities . Since the project provides on-site recreational amenities and will pay PFF, impacts would be less than significant.
5.13 Wildfire
Threshold of Significance: A significant wildfire would be identified if the project was located in or near a state responsibility area or lands classified as very high fire hazard severity zone and would:
• Substantially impair an adopted emergency response plan or emergency evacuation plan; • Due to slope, prevailing wind, and other factors exacerbate wildlife risk, and thereby, expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire;
• Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or • Expose people or structure to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability or drainage changes.
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The project site is located in a Local Responsibility Area, not a State Responsibility area (CAL FIRE 2022). The project site is in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per California Department of Forestry and Fire Protection (CAL FIRE) San Marcos Fire Hazards Severity Zones Map (2009) and is surroun ded by areas identified as Non - VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. It should be noted there are two easements on the site associated with vegetation management for fire fuel reduction. One is located along a portion of the site’s eastern boundary and the other is located along a portion of the site’s southern boundary.
These are associated with fire buffer maintenance requirements of adjacent development. The project will also implement a zoned brush management plan which will provide a minimum of 150 feet of clearance. The brush management plan will follow CAL FIRE’s guidance for defensible space (CAL FIRE 2023) which includes three zones of defensible space. No impact is identified for this issue area.
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6.0 Other CEQA Considerations
6.1 Significant and Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines, Section 15126.2(b), requires that an Environmental Impact Report (EIR) describe any significant impacts that cannot be avoided, including those impacts that can be mitigated but not reduced to a less -than-significant level. Chapter 3, Environmental Analysis, of this EIR describes the potential environmental impacts of the proposed project and recommends mitigation measures to reduce impacts, where feasible. Based upon the analysis in Sections 3.1 through 3.13 of this EIR, the proposed project would not have any significant and unavoidable impacts. All impacts would be mitigated to below a level of significance through the incorporation of mitigation measures. These mitigation measures would be identifie d in a Mitigation Monitoring and Reporting Program that will be adopted as part of the project and also be made a condition of approval of the project.
6.2 Growth Inducement
Section 15126.2(e) of the CEQA Guidelines mandates that the growth inducing nature of a proposed project be discussed. This CEQA Guideline states the growth-inducing analysis is intended to address the potential for the proposed project to “foster economic or population growth, or the construction of additional housing, either dir ectly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) also mandates that a CEQA document speak to the proposed project’s likelihood to induce substantial population growth in an area, either d irectly (e.g., by proposing new homes or businesses) or indirectly (e.g., through extension of roads or other infrastructure).
A project may be distinguished as either facilitating planned growth or inducing unplanned growth.
Facilitating growth is related to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing grow th is related to lowering or removing barriers to growth or by creating an amenity or facility that attracts new population/economic activity.
For purposes of this EIR analysis, a significant growth inducement impact would occur if the proposed project, and associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burden existing community services, the environment or cause a demand for General Plan Amendments. This section contains a discussion of the growth inducing factors related to the proposed project and as defined under CEQA Guidelines, Section 15126.2(e). A project is defined as growth inducing when it directly or indirectly:
• Fosters population growth;
• Includes the construction of additional housing in the surrounding environment; • Removes obstacles to population growth;
• Taxes existing community service facilities, requiring construction of new facilities that could cause significant environmental effects; and/or
• Encourages or facilitates other activities that could significantly affect the environments, either individually or cumulatively.
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It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
As discussed in Section 5.12, Population and Housing, the project site has a General Plan Designation of SPA and is associated with the Heart of the City Specific Plan (HOCSP). The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Mission Road corridor, including the project site, have a sub-plan designation of Richmar Specific Plan. Prior to the site’s inclusion under the Richmar sub -plan, the underlying designation for the property was Single-Family Detached 2 to 4 du/ac per the HOCSP.
Development criteria for the Richmar Specific Plan has not been adopted by the City; therefore, properties requesting development within this sub -plan area are required to establish individual specific plans. As such, there is no fixed land use or density currently assigned to the project site. The General Plan identifies commercial, office and multifamily residential as land use options within the Richmar Specific Plan Area. Due to its location and the adjacent residential land uses, a multifamily residential development, under a Specific Plan, is the most suitable land use for the subject property.
City policy requires that a secondary access be provided if more than 50 units are proposed. Given the topographical constraints and the lack of availability of a secondary/emergency vehicle access point, a maximum of 50 multifamily residential units could be built on the site. This would result in a density of 5.9 du/acre. The project site would not be suitable for commercial or office development given the site topography and adjacent uses . The proposed project has a proposed density of 5.7 du/acre.
Therefore, the project’s development intensity and density would be slightly less than what is identified in the current General Plan , and the project would not result in substantial unplanned population growth in an area, directly or indirectly and no impact is identified.
As detailed in Section 3.13, Utilities and Service Systems, the proposed project would extend the existing 8 -inch gravity sewer main located north of the project site in Woodward Street for approximately 490 feet. This extension is only intended to serve the proposed project.
Additionally, the majority of the surrounding area is developed. The SANDAG population growth forecasts rely, in part, on individual jurisdiction’s planning documents, such as the City’s General Plan.
The City has a population rate of 3.1 persons per dwelling unit. Therefore the project would result in the addition of approximately 143 people. Because the project proposes a General Plan Amendment the estimated population of 143 people would not have been accounted for in SANDAG’s projections.
Therefore, the project’s induced population would exceed these projections. However, determination of impacts related to population growth are based upon whether the induced growth would be considered substantial.
The City’s population is projected to grow from 94,258 people in 2016 to 104,365 people by 2035 (an increase of 10,107 people) (SANDAG 2022). The population increase of 143 people would account for 1.4% of SANDAG’s projected population growth.
There is no hardline number or percentage available to determine whether or not this estimated introduction of 143 people (1.4 % of projected growth) could be considered a substantial increase in population. However, SANDAG’s 2050 Regional Growth Forecast is intended to be used as a starting point for regional planning as opposed to a prescribed growth pattern. Although the City determined that there are adequate sites available with appropriate designations/zoning to accommodate the remaining Regional Housing Needs Allocation (RHNA) for the current Housing Element planning period, the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with approved/constructed residential development (City of San
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Marcos 2021). Therefore, while the proposed project would directly induce growth beyond current estimates and forecasts, it would not be considered substantially growth inducing. Impacts would be less than significant.
6.3 Significant Irreversible Environmental Changes
CEQA Guidelines, Section 15126.2(d), requires that an EIR discuss any significant irreversible environmental changes which would be caused by the proposed project should it be implemented. Per this guideline “Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses.
Also irreversible damage can result from environmental accidents associated with the project.
Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.”
Approval of the project would involve the development of 46 duplex residential units and associated infrastructure improvements.. Con struction and/or operation of the proposed project would require the use of resources that include, but are not limited to, soils, gravel, concrete, and asphalt, lumber and other related forest products, petrochemical construction materials, steel, copper, and other metals, water, fuels, and energy. As such, the proposed project would result in the short-term and long- term use of fossil fuels and other nonrenewable resources. The grading proposed by the project would modify the undeveloped slopes permanently. These are irreversible environmental changes that would be realized with implementation of the proposed project.
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7.0 References
Summary
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
Project Description (Section 2.0)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
California Department of Forestry and Fire Protection (CAL FIRE). 2023. Defensible Space. https://www.fire.ca.gov/dspace Viewed January 30, 2024.
GeoTek. 2019. Preliminary Geotechnical Investigation – Proposed Residential Development APN 220- 210-49-00, Northeast of Woodward & Mission, San Marcos, California. May 16.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
Aesthetics (Section 3.1)
City of San Marcos. 2023a. Zoning Ordinance, Section 20.300.080- Light and Glare Standards.
Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library. municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.300SIPLGEDES T_S20.300.080LIGLST Viewed February 7, 2024.
City of San Marcos. 2023b. Zoning Ordinance, Section 20.260 -Ridgeline Protection & Management Overlay Zone. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 260RIPRMAOVZO Viewed February 7, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
United States Census Bureau (USCB). 2023. Quick Facts Escondido City, San Marcos City, California, United States. https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia,sanmarcos %20citycalifornia,US/PST045219 Viewed November 21, 2023.
Air Quality (Section 3.2)
California Air Resources Board (CARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October . https://ww2.arb.ca.gov //sites/default/files/classic/diesel/documents/rrpfinal.pdf Viewed February 7, 2024.
California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. https://www.aqmd.gov/docs/default -source/ceqa/handbook/california-air- resources-board-air-quality-and-land-use-handbook-a-community-health-perspective.pdf Viewed February 7, 2024.
California Air Resources Board (CARB). 2016. Ambient Air Quality Standards. May 4. http://www.arb.ca.gov/research/aaqs/aaqs2.pdf Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-2
LDN Consulting (LDN). 2025. Air Quality Assessment, Woodward 46 Specific Plan SP22 -005, SP22- 0006, GPA22-0004, MFSD22-0005, TSM22-0004, City of San Marcos, CA. January 7.
Linscott Law & Greenspan (LLG). 2023. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
San Diego Air Pollution Control District ( SDAPCD). 1976. Regulation IV; Rule 51: Public Nuisance. https://www.sdapcd.org/content/sdapcd/rules.html Viewed October 9, 2023.
San Diego Air Pollution Control District ( SDAPCD). 2019. Rule 20.2: New Source Review Non- Major Stationary Sources. https://www.sdapcd.org/content/sdapcd/rules.html Viewed February 7, 2024.
San Diego Air Pollution Control District (SDAPCD). 2020. 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County. October. https://ww2.arb.ca.gov/our- work/programs/california-state-implementation-plans/nonattainment-area-plans/san-diego-county-0 Viewed February 7, 2024.
San Diego Air Pollution Control District ( SDAPCD). 2021. Regulation XII; Rule 1210: Toxic Air Contaminant Health Risks - Public Notification and Risk Reduction. https://www.sdapcd .org/content/sdapcd/rules.html Viewed February 7, 2024.
San Diego Air Pollution Control District (SDAPCD). 2023. Attainment Status. https://www.sdapcd .org/content/sdapcd/planning/attainment-status.html Viewed February 7, 2024.
Biological Resources (Section 3.3)
Alden Environmental. 2024. 2024 Survey Report for Foraging Crotch’s Bumble Bee (Bombus crotchii) on the Woodward Specific Plan Development Project. August 15.
AMEC Earth & Environmental, Inc. (AMEC). 2003 . Volume II Final MHCP Plan Biological Analysis and Permitting Conditions. March. https://www.sandag.org/-/media/SANDAG/Documents/PDF/projects- and-programs/environment/regional-habitat-conservation/volume-2-final-multiple-habitat- conservation-program-plan-biological-analysis-permitting-2003-03-01.pdf Viewed February 7, 2024.
California Department of Fish and Wildlife (CDFW). 2023. Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species. June 6. https://nrm .dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline Viewed February 11, 2024.
KMEA. 2018. Coastal California Gnatcatcher (Polioptila californica californica) Protocol Survey Results for the Mission 316 Project, San Marcos, California. November 29.
KMEA. 2020. 2020 Coastal California Gnatcatcher (Polioptila californica californica) Pre-Construction Survey Results for the Mission 316 Project, San Marcos, California. October 9.
Oberbauer, Thomas, Meghan Kelly, and Jeremy Buegge (Oberbauer, et.al). 2008. Draft Vegetation Communities of San Diego County. March Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California.” Robert F. Holland, Ph.D., October 1986 . https://www.sand iegocounty.gov/content/dam/sdc/pds/ceqa/Soitec-Documents/Final-EIR-Files/references/rtcref /ch9.0/rtcrefaletters/O14%202014-12-19_OberbauerTM2008.pdf Viewed January 30, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-3
Rincon Consultants (Rincon). 2024. Focused Rare Plant Survey Report for Woodward Specific Plan Development Project. February 7.
Rincon Consultants (Rincon). 2023. Coastal California Gnatcatcher Protocol Survey Report for Woodward Specific Plan Development Project. October 4.
San Diego Association of Governments (SANDAG). 2003. Final MHCP Plan – Volume 1. https://www. sandag.org/-/media/SANDAG/Documents/PDF/projects-and-programs/environment/regional- habitat-conservation/volume-1-final-multiple-habitat-conservation-program-plan-2003-03-01.pdf Viewed February 7, 2024.
Sawyer, J. O., T. Keeler-Wolf, and J.M. Evens (Sawyer et.al). 2009. A Manual of California Vegetation, Second Edition. California Native Plant Society, Sacramento, California.
Xerces Society for Invertebrate Conservation, 2023. At Risk Bumble Bees, Crotch’s Bumble Bee. https://xerces.org/endangered-species/species-profiles/bumble-bees/crotchs-bumble-bee Viewed October 19, 2023.
Cultural Resources (Section 3.4)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
City of San Marcos. 2023. Archaeological and Historical Resources Consultant Guidelines. January. https://www.san-marcos.net/home/showpublisheddocument/27022/638090369405800000 Viewed February 7, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
Energy (Section 3.5)
California Air Resources Board (CARB). 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf. Viewed February 7, 2024.
California Air Resources Board (CARB). 2022b. EMFAC2021 v1.0.1. https://arb.ca.gov/emfac/ Accessed 2022.
California Air Resources Board (CARB). 2023. Advanced Clean Cars II. https://ww2.arb.ca.gov/our- work/programs/advanced-clean-cars-program/advanced-clean-cars-ii Viewed February 7, 2024.
California Energy Commission (CEC). 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” March . https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_ Building_Standards_FAQ_ada.pdf Viewed February 7, 2024.
California Energy Commission (CEC). 2021. 2022 Building Energy Efficiency Standards Summary.
August. https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdate Summary_ADA.pdf Viewed February 7, 2024.
California Public Utility Commission (CPUC). 2021. Natural Gas and California. https://www.cpuc. ca.gov/natural_gas/ Viewed February 7, 2024.
Energy Information Administration, United States (EIA). 2023 a. California State Energy Profile. April
20. https://www.eia.gov/state/print.php?sid=CA Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-4
Energy Information Administration, United States (EIA). 2023b. State Electricity Profiles: Table 1. 2022 Summary Statistics (California). Released November 2 . https://www.eia.gov/electricity /state/california/index.php Viewed February 7, 2024.
LDN Consulting (LDN). 2023. Energy Usage Letter – Woodward 46 Specific Plan (SP22 -0005, SP22- 0006, GPA22-0004, MFSD22-0005, TSM22-0004). August 29.
San Diego Gas & Electric (SDG&E). 2022a. About Us. https://www.sdge.com/more-information/our- company/about-us Viewed February 7, 2024.
San Diego Gas & Electric (SDG&E). 2022b. The Path to Net Zero: A Decarbonization Roadmap for California. April. https://www.sdge.com/sites/default/files/documents/netzero2.pdf. Viewed February 7, 2024.
Geology and Soils (Section 3.6)
California Department of Conservation. 2023. EQ Zapp: California Earthquake Hazards Zone Application. April 4. https://maps.conservation.ca.gov/cgs/EQZApp/app/ Accessed September 21, 2023.
California Geological Survey. 2008. Special Publication 117A Guidelines for Evaluating and Mitigating Seismic Hazards in California. https://www.conservation.ca.gov/cgs/Documents /Publications/Special-Publications/SP_117a.pdf Viewed February 1, 2024.
City of San Marcos. 2012. City of San Marcos General Plan, Safety Element. Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument/8476/636573113845230000 Viewed February 7, 2024.
County of San Diego. 2009. Guidelines for Determining Significance for Paleontological Resources.
January 15 . https://www.sandiegocounty.gov/dplu/docs/Paleo-Guidelines.pdf Viewed February 7, 2024.
GeoTek. 2019. Preliminary Geotechnical Investigation – Proposed Residential Development APN 220- 210-49-00, Northeast of Woodward & Mission, San Marcos, California. May 16.
Hydrology/Water Quality (Section 3.7)
Carlsbad Watershed Management Area. 2022. Overview http://www.projectcleanwater.org/ watersheds/carlsbad-wma/#plan Viewed February 7, 2024..
City of San Marcos. 2017. City of San Marcos Jurisdictional Runoff Management Plan. January 26. https://www.san-marcos.net/home/showpublisheddocument?id=15523 Viewed February 7, 2024.
City of San Marcos 2023. BMP Design Manual for Permanent Site Design, Storm Water Treatments and Hydromodification Management. February. https://www.san-marcos.net/home/ showpublisheddocument/27192/638114580843700000 Viewed February 7, 2024.
Excel Engineering (Excel). 2022. Priority Development Project Stormwater Quality Management Plan Cornerstone Communities Woodward, Woodward Street, San Marcos, CA, September 22.
Excel Engineering (Excel). 2023. Priority Project Hydrology Study for Cornerstone Communities Cornerstone Communities Woodward, Woodward Street, San Marcos, CA, September 22.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-5
Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0793G. https://msc.fema.gov/portal/search Viewed October 16, 2023.
Regional Water Quality Control Board San Diego Region. 2015. Order No. R9 -2015-0100. An Order Amending Order No. R9-2013-001, NPDES No. CAS 010266, As Amended by Order No. R9-2015-001.
National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4s) Draining the Watersheds within the San Diego Region. https://www.waterboards.ca.gov/sandiego/board_decisions /adopted_orders/2015/R9-2015-0100.pdf Viewed February 7, 2024.
State Water Resources Control Board (SWRCB). 2022. California 2020 -2022 Integrated Report (303(d) List/305(b) Report). State Water Board Approval January 19. U.S . EPA Approval May 11. https://www.waterboards.ca.gov/water_issues/programs/water_quality_assessment/ Viewed February 7, 2024.
Land Use and Planning (Section 3.8)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
California Department of Forestry and Fire Protection (CAL FIRE). 2009.
Fire Hazard Severity Zones, San Marcos. https://osfm.fire.ca.gov/what -we-do/community-wildfire- preparedness-and-mitigation/fire-hazard-severity-zones Viewed February 7, 2024.
California Department of Resources Recycling and Recovery (CalRecycle). 202 2. Jurisdiction Diversion/ Disposal Rate Summary . https://www2.calrecycle.ca.gov/LGCentral /DiversionProgram/JurisdictionDiversionPost2006 Viewed February 7, 2024.
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November 16. https://www.san- marcos.net/home/showpublisheddocument?id=25036 Viewed February 7, 2024.
City of San Marcos. 2023. Zoning Ordinance, Section 22.250.020 – Specific Plan Area Zone. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library.municode.com/ca/ san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.250SPPLARZO Viewed February 7, 2024.
Linscott Law & Greenspan (LLG). 2023. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
San Diego Association of Governments (SANDAG). 2002. SANDAG (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region. April https://www.sandiego county.gov/content/dam/sdc/pds/ceqa/LehmanTPM/38%20Appendix%20T9_SANDAG%20Trip%20 Generation%20Rates.pdf Viewed February 2, 2024.
Noise (Section 3.9)
California Department of Transportation (Caltrans) 2020. Transportation and Construction Vibration Guidance Manual. April. https://dot.ca.gov/-/media/dot-media/programs/environmental- analysis/documents/env/tcvgm-apr2020-a11y.pdf Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-6
City of San Marcos. 2023. Zoning Ordinance, Section 20.300.0 70- Performance Standards. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library.municode. com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.300SIPLGEDEST_S20.30
0.070PEST Viewed February 2, 2024.
Federal Transit Administration (FTA) 2018. Transit Noise and Vibration Impact Assessment Manual.
September. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/ transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf Viewed February 7, 2024.
Linscott Law & Greenspan (LLG). 2023. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
LDN Consulting (LDN). 2021. San Marcos Rock Crusher Noise.
LDN Consulting (LDN). 2025. Noise Assessment, Woodward 46 Specific Plan, SP22 -0005, SP22- 0006, GPA22-0004, MFSD22-0005, TSM22-0004, City of San Marcos, January 7.
Public Services (Section 3.10)
California Department of Forestry and Fire Protection (CAL FIRE). 2023. Defensible Space. https://www.fire.ca.gov/dspace Viewed February 7, 2024.
California State University San Marcos (CSUSM). 202 4. Borrowing Books and Media. https://biblio.csusm.edu/content/borrowing-policies-books-and-media Viewed February 7, 2024.
City of San Marcos. 2012a. City of San Marcos General Plan. Parks, Recreation and Community Health Element. Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument /8477/636573113841930000 Viewed February 7, 2024.
City of San Marcos. 2012b. San Marcos General Plan EIR. Adopted February 14.
City of San Marcos. 202 4. Fire Department Overview. https://www.san -marcos.net /departments/public-safety/fire-department/department-overview. Viewed February 7, 2024.
San Diego County Library. 202 4 About the Library. https://www.sdcl.org/about/ Viewed February 7, 2024.
San Diego County Sheriff’s Department (SDCSD). 2024 . San Marcos Station. https://www. sdsheriff.gov/Home/Components/FacilityDirectory/FacilityDirectory/40/ Viewed February 7, 2024.
San Marcos Unified School District (SMUSD). 2023a. SMUSD Fast Facts. https://www.smusd.org/ about_us/district_overview Viewed February 7, 2024.
San Marcos Unified School District (SMUSD). 2023b. Woodward 46 Specific Plan Project Letter from Tova K. Corman, Executive Director Facilities Planning & Development, SMUSD. November 7.
San Marcos Unified School District (SMUSD ) 2023c. Residential and Commercial Developer Fees. https://www.smusd.org/departments/facilities_planning_and_development/residential_and_comm ercial_developer_fee_summary Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-7
Transportation (Section 3.11)
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November https://www.san- marcos.net/home/showpublisheddocument?id=25036 Viewed February 7, 2024.
Linscott Law & Greenspan (LLG). 2023a. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
Linscott Law & Greenspan (LLG). 2023b. Vehicle Miles Traveled Study: Woodward 46 Apartment Project, San Marcos California. March 13, 2023.
Tribal Cultural Resources (Section 3.12)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
City of San Marcos. 202 4. Archaeological and Historical Resources Consultant Guidelines. January. https://www.san-marcos.net/home/showpublisheddocument/27022/638090369405800000 Viewed October 10, 2024.
Utilities and Service Systems (Section 3.13)
California Department of Resources Recycling and Recovery (CalRecycle) . 2019a. SWIS Facility/Site Activity Details: Escondido Resource Recovery (37 -AA-0906). https://www2.calrecycle.ca.gov/Solid Waste/SiteActivity/Details/1830?siteID=2903 Viewed February 7, 2024.
California Department of Resources Recycling and Recovery (CalRecycle) . 2019b. Estimated Solid Waste Generation Rates. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates Viewed February 7, 2024.
California Department of Resources Recycling and Recovery ( CalRecycle). 2022. Jurisdiction Diversion/ Disposal Rate Summary . https://www2.calrecycle.ca.gov/LGCentral /DiversionProgram/JurisdictionDiversionPost2006 Viewed February 7, 2024.
City of San Marcos 2012. Land Use and Community Design Element, City of San Marcos General Plan. https://www.san-marcos.net/work/economic-development/general-plan Viewed February 7, 2024.
County of San Diego. 2005. Integrated Waste Management Plan Countywide Siting Element.
September. https://www.sandiegocounty.gov/content/dam/sdc/common_components/images/dpw /recyclingpdfs/2005_sitingelement.pdf Viewed February 7, 2024.
County of San Diego. 2022. Five-Year Review Report of the Countywide Integrated Waste Management Plan. https://www.sandiegocounty.gov/content/dam/sdc/dpw/SOLID_WASTE_PLANNING_and_ RECYCLING/Files/2022%20Five-Year%20Review.pdf Viewed February 7, 2024.
Metropolitan Water District of Southern California (MWD). 2021. 2020 Urban Water Management Plan (UWMP). June. https://www.mwdh2o.com/media/21641/2020-urban-water-management-plan-june- 2021.pdf Viewed February 7, 2024.
San Diego County Water Authority (SDCWA). 2021. 2020 Urban Water Management Plan (UWMP).
March. https://www.sdcwa.org/wp-content/uploads/2021/03/Draft-2020-UWMP.pdf Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-8
Vallecitos Water District (VWD). 2018. 2018 Water, Wastewater and Recycled Water Master Plan.
October 4. https://www.vwd.org/home/showpublisheddocument/10656/636752049380230000 Viewed February 7, 2024.
Vallecitos Water District (VWD). 2023. Woodward 46 Water and Sewer Study, Work Order #269767, Final Technical Memorandum, prepared by Elizabeth Lopez and Eileen Koonce. April 6.
Alternatives (Section 4.0)
GeoTek. 2019. Preliminary Geotechnical Investigation – Proposed Residential Development APN 220- 210-49-00, Northeast of Woodward & Mission, San Marcos, California. May 16.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
SANDAG. 2023. San Diego Region SB743 VMT Maps. https://www.arcgis.com/apps/webappviewer /index.html?id=bb8f938b625c40cea14c825835519a2b Viewed November 21, 2023.
Vallecitos Water District (VWD). 2023. Woodward 46 Water and Sewer Study, Work Order #269767, Final Technical Memorandum, prepared by Elizabeth Lopez and Eileen Koonce. April 6.
Environmental Effects Found Not to be Significant (Section 5.0) ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
California Department of Forestry and Fire Protection (CAL FIRE). 2009. Fire Hazard Severity Zones, San Marcos. https://osfm.fire.ca.gov/what -we-do/community-wildfire-preparedness-and-mitigation /fire-hazard-severity-zones Viewed February 7, 2024.
California Department of Forestry and Fire Protection (CAL FIRE). 2022. State Responsibility Area Fire Hazard Severity Zones. November 21. https://osfm.fire.ca.gov/media/dqfbrtl1 /fhsz_county_sra_11x17_2022_sandiego_ada.pdf Viewed February 7, 2024.
California Department of Forestry and Fire Protection (CAL FIRE). 2023. Defensible Space. https://www.fire.ca.gov/dspace Viewed February 7, 2024.
Caltrans. 2019. Designated and Eligible Scenic Highways Spreadsheet. https://dot.ca.gov/pro grams/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways Viewed February 2, 2024.
City of San Marcos. 2012. City of San Marcos General Plan , Conservation and Open Space Element and Safety Element. Adopted February 14. https://www.san-marcos.net/home /showpublisheddocument?id=8476 https://www.san-marcos.net/home/showpublisheddocument /8478/636597348039500000 Viewed September 28, 2023.
City of San Marcos. 2020. Final Climate Action Plan. December. https://www.san-marcos. net/home/showpublisheddocument/25084/637435406644270000 Viewed February 7, 2024.
Department of Toxic Substance Control (DTSC) 2023. EnviroStor D atabase. https://geotracker.waterboards.ca.gov/profile_report?global_id=T06019712665 Accessed May 16, 2023.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-9
Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0793G . https://msc.fema.gov/portal/search Viewed February 7, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
San Diego Association of Governments (SANDAG). 2003. Final MHCP Plan – Volume 1. https://www. sandag.org/-/media/SANDAG/Documents/PDF/projects-and-programs/environment/regional- habitat-conservation/volume-1-final-multiple-habitat-conservation-program-plan-2003-03-01.pdf February 7, 2024.
San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan. Adopted January 25, 2010. Amended March 4, 2010, and December 1, 2011. http://www.san.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command=Core_Download &EntryId=2991&language=en-US&PortalId=0&TabId=225 Viewed February 9, 2024.
Vallecitos Water District (VWD). 2023. Woodward 46 Water and Sewer Study, Work Order #269767, Final Technical Memorandum. April 6.
Other CEQA Considerations (Section 6.0)
City of San Marcos. 2021. 2021-2029 Housing Element. July 31. https://www.san- marcos.net/home/showpublisheddocument/25740/637689416879030000 Viewed February 9, 2024.
San Diego Association of Governments (SANDAG). 2022. Series 14 Regional Growth Forecast Documentation and Baseline Subregional Allocation https://www.sandag.org/-/media/SANDAG /Documents/PDF/data-and-research/socioeconomics/estimates-and-forecasts/series-14-regional- growth-forecast-documentation-and-baseline-subregional-allocation.pdf Viewed February 9, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-10
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Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page 8-1
8.0 List of Preparers
City of San Marcos (Lead Agency)
Scott Nightingale, Principal Planner
Norm Pedersen, Associate Planner
Bradley Holder, PE, CFM, Associate Civil Engineer – Land Development Kyrenne Chua, PE, MPA, Senior Civil Engineer
Environmental Impact Report
Sophia Mitchell & Associates, LLC
Sophia Habl Mitchell, LEED AP, Project Manager
Melyssa Sheeran, Senior Environmental Consultant
Air Quality, Energy, Greenhouse Gas, and Noise Reports
LDN Consulting
Jeremy Louden, Principal
Archeological Resources Inventory
ASM Affiliates
Holly Drake, RPA
Shelby Castells, RPA
Biological Resources Report, Rare Plant Surveys and CAGN Surveys Rincon Consultants
Jacob Hargis, Biologist
Jared Reed, Senior Biologist/Project Manager
Kelly Rios, Biologist (Coastal California Gnatcatcher Surveys) Casey Clark, Biologist (Rare Plant Surveys)
Jessica Quinn, Supervising Biologist/Project Manager
Angie Harbin, Director-Natural Resources
Isabelle Radis, GIS Specialist
Abby Robles, GIS Analyst
Biological Resources, Crotch’s Bumble Bee Survey
Alden Environmental
Brian Lohstroh, Principal Biologist
Geotechnical Investigation
GeoTek, Inc.
Christopher D. Livesey, P
Benjamin R. Grenis, RCE
Stormwater Quality Management Plan/Hydrology Report
Excel Engineering
Robert D. Dentino, RCE
Transportation Analysis
Linscott, Law & Greenspan Engineers
John Boarman, PE, Principal
Renald Espiritu, Transportation Engineer II
8.0 Preparers
Woodward Specific Plan Draft EIR March 2025
City of San Maros Page 8-2
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