The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As shown in Table 3.8 -12, the project is consistent with the applicable goals and policies.
3.3.3 Thresholds of Significance
CEQA Guidelines define “significant effect on the environment” as a “substantial or potentially substantial adverse change in the environment.” CEQA Guidelines further indicate that there may be a significant effect on biological resources if the project would:
• Threshold #1: Have a substantial adverse effect either directly or through habitat modifications, on any species identified as a candidate, sensitive or special-status species in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
• Threshold #2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
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• Threshold #3: Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance.
• Threshold #4: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.
As noted above, it was determined that there would be no impact to state or federally protected wetlands, and no impact to wildlife corridors and nursery sites. Section 5.2, Environmental Effects Found Not to be Significant – Biological Resources, of this EIR provides additional information on these topics. The Initial Study is included as Appendix B.1 of this document.
3.3.4 Project Impact Analysis
Development of the proposed project would require grading for site preparation which can result in direct or indirect impact to biological resources. Portions of the common open space area within Lot A would be preserved as biological habitat and subject to an open space easement. The project includes
5.15 acres of common open space – grades 10 percent and greater. The project site contains special- status biological resources, including sensitive vegetation communities and suitable habitat for nesting birds.
As a condition of project approval, the applicant/developer/property owner shall pay Public Facility Fees, a portion of which go towards City-wide habitat conservation efforts.
Table 3.3-2 presents the types and acreage of each vegetation community/land cover type within the project site and the amount that would be impacted by development of the proposed project. These impact numbers include any fire fuel modification areas that would be required for the project. All fire fuel modification for the project would take place on site, no offsite work would be required. There is a total of 0.25 acre s of existing fuel modification easements onsite that are within Diegan Coastal Sage Scrub habitat and are therefore designated as Impact Neutral Areas in the impact calculations (
Figure 3.3-2).
Table 3.3-2. Vegetation Community/Land Cover Types with Project Impact Area Habitat Group Vegetation Community/ Land
Cover Type Sensitive? Total Onsite
(Acres)
Project Impact
(Acres)
C Diegan Coastal Sage Scrub Yes 7.73 5.24
C Disturbed Diegan Coastal
Sage Scrub Yes 0.51 0.26
F Disturbed Habitat No 0.14 0.05
F Urban/Developed No 0.05 0.03
Total 8.43 5.58
Source: Rincon 2025.
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Threshold #1: Have a substantial adverse effect either directly or through habitat modifications, on any species identified as a candidate, sensitive or special -status species in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
Special-Status Plants Species
One special-status species, San Diego sand aster, was considered to have a moderate potential to occur. Neither San Diego sand aster, nor any other rare plant species were detected on-site during the survey. Since the reconnaissance survey was not conducted during the flowering period for potentially occurring sensitive plant species , additional focused rare plant surveys were conducted during the appropriate time in spring and summer 2023. Results from focused rare plant surveys conducted by Rincon in 2023 were negative. San Diego sand aster was not observed during the surveys; therefore, they are presumed absent and no impacts to special -status plant species are anticipated as a result of the project.
Special - Status Wildlife Species
Coastal California Gnatcatcher
CAGN has been identified in the Diegan Coastal Sage Scrub habitat within the project site, including within the overall study area to the east and west. USFWS protocol surveys were conducted in 2018 and preconstruction surveys were conducted in 2020 for the Mission 316 development project parcel south of the project site (KMEA 2020). These surveys recorded individuals foraging, nesting pairs, and two family groups within the project are a. Individuals were also recorded within sage scrub habitat, designated MHCP Hardline Reserve to the west of the project site across Woodward Street. Foraging individuals were also observed and recorded adjacent to the project site on the east, south of Silk Mill Place Road. Protocol surveys conducted in 2023 did not identify any CAGN on the project site (Rincon 2023).
The project could directly impact CAGN through destruction of occupied nests during vegetation removal on the project site if vegetation clearance occurs during the CAGN nesting season (February 15 – August 31). Indirect impacts to CAGN due to construction noise and dust are also possible, which could cause nest failures due to parental abandonment.
The proposed project would directly impact CAGN through the permanent removal of 5.24 acres of suitable, intact Diegan Coastal Sage Scrub, and approximately 0.26 acre of Disturbed Diegan Coastal Sage Scrub (
Figure 3.3-4) habitat types that are used by CAGN for most of its life history. The proposed development area is composed of both dense Diegan Coastal Sage Scrub and Disturbed Coastal Sage Scrub. CAGNs have been observed occupying this habitat during previous protocol and preconstruction surveys as described above.
CAGN that is present both on-site and in adjacent areas would also be potentially affected by indirect impacts associated with the project, such as dust, noise, human presence, nighttime lighting, increase in predators, and spread of non -native species int o occupied habitat. These indirect impacts could result in nest failures or individual mortality of CAGN. The direct and indirect impacts to CAGN are potentially significant (Impact BIO-1) and mitigation is required. • Impact BIO-1 The proposed project has the potential to result in direct and indirect impacts to coastal California gnatcatcher.
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Crotch’s Bumble Bee
CBB has been identified in the south central portion of the project site. In 2024, three surveys were conducted consistent with the recommendations in the CDFW Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (2023), One CBB was observed during the June 6, 2024 survey. The Diegan Coastal Sage Scrub habitat (including D isturbed) on site supports suitable foraging and nesting resources for bumble bees as this habitat contains substantial nectar resources and burrowing a nimal species (lizards, gophers, etc.). Therefore, the site is considered suitable nesting and foraging habitat for species (Alden 2024). Removal of vegetation and grading of the project site has the potential to directly and indirectly impact CBB. The direct and indirect impacts to CBB are potentially significant (Impact BIO-2) and mitigation is required. • Impact BIO-2 Focused surveys found the Diegan Coastal Sage Scrub (including Disturbed) 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.
Other Special-Status Wildlife
Orange-throated whiptail, coastal whiptail, Southern California rufous -crowned sparrow, Cooper’s hawk, and Bryant’s woodrat all have either a moderate or high potential to occur on the project site, primarily within the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub. Southern California rufous-crowned sparrow and Cooper’s hawks are highly mobile and would lik ely escape direct impacts from vegetation removal and grading activities associated with the project by moving into the undisturbed open space to the north, northwest, east, and southeast, unless they are nesting on or adjacent to the site, which is addressed further in Impact -BIO-4, below. Some mortality to the reptile species (Orange-throated whiptail and coastal whiptail) could occur during vegetation removal and grading, but project implementation is not expected to cause a significant impact to the species given the small number of individuals likely to occur within the 5.5 acres of sage scrub habitat to be removed. Woodrat middens were detected on site and individuals could be disturbed or harmed by project construction. The project could potentially impact several special -status wildlife species. This represents a
significant impact (Impact BIO-3) and mitigation measures are required. • Impact BIO-3 The proposed project has the potential to result in direct and indirect impact to special -status wildlife species including Orange -throated whiptail, coastal whiptail, Southern California rufous -crowned sparrow, Cooper’s hawk, , and Bryant’s woodrat.
Nesting Birds and Raptors
The habitats within the project site and study area, which include Diegan Coastal Sage Scrub, provide suitable nesting habitat for a variety of nesting bird species such as passerines and non -passerine terrestrial birds that may nest on the ground or within the scrub vegetation, including coastal California gnatcatcher and southern rufous crowned sparrow. The project site does not contain suitable habitat for raptor species due to the lack of large trees for nesting, however the large stand of eucalyptus trees and riparian woodland habitat within the study area across Woodward Street could provide nesting habitat for raptor species such as red-tailed hawks or Cooper’s hawk. Ornamental palm trees associated with the residential houses on the upper eastern slope off of Silk Mill Place occur within the study area. These trees could potentially provide low quality suitable nesting habitat for raptors.
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The project could impact raptors and other nesting birds , including Cooper’s hawk and Southern California rufous-crowned sparrow, respectively, if construction occurs while they are actively nesting on or adjacent to the project site (January-August). Impacts could occur through direct mortality with vegetation removal and grading or indirectly by nest abandonment, due to construction activities associated with the project such as noise, dust, nighttime lighting, human presence/disturbance, and an increase in predators. Cooper’s hawk has been previously observed over the project site but along with other raptors is not expected to nest on the project site given the lack of trees, although they may nest within the riparian corridor adjacent to the project site. The loss of a nest due to construction activities would be a violation of CFGC Sections 3503, 3503.5, 3511, 3513 and 3800 and the MBTA, and considered a
significant impact (Impact BIO-4). Mitigation is required. • Impact BIO-4 The proposed 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.
Indirect Impacts
Indirect impacts are physical changes to the environment which are not immediately related to a project but may occur at some point in the future due to conditions introduced with implementation of the project. Indirect impacts include urban run -off, introd uction of meso-predators ( e.g., dogs and cats), invasive plant species, and noise and lighting effects. The project has the potential to result in significant indirect impacts to sensitives species (Impact BIO-5) and mitigation is required. • 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.
Threshold #2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? There are no riparian habitats located on the project site (3.3-2). The riparian area located within the western portion of the study area is avoided by the project and separated from project activities by Woodward Street (Figure 3.3-2). Therefore, the project would not have a substantial adverse effect on riparian habitat.
The project would result in the direct removal of 5.5 acres of Diegan C oastal Sage Scrub (including Disturbed) that falls under the City’s Habitat group C definition of Coastal Sage Scrub, which is considered a sensitive habitat. Impacts to vegetation communities are summarized in Table 3.3-1 and shown on Figure 3.3 -4. Existing fuel modification easements total 0.25 acre and are designated as Impact Neutral Areas, and therefore excluded.
Impacts to Diegan C oastal Sage Scrub and Disturbed Coastal Sage Scrub would be considered a significant impact (Impact BIO-6) and mitigation is required. • Impact BIO-6 The proposed project would impact 5.24 acres of Diegan Coastal Sage Scrub and 0.26 acre of Disturbed Diegan Coastal Sage Scrub for a total of
5.50 acres of impact.
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Threshold #3: Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance.
The Conservation and Open Space Element of the City’s General Plan includes policies related to the protection of biological resources. The applicable policies, as well as the project’s consistency with these policies, are presented below:
Conservation and Open Space
Policy
Project Consistency
Policy COS-1.1
Support the protection of
biological resources through the
establishment, restoration, and
conservation of high-quality
habitat areas.
The project site contains suitable and high-quality Diegan Coastal Sage Scrub, with the exception of Disturbed Coastal Sage Scrub, including designated FPA Hardline Reserve habitat to the north and east. The FPA Hardline Reserve habitat is partly within the project site, but not within the proposed project impact area and thus vegetation within is not anticipated to be directly impacted from project implementation. Impacts to Diegan Coastal Sage Scrub has been identified as Impact BIO-6 and mitigation for impacts to Diegan Coastal Sage Scrub is identified in mitigation measure MM-BIO-6, in Section 3.3-6, Mitigation measure MM- BIO-6 requires a total of 5.5 acres of occupied CAGN Diegan Coastal Sage Scrub habitat to be preserved. This can be accomplished through off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the City’s Planning Manager.
Therefore, with implementation of mitigation measure MM-BIO-6, the project would not conflict with this policy.
Policy COS-1.2
Ensure that new development,
including Capital Improvement
Projects, maintain the biotic
habitat value of riparian areas,
oak woodlands, habitat
linkages, and other sensitive
habitats.
The project site does not support any riparian areas, oak woodlands, or habitat linkages. Diegan Coastal Sage Scrub within the project site is considered sensitive (Impact BIO-6); however, mitigation measure MM-BIO-6 would require a total of
5.5 acres of Diegan Coastal Sage Scrub habitat to be preserved.
This can be accomplished through off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the City’s Planning Manager. Therefore, with implementation of mitigation measure MM-BIO-6, the project would not conflict with this policy.
Policy COS-2.1
Provide and protect open space
areas throughout the City for its
recreational, agricultural, safety,
and environmental value.
The project site contains biologically sensitive open space, FPA Hardline Reserve habitat to the north, east, and west across Woodward Street. Impacts to Diegan Coastal Sage Scrub has been identified as Impact BIO-6; however, mitigation measure MM-BIO-6 requires a total of 5.5 acres of occupied CAGN Diegan Coastal Sage Scrub habitat be preserved. This can be
accomplished through off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the City’s Planning Manager.
Therefore, with implementation of mitigation measure MM-BIO-6, the project would not conflict with this policy.
Policy COS-2.2 The project site was anticipated for development and is not identified as being within an FPA in the MHCP. The proposed
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Conservation and Open Space
Policy
Project Consistency
Limit, to the extent feasible, the
conversion of open space to
urban uses and place a high
priority on acquiring and
preserving open space lands for
recreation, habitat protection
and enhancement, flood hazard
management, water and
agricultural resources
protection, and overall
community benefit.
project would impact Diegan Coastal Sage Scrub (Impact BIO-6) and mitigation is proposed (MM-BIO-6) to reduce the impact to this sensitive habitat to below a level of significance. This mitigation measure requires mitigating the loss of the habitat at a 1:1 ratio. This can be accomplished through on-site
preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the City’s Planning Manager. Therefore, with implementation of mitigation measure MM-BIO-6, the project would not conflict with this policy.
Policy COS-2.6
Preserve healthy mature trees
where feasible; where removal
is necessary, trees shall be
replaced at a ratio of 1:1.
The site contains dense, low growing shrubs and scrub species and lacks mature trees. No mature trees were observed within the project site. The proposed project would plant 246 trees, as detailed in the landscape concept plan (Appendix A.2 of the EIR); therefore, implementation of the project would not conflict with this policy.
In summary, the project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Impacts would be less than significant.
Threshold #4: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.
The project site is located within the MHCP, which identifies a series of FPAs within which some lands will be dedicated for preservation of native habitats. Biological Core and Linkage Areas ( BCLAs) were designed to conserve sensitive species and corridors between areas of high- quality habitat and to provide avenues for wildlife movement between these areas. The project impact area is not located within an FPA, however FPA Hardline Reserve habitat is located partly within the northeastern and southeastern corners of the project site, as illustrated in Figure 2-1 of the Final MHCP Plan (AMEC et al. 2003). The project site is not within a BCLA, as illustrated in Figure 2 -3 of the Final MHCP Plan (AMEC et al. 2003). When the FPA was initially created, it intentionally left out this project site (parcel) out, negating any potential impacts.
The proposed project could result in i mpacts to MHCP covered species, CAGN, other special -status wildlife species, and Diegan Coastal Sage Scrub, which is a sensitive vegetation community (Impact BIO-1 through Impact BIO-6). Implementation of mitigation measures have been identified (MM-BIO-1 through MM-BIO-6) which would reduce potentially significant biological resource impacts to below a level of significance.
Therefore, no conflicts with local policies, ordinances, or MHCP provisions are anticipated with the implementation of these mitigation measures.
3.3.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA
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Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future projects producing relat ed impacts; or (2) a summary of projects contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For the purpose of assessing the proposed project’s cumulative impact with respect to biological resources the cumulative analysis is based upon a list approach. All of the cumulative projects within the City, identified in Table 2-4, are considered in this cumulative analysis.
The biological cumulative impact analysis focuses on those projects that would have a similar type of biological resource impact as the proposed project. The project has the potential to cause an impact to CAGN, CBB, other special-status wildlife species, nesting birds, as well as sensitive habitat (Diegan Coastal Sage Scrub).
The cumulative projects which remove Diegan C oastal Sage Scrub or other sensitive habitats would be required to mitigate their impacts at a ratio consistent with the MHCP and the City’s Draft Subarea Plan. Cumulative projects which remove vegetation could also impact special -status species as well as nesting birds. Similarly, such projects would be required to implement mitigation that would require restrictions on construction timing, or the performance of pre -construction surveys to ensure that special-status species, and nesting birds would not be impacted. This is similar to the mitigation identified for the proposed project and would ensure that cumulative impacts are less than significant.
3.3.6 Mitigation Measures
Implementation of the following mitigation measure would be required as a condition of project approval:
California Coastal Gnatcatcher (Impact BIO-1)
MM-BIO-1a An updated presence/absence protocol survey of the project site and a 500 -foot buffer around the project site shall be conducted by a qualified biologist with a valid United States Fish and Wildlife Service 10(a)(1)(A) permit to further evaluate the coastal California gnatcatcher (CAGN) territories that could be affected by short term project construction activities, including vegetation clearance, and long term habitat loss and indirect impacts. In accordance with the USFWS survey protocol, a minimum of six breeding season surveys shall be conducted at least 1 week apart from March 15, through June 30, pending the anticipated construction timeline for the project. The results of the survey shall be submitted to the City and USFWS
upon completion.
If CAGN is detected during the protocol survey, vegetation clearing shall only be conducted between September 1 and February 14, outside of the breeding season for CAGN. If vegetation clearing must start outside of those dates, then focused nesting surveys would be conducted prior to vegetation clearing for the project site and a 500-foot buffer zone. No more than 3 days prior to the clearing of vegetation, a qualified biologist shall conduct a pre-construction clearance survey for CAGN to confirm that the vegetation on -site is not occupied by the species. If nests are found, they would be avoided by establishing a 500 -foot non-disturbance buffer around the nest. Vegetation clearance may continue with regular biological monitoring if there is no indication o f disturbance to the nest(s). If the vegetation
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clearance is potentially disruptive to active nests a larger buffer may be implemented as determined by the qualified biologist. If CAGN are observed moving through the area during vegetation clearing activities, the project biologist may delay the removal of vegetation and/or grading until CAGN has left the area of their own volition.
If CAGN is found to be within the survey area (project site plus a 500 -foot buffer) during protocol or pre -construction surveys, the following avoidance and minimization measures shall be implemented.
a) To reduce potential noise impacts to nesting CAGN, a qualified biologist shall monitor noise levels with a noise monitoring device at an appropriate distance from the nest to determine if construction activity noise is above 60 dBA Leq, the standard level requested by the USFWS, or if noise levels above 60 dBA Leq have the potential to affect any CAGN nests.
b) If/when an active CAGN nest is identified, an acoustician shall monitor noise at the edge of construction as directed by the qualified biologist. If noise levels continue to exceed 60 dBA Leq, the acoustician shall consult with the qualified biologist and provide requirements for the construction contractor to make operational and barrier changes to reduce noise levels to 60 dBA Leq during the breeding season (February 15 through August 31). Noise monitoring shall occur during operational changes and instal lation of barriers, as needed, to ensure their effectiveness. If the noise meets or exceeds the 60 dBA Leq threshold, or if the biologist determines that the activities in general are disturbing the nesting activities, the biologist shall have the authority to halt construction and shall consult with t he USFWS to devise methods to reduce the noise and/or disturbance in the vicinity. This may include methods such as, but not limited to, turning off vehicle engines and other equipment whenever possible to red uce noise, installing a protective noise barrier between the nesting coastal CAGN and the activities, and working in other areas until the young have fledged.
All active nests shall be reported within 24 hours to the USFWS upon detection.
MM-BIO-1b Long-Term Open Space Management
A long-term open space management plan shall be developed to minimize impacts of the residential development on the adjacent coastal California gnatcatcher (CAGN) and Diegan Coastal Sage scrub habitat. The adjacent area falls within a Multiple Habitat Conservation Program Hardline Reserve, occupied by CAGN, and additional mitigation measures are necessary to minimize impacts associated with increased human and domestic pet presence from the project. The plan shall include a program of education to reduce domestic and feral cat encroachment (using the program developed by the American Society for the Prevention of Cruelty to Animals). Use of invasive exotic plant species in landscaped areas adjacent to or near sensit ive vegetation communities shall be restricted. The applicant shall encourage the use of native species in the landscaping plan and shall avoid the use of species listed in Lists A & B of the California Invasive Plant Council's list of Exotic Pest Plants of Greatest Ecological Concern in California as of October 1999.
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This list includes such species as pepper trees ( Schinus mole ), pampas grass (Cortaderia selloana ), fountain grass, ice plant ( Carpobrotus sp.), myoporum (myoporum sp.), black locust ( Robinia pseudoacacia), capeweed (Arctotheca calendula), tree of heaven ( Ailanthus altissima), periwinkle Vinca major), sweet alyssum (Lobularia maritima), English ivy (Hedera helix), French broom ( Genista monspessulana), Scotch broom (Cytisus scoparius), and Spanish broom (Spartium junceum). The plan shall also address permanent residential lighting to be directed away from the open space.
Crotch’s Bumble Bee (Impact BIO-2)
MM-BIO-2 MM-BIO-2 Focused surveys found the Diegan Coastal Sage Scrub on site to be occupied by Crotch’s bumble bee (CBB). Thus, there is potential for take of CBB and adverse impacts may occur through the removal of occupied habitat. However, the project would incorporate the following CBB avoidance , minimization and mitigation measures to avoid take and reduce significant impacts to below a level of significance. should the species remain a candidate for state listing. If the State ultimately does not list Crotch’s bumble bee under the California Endangered Species Act and the species i s removed from candidate status, the mitigation measures outlined below would no longer be applicable.
Avoidance, Minimization, and Mitigation Measure for Crotch’s Bumble Bee Prior to the Notice to Proceed (NTP) for any construction permits, including but not limited to, the first Grading Permit, The City shall verify the following project requirements regarding the CBB are shown on the construction plans. Should this species no longer be a potential candidate for listing at the time of the preconstruction meeting, then no avoidance measures shall be required.
Incidental Take Permit:
• Crotch’s bumble bee has been detected onsite, and all suitable habitat is considered occupied. As avoidance of impacts is not feasible, the Project applicant shall consult with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq.).
If an Incidental Take Permit is issued, the Project applicant shall comply with the mitigation measures detailed in the take authorization issued by CDFW. In addition, the terms and conditions of that permit shall supersede any conflicting measures contained in this document. The Project applicant shall provide a copy of a fully executed take authorization prior to the issuance of a grading permit and before any ground disturbance and vegetation removal. Should the State decline to list the species under the California Endangered Species Act and remove its candidate status, this measure shall no longer be applicable, and an Incidental Take Permit will not be required.
Pre-activity surveys:
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• To avoid direct impacts on CBB , removal of habitat (i.e., defined as any habitat disturbance) in the proposed area of disturbance must occur outside of the Colony Active Period (generally occurring between February 1 April 1 through August 31). If the removal of habitat in the proposed area of disturbance must occur during the Colony Active Period, a Qualified Biologist shall conduct a pre -activity (defined as any habitat disturbance) survey no more than three days prior to the initiation of construction activities to determine the presence or absence of CBB within the proposed area of disturbance following CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023) or the latest guidance from CDFW no more than 10 days and no less than 3 days prior.
• A Qualified Biologist must meet the qualifications discussed in the CDFW guidance (i.e., Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species, dated June 6, 2023). Resumes shall be provided to CDFW for review. demonstrate the following qualifications:
at least 40 hours of experience surveying for bee or other co -occurring aerial invertebrate species (such as Quino checkerspot butterfly) and have completed a CBB detection/identification training by an expert CBB entomologist; or the biologist must have at least 20 hours of experience directly observing CBB.
• The pre -activity survey shall consist of non -lethal photo vouchers photographic surveys following California Department of Fish and Wildlife (CDFW) guidance (CDFW 2023). (i.e., Survey Considerations for California Endangered Species Act [CESA] Candidate Bumble Bee Species, dated June 6, 2023). The surveys shall consist of passive methods unless a Memorandum of Understanding is obtained. The Qualified Biologist shall send all photographic vouchers to a CDFW approved taxonomist to confirm the identifications of the bumble bees encountered during surveys. If candidate bumble bees will be captured or handled during surveys, then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific Collecting Permit pursuant to CDFW guidance (CDFW 2023).
If additional activities (e.g., capture or handling) are deemed necessary to identify bumble bees of an unknown species that may be CBB , then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific Collecting Permit pursuant to CDFW Survey Considerations for CESA Candidate Bumble Bee Species (CDFW 2023). Survey methods that involve lethal take of species are not acceptable.
• If pre -activity surveys identify CBB individuals on -site, the Qualified Biologist shall notify and consult with CDFW to establish, monitor, and maintain no-work buffers around the associated floral/nest resources or identified nesting locations . The size and configuration of the no-work buffer shall be based on the best professional judgment of the Qualified
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Biologist in consultation with CDFW. Construction activities shall not occur within the no-work buffers until the bees appear are no longer active (i.e., associated floral resources appear desiccated and no bees are seen flying for three consecutive days indicating dispersal from the area). Take of any endangered, threatened, candidate species that results from the project is prohibited, except as authorized by State law (Fish and Game Code section 86, 2062, 2067, 2068, 2080, 2085; California Code Regulations, Title 14, section 786.9) under CESA.
• Survey data shall be submitted by the Qualified Biologist to the California Natural Diversity Database (CNDDB) in accordance with the Memorandum of Understanding with CDFW, or Scientific Collecting Permit requirements, as applicable.
Compensatory Mitigation for Impacts to Crotch’s Bumble Bee Habitat Should the species be formally listed, or remain a candidate for listing, mitigation for the loss of CBB occupied Diegan Coastal Sage Scrub shall be conducted to reduce impacts to less than significant. This mitigation will be carried out in conjunction with the Diegan coastal sage scrub mitigation described in MM-BIO-6. Specifically, the Diegan coastal sage scrub mitigation shall include habitat compensation at a minimum 1:1 ratio or as negotiated through consultation with the CDFW for an Incidental Take P ermit, to also benefit the CBB. This mitigation may be satisfied through off -site acquisition, in lieu fees, purchase of credits from an approved mitigation bank, or a combination thereof. If necessary, habitat enhancement or restoration also may be incorporated, to be described in a Habitat Management and Monitoring Plan (i.e. planting of native Diegan coastal sage scrub flowering plant species known to support bumble bee populations, removal of invasive species, etc.).
If prepared, the HMMP or other plans for Crotch’s bumble bee habitat enhancement or restoration will be provided to CDFW for review and approval.
Any land acquired as off -site mitigation to benefit CBB shall include a cost estimate for long -term management, an endowment, and a land protectio n mechanism such as a conservation easement. Mitigation lands for CBB must be occupied or include high quality suitable habitat. This species shall also be included in the Worker Environmental Awareness Program educational program described in MM-BIO-3a and BMP’s implemented per MM-BIO-3c.
Direct and Indirect Impacts to Sensitive Wildlife Species (Impact BIO-3) MM-BIO-3a Worker Environmental Awareness Program (WEAP) The applicant shall implement a Worker Environmental Awareness Program (WEAP) for the construction crew that will be developed by a qualified biologist.
Each employee (including temporary, contractors, and subcontractors) will receive the WEAP presentation on the first day of project work. They will be advised of sensitive species in the area and avoidance measures being implemented to protect them at the site. At a minimum, the WEAP will include the following topics:
occurrence of the listed and sensitive species in the area, their general ecology, sensitivity of the species to human activities, legal protection afforded these species, penalties for violations of federal and State laws, reporting requirements,
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and project features and conditions designed to reduce direct and indirect impacts to these species, role of the Biological Monitor, and worker responsibilities to maintain compliance with mitigation measures while working at the site.
MM-BIO-3b Work Limit Delineations
Approved construction work area limits shall be delineated and marked clearly, by flagging or temporary orange construction fencing, in the field prior to vegetation removal. The marked boundaries shall be maintained and clearly visible to personnel on foot and by heavy equipment operators. Fencing shall be placed on the impact side of the work area to reduce the potential for encroachment and additional vegetation loss within adjacent open space. Fencin g shall be put in place by a qualified surveyor per the project applicant’s approved construction and grading plans. All temporary fencing shall be removed only after the conclusion of all grading, clearing, and construction. Employees shall strictly limit their activities and vehicles to the designated proje ct areas, staging areas, and routes of travel.
The biological monitor shall verify that the limits of construction have been properly staked and are readily identifiable. Intrusion by unauthorized vehicles outside of construction limits shall be prohibited , with control exercised by an on -site foreman. Access routes to the construction area outside of work hours shall be blocked with physical barriers, such as concrete blocks or large equipment.
MM-BIO-3c Biological Monitor and Construction BMPs
A City of San Marcos -approved, qualified biologist shall be present during all vegetation clearing and other activities with the potential to affect coastal California gnatcatcher ( CAGN), orange throated whiptails, coastal whiptails, Bryant’s woodrat, Coopers hawks, and southern rufus -crowned sparrow, nesting birds, and any other sensitive plant or wildlife resource, and will monitor the project for avoidance of unanticipated impacts to the aforementioned species and their habitats. Standard construction Best Management Practices will be implemented by the contractor to minimize potential impacts to sensitive species. The biologist shall have the authority to halt all associated project activities that may be in violation of the protective measures. Daily monitoring logs shall be maintained and a monthly report of compliance with biological resource measures will be provided to the City during construction. Standard Construction Best Management Practices shall include the following:
Vehicle speeds will not exceed 10 miles per hour (mph) adjacent to CAGN habitat. Clear signage will be installed and maintained throughout the construction period.
Placement of drip pans under parked equipment and vehicles. Regular inspection and maintenance of equipment to avoid spills and immediate containment of any spills.
Chemicals. Herbicides, and pesticides will not be used. Pets and firearms will not be allowed at the site.
Trash will be removed from the site daily or be stored in wildlife proof containers
Stormwater protection ( i.e., straw waddles, silt fence) will be employed to prevent spills, runoff, or sediment from entering nearby aquatic habitats.
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These materials will be weed free and no project debris or rubbish will be allowed to enter into or be placed where it may be washed by rainfall or runoff in the wetlands.
Staging/storage areas for equipment and materials will be located at least 100 feet away from the riparian areas. Equipment will be checked and maintained daily to prevent leaks of pollutants into the wetlands. No equipment maintenance will be carried out within 100 feet of the riparian area.
All pipes, culverts, or similar structures with a 4 -inch diameter or greater that are stored on the construction site overnight shall be thoroughly inspected for wildlife or nesting birds before the pipe is subsequently curried, capped, or otherwise used or moved in any way.
To prevent inadvertent entrapment of wildlife during construction, all excavated, wells, steep-walled holes, or trenches more than 2 feet deep shall be covered with plywood or similar materials at the close of each working day. Any construction lighting will be directed toward the work area and away from adjacent habitats.
MM-BIO-3d Woodrat Middens
Woodrat middens (nests) are large nests or dens made of woody debris, such as sticks, dead cacti, and bark. Middens were observed throughout the project site and within the project impact area. The project may contain both big-eared woodrat Bryant’s woodrat and all middens will be treated as potentially sensitive. Within 30 days of initial site disturbance, a pre -construction survey shall be conducted for woodrat middens. All occupied woodrat middens shall be mapped and flagged for avoidance to the extent feasible, with a minimum of 10-feet surrounding the active midden. If avoidance is not feasible, middens will be disturbed “daylighted” by a qualified biologist one night before anticipated vegetation removal to allow for the rats to escape and passively relocate prior to disturbance of the area.
Nesting Birds and Raptors (Impact BIO-4)
MM-BIO-4 If site clearing activities are conducted between January 1 and August 31, a qualified biologist shall conduct a nesting bird survey no more than 3 days prior to the start of such activities to identify actively nesting birds within the project site and a 500-foot buffer around the project site. If any nests are found, their locations shall be flagged and an appropriate avoidance buffer, ranging in size from 25 to 50 feet for passerines, and up to 500 feet for raptors depending upon the species and the proposed work activity. The non -disturbance buffer zone shall be determined and demarcated by a qualified biologist with bright orange construction fencing or other suitable flagging materials. Active nests shall be monitored at a minimum of once per week until it has been determined that the nest is no longer being used by either the young or adults. No disturbance shall occur within this buffer until the qualified biologist confirms that breeding/nesting is completed, and all the young have fledged. If project activities must occur within the buffer, activities shall be conducted at the discretion of the qualified biologist and with monitoring and management to confirm that nesting birds and the nests are not disturbed. If no nesting birds are observe d during the nesting survey or during other monitoring activities, then no further actions shall be necessary. A
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follow-up survey will be needed if site clearing does not occur within 3 days after the initial survey and/or a pause in construction activity occurs for more than 7 days.
Indirect Impacts to Sensitive Species (Impact BIO-5)
Implementation of mitigation measures MM-BIO-3a through MM-BIO-3d, described above would reduce potential indirect impacts to sensitive species.
Impact to Sensitive Habitat (Impact BIO-6)
MM-BIO-6 The permanent loss of 5.5 acres of Diegan Coastal Sage Scrub, and Disturbed Diegan Coastal Sage Scrub shall be mitigated at a minimum 1:1 ratio. Section
5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on -site mitigation, off -site acquisition, in -lieu fees, or and mitigation credits. For mitigation purposes, the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub acreages on the project site that would be impacted have been combined as these two vegetation communities are considered to have similar sensitivity under the Multiple Habitat Conservation Program. Thus, 5.5 acres of occupied coastal California gnatcatcher Diegan Coastal Sage Scrub will be preserved by the project applicant through off -site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City of San Marcos Planning Manager and the Wildlife Agencies wildlife agencies prior to issuance of the grading permit. If on site or off-site habitat mitigation will be completed by the Applicant to satisfy the compensatory mitigation requirements, it shall be carried out in accordance with a Habitat Mitigation and Monitoring Plan (HMMP) that outlines the strategy for enhancement and maintenance of the habitat for locally sensitive species occupying Diegan Coastal Sage Scrub.
The HMMP will be provided to Wildlife Agencies for review and approval. Any land acquired as off -site mitigation to benefit gnatcatcher shall include a cost estimate for long -term management, an endowment, and land protection mechanism such as a conservation easement. Mitigation lands for gnatcatcher must be occupied or include high quality suitable habitat.
3.3.7 Conclusion
Development of the proposed project would result in potential direct and indirect impacts to CAGN, CBB, other special-status wildlife species, and nesting birds. Implementation of mitigation measures MM-BIO-1 through MM-BIO-6 would reduce potential direct and indirect impacts to sensitive wildlife species to below a level of significance. These measures require pre-construction surveys during the applicable nesting seasons and other measures to ensure that there are no direct impacts to CAGN, Bryant’s woodrat, other sensitive species, and nesting birds.. The proposed project would also impact
5.5 acres of Diegan coastal sage scrub habitat. The project would mitigate the impact at a 1:1 ratio, as identified in mitigation measure MM-BIO-6. Per mitigation measure MM-BIO-6, 5.5 acres of CAGN- occupied Diegan Coastal Sage Scrub and disturbed Diegan coastal sage scrub would be preserved by the project applicant through off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City’s Planning Manager and wildlife agencies prior to issuance of the grading permit. In addition, MM- BIO-2 includes consultation with CDFW, potentially an Incidental Take Permit, and requires that the
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habitat compensation for Diegan Coastal Sage Scrub includes enhancements to benefit CBB. The Diegan Coastal Sage Scrub mitigation identified under MM -BIO-6 would also serve as the habitat mitigation for CBB. In summary, all biological resources impacts would be reduced to below a level of significance.
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Figure 3.3-1. MHCP Conservation Areas in Project Vicinity
Source: Rincon 2025.
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Figure 3.3-2. Vegetation Communities and Land Cover Types within Project Site and Study Area
Source: Rincon 2025.
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Figure 3.3-3. Biological Resources Map
Source: Rincon 2025.
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Figure 3.3-4. Vegetation Communities and Land Cover within Project Impact Area
Source: Rincon 2025.
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3.4 Cultural Resources
Introduction
This section identifies the cultural resources on the project site and analyzes the potential impacts of the proposed project on cultural resources. Cultural resources considered in this analysis include archaeological ( precontact Native American [ prehistoric] and non -Native American historic -era) resources, historical resources, unique archaeological resources, and human remains . Tribal Cultural Resources are analyzed in Section 3.12 of the Environmental Impact Report (EIR) 4.
The analysis in this section is based upon the following report prepared by ASM:
• Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California (ASM 2024)
Due to the confidential nature of the archaeological report, it is not included as a technical appendix to the EIR. The archaeological resources inventory report included a record search, literature review, correspondence with Native American contacts, and field survey. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s web site.
5 In the Initial Study checklist prepared for the proposed project (Appendix B.1), it was determined that there would be no potential for the proposed project to have an adverse impact on historic resources since none were identified on the site. Section 5.4, Environmental Effects Found Not to be Significant – Cultural Resources of this EIR provides additional information on this topic.
Table 3.4-1 summarizes the project- and cumulative-level cultural resources impacts, by threshold.
Table 3.4-1. Cultural Resources Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 – Cause a substantial adverse
change in the significance of a
historical resource pursuant to
Section 15064.5.
No Impact No Impact No Impact
#2 – Cause a substantial adverse
change in the significance of an
archaeological resource pursuant to
Section 15064.5.
Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant
#3 – Disturb any human remains,
including those interred outside of
dedicated cemeteries.
Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant
4 Full references for documents cited in this section are included in Chapter 7, References, of this EIR. 5 http://www.san-marcos.net/work/economic-development/general-plan
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3.4.1 Existing Conditions
Records Search
Previous Cultural Resources Reports
A records search request was submitted to South Coastal Information Center (SCIC), San Diego State University on December 30, 2022 . The records search results identified that 81 previous cultural resources studies have been conducted within one mile of the project area , with three studies that intersected the proposed project area. One archaeological study was conducted by Carrico (WESTEC) in 1976. Three other regional overview studies ) of the larger overall area can also be considered encompassing the current project area, though the level of investigation and applicability of the results towards the current study are at-best supplementary (ASM 2024).
Previously Recorded Cultural Resources
The SCIC records search did not identify any cultural resources within the project area. The records search identified 40 previously recorded cultural resources within a one -mile radius of the project location with none identified as intersecting the project area. Two cultural resources (SDI-21254 and SDI-23161) have been previously recorded in the vicinity of the proposed project area.
SDI-23161 was recorded in 2018 as a multi -component site consisting of four bedrock milling features, sixteen historic features and historic debris. No subsurface deposits were identified during testing and the site was recommended not eligible to the Cali fornia Register of Historic Resources (CRHR).
SDI-21254 was recorded in 2014 as the ruins of a historic structure and was recommended not eligible to the CRHR. During construction monitoring in 2015 a prehistoric cultural deposit was identified consisting of a scatter of lithic artifacts, marine shell , and historic artifacts. One piece of possible human remains was identified during monitoring. The City of San Marcos and the San Luis Rey Band of Mission Indians consulted and further testing at the site identified 157 prehistoric artifacts. The site was recommended not eligible to the CRHR, however due to the possible human remain, the site was determined to be significant under CEQA (ASM 2024).
No historical addresses are located within the project area; however, three historical addresses were previously recorded within one mile of the project area including, the San Marcos Forest Fire Station Gas & Oil House and two single family residences. The San Marcos Forest Fire Station Gas & Oil House (P-37-014081) was previously recommended eligible for the National Register of Historic Places (NRHP) under Criteria A and D , however it was reevaluated and determined not eligible based on its current condition in 2023. (ASM 2024).
Archival Research
In addition to the SCIC records search, ASM conducted an on -line review of historic al aerial photographs of the project area and general vicinity, to help determine the possible development and land use of the project area in the past. The earliest-available aerial images of the property were from 1928 and the most recent google earth image dates to 2021. Table 3.4-2 summarizes the historical aerial photographic review.
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Table 3.4-2. Historical Aerial Photograph Review
Date Description
1928 Project area consisted of two graded areas with a dirt road connecting the two.
1938 At least one of the roadways appears to have been abandoned. 1953-1964 Between 1953 and 1964, another episode of disturbance is visible on the aerial imagery.
1980 A four-sided feature is visible in these graded areas. 1987 The four-sided feature is no longer visible.
Post 1987 Activity in the project area appears to be sporadic and included clearing of some of the previously cut roadways.
2021
In the most-recent google earth images dating to 2021, a small approximately 7-x-10-ft feature is visible in the southern portion of the project area. During the survey, it was determined that this feature was an abandoned asphalt-related machine.
Source: ASM 2024.
Natural Setting
The project area lies on the coastal plain of San Diego County in the Coastal Province and western Peninsular Range Province. The coastal strip has a 130-km-long shoreline and is comprised of raised Pleistocene marine and non-marine terraces ranging from 20 to 5 km in width . Cretaceous, Tertiary, and Quaternary marine and non-marine sedimentary deposits define these terraces, which have been extensively modified by erosion. Drainages of varied catchment size are closely spaced along the coast, and lagoons have formed at the mouths of many of these rivers. San Marcos is part of the central coastal plain (ASM 2024).
The project site is currently undeveloped, vacant land. Per the biological resources report prepared for the project, the majority of the project area is very rugged with large boulder outcroppings, with a steep hillside sloping down towards the Mission Villas development south of the project site (Rincon 2025).
Elevation ranges from 754 feet above mean sea level (amsl) from the east, 700 feet from the northern boundary of the project, sloping down to 615 feet in the southwestern portion. The site generally slopes from higher elevation to the north and east downward towards Woodward Street. Large boulders were observed distributed throughout the site. No drainages occur on the project site. The project site contains Diegan Coastal Sage Scrub (including disturbed) and the developed Woodward Street. The central portion of the project site shows a history of anthropogenic disturbances with disturbed habitat, trash, and old equipment observed (Rincon 2025).
Archaeological Context
Archaeological fieldwork along the southern California coast has yielded a diverse range of human occupation extending from the terminal Pleistocene into the Ethnohistoric period. A variety of different regional chronologies, often with overlapping terminology, have been used in coastal southern California, and they vary from region to region. Today, the prehistory of San Diego County is generally divided into three major temporal periods: Paleoindian, Archaic, and Late Prehistoric . These time periods are characterized by patterns in material culture that are thought to represent distinct regional
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trends in the economic and social organization of prehistoric groups. The following information on these periods is from the archaeological resources survey and evaluation report for the project by ASM (2024).
Paleoindian Period
The antiquity of human occupation in the New World has been the subject of considerable debate over the last few decades. A widely accepted model is that humans first entered the western hemisphere between 12,000 and 15,000 years B.P. While there is no firm evidence of human occupation in coastal southern California prior to 12,000 B.P., dates as early as 23,000 B.P. and even 48,000 B.P. have been reported. The amino acid racemization technique used to date these sites has been largely discredited, however, by more recent accelerator radiocarbon dating of early human remains along the California coast . Despite intense interest and a long history of research, no widely accepted evidence of human occupation of North America dating prior to 15,000 B.P. has emerged (ASM 2024).
The Paleoindian period begins with Clovis occupation, a widespread phenomena in North America.
Noted for its distinctive tool kit characterized by fluted points, Clovis occupation dates to the end of the Pleistocene, from 11,200 B.P. to 10,600 B.P. The Pal eoindian period in San Diego County is considered to date to the terminal Pleistocene and the early Holocene, from at least 10,000 B.P. to 8500/7500 B.P. Although no Clovis sites are documented in the region, occasional isolated fluted points have been recovered. A variety of terms have been proposed for Paleoindian assemblages in the southern California region. Rogers, the first to temporally order the archaeological assemblages of the region, introduced and later discarded the terms Scraper-Makers, Malpais and Playa to label early lithic industries of the region then coined the term San Dieguito, still widely used today, to refer to the earliest artifact assemblages in San Diego County. San Dieguito assemblages are composed almost entirely of flaked stone tools, including scrapers, choppers, and large projectile points. Until recently, the near absence of milling tools in San Dieguito sites was viewed as the major difference between Paleoindian economies and the lifeways which characterized the later Archaic period (ASM 2024).
The terminal Pleistocene San Dieguito adaptation occurred within a climatic period of somewhat cooler and moister conditions than exist presently. The range of possible San Dieguito economic adaptations and the interpretation of the San Dieguito complex as a big game hunting tradition are based primarily on materials from the Harris Site . Subsequently, it was hypothesized that differences between San Dieguito and the subsequent La Jolla artifact assemblages may reflect functional differences rather than temporal or cultural variability (ASM 2024).
Archaic Period
The Archaic period (similar to the Encinitas tradition and the Millingstone horizon) began between 9,000 and 8,500 years ago and ended between 1,300 and 800 years ago. A distinction is often made between coastal shell midden sites (La Jolla complex) and inland non -shell midden sites (Pauma complex). Shell middens are generally characterized by flaked cobble tools, basin metates, manos, discoids, and flexed burials. Three temporal phases have been distinguished within the Archaic period (ASM 2024).
Initial Archaic exploitation of the San Diego area littoral zone is generally considered to have entailed sizable semisedentary populations focused around resource -rich bays and estuaries . Shellfish were interpreted as a dietary staple; plant resources (both nuts and grasses) were also an important dietary component, while hunting and fishing were less important. This adaptive strategy remained largely unchanged for several thousand years. The La Jolla Complex reached its population and cultural climax between 7000 and 4000 years ago when there was a plentiful supply of shellfish in the lagoons along
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the coast. Major changes in human adaptations occurred after 4,000 years ago when estuarine silting was considered to have become so extensive as to cause a decline in associated shellfish populations.
A major depopulation of the coastal zone has been post ulated, with settlements shifting inland to a river valley orientation, intensifying exploitation of terrestrial small game and plant resources, possibly including acorns. The coast was abandoned or only seasonally occupied, with a possible slight increase in coastal occupation after 1,600-1,200 years ago (ASM 2024).
Late Prehistoric Period
The Late Prehistoric period is generally considered to have begun between 1,300 and 800 years ago or the equivalent of between A.D. 700 and 1250. Local regional cultural complexes have been distinguished between the northern area (San Luis Rey complex), so uthern coastal area (Yuman complex), and the southern inland area (Cuyamacha complex). In general, this period was characterized by the appearance of small pressure -flaked arrow points (Cottonwood Triangular and Desert Side-notched points) indicative of bow and arrow technology, the appearance of ceramics, the replacement of flexed inhumations with cremations, the possible appearance of the mortar and pestle, and an emphasis on inland plant food collecting and processing, especially of acorns . The precise timing of the introduction of these items is still debated due to the poor chronological resolution and bioturbation at multicomponent sites . In addition, recent research is revealing the persistence of inhumations throughout most of the late Holocene in northern coastal San Diego (ASM 2024).
Explanations for the origin of the Late Prehistoric period vary. It has been speculated that Uto-Aztecan- language speakers migrated from the deserts to the southern coast of California at least 1,000-1,500 years ago. Some archaeologists have embraced this hypothesis and correlated it with the origins of the Late Prehistoric period. The Luiseño and Kumeyaay were initially discussed under the rubric of the Mission Indians and were distinguished from earlier shell -midden and scraper -maker cultures.
Archaeologists later argued for continuity in occupation from the Archaic to the Late Prehistoric period and distinguished three phases of shell middens. It was believed that the Kumeyaay culture of 500 years ago was the result of earlier migration of Yuman populations from the coast to the Colorado River (perhaps as the result of an influx of Shoshone populations in northern San Diego County), adaptation to this new riverine setting and adopting traits from adjacent populations in the Southwest, and subsequent movement back to the coast at the onset of the Late Prehistoric period. Subsequently, scholars have emphasized several cultural processes to explain Late Prehistoric cultural developments including: a chronological gap , cultural continuity and the addition of new traits , a population replacement, or that several factors were at play (ASM 2024).
The San Luis Rey complex in the northern inland area was generally applied to the north coast region.
It has been suggested that the San Luis Rey I phase began around A.D. 1400 and included small triangular arrow points, manos, portable metates, mortars, pestles, Olivella beads, and stone pendants. The San Luis Rey II phase differed only in the addition of ceramics and pictographs around A.D. 1750. It was further hypothesized that the lower portions of the San Luis Rey drainage had sedentary villages with limited use of marine resources. The Late Prehistoric period has been paradigmatically linked with the subsequent ethnohistoric record, and direct historical analogies assume considerable adaptive stability for populations, linguistic groups, and their territorial extent as documented by Europeans (ASM 2024).
Ethnographic Context
The Post-Contact period began in A.D. 1769 with the Spanish establishment of the Mission San Diego de Alcalá. Yet Spanish explorers first encountered Native Americans in the San Diego area in A.D. 1542
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when Cabrillo landed at Point Loma along San Diego Bay . The local inhabitants would have been negatively affected by protohistoric transmission of diseases via sea visits and through contact with Native Americans in the Baja California region. Portolá ’s A.D. 1769 expedition from San Diego to Monterey documented a series of Native American coastal villages in the San Diego area, typically situated along the region's major drainages . The subsequent establishment of the San Juan Capistrano Mission in 1776 and the San Luis Rey de Francia Mission in 1798 further impacted traditional coastal settlement systems. Acculturation, assimilation, and the introduction of Old World diseases greatl y disrupted and reduced Native American populations, and by the early 1800 s traditional coastal villages were largely abandoned . As a result, we know very little about traditional coastal life, except what can be gleaned from mission records. Nineteenth and twentieth century ethnohistoric reconstructions provide only minimal insight into coastal adaptations – particularly with respect to such issues as cultural complexity, population densities, and regional interaction – and are built from the perspective of remnant inland populations and their occasional seasonal exploitation of a littoral zone dominated and largely controlled by European settlers (ASM 2024).
From north to south, coastal San Diego was occupied by the Juaneño, Luiseño, and Kumeyaay Native American groups. The Juaneño and Luiseño are Uto-Aztecan speakers whose territory ranged from Agua Hedionda Lagoon (or possibly Batiquitos Lagoon) in the south to Aliso Creek in Orange County, to near Santiago Peak in the northeast, and to the Palomar Mountain area in the southeast. They are linguistically and culturally related to the Gabrielino and the Cahuilla. The terms Juaneño and Luiseño are derived from a ssociation with the San Juan Capistrano and San Luis Rey missions respectively, along the coast. Some archaeologists recognized Juaneño as a dialect of Luiseño, while others viewed the Juaneño as part of the Luiseño on the basis of cultural and linguistic similarities. Little or nothing is known about the coastal Juaneño-Luiseño, and hence the following ethnohistoric observations are largely based on inland Luiseño (ASM 2024).
During this period, the Luiseño people had a fairly rigid social structure and a moderately high population density. Maximum population estimates at Spanish contact range from 5,000 to 10,000.
With a territory extending for almost 4,000 km², maximum population density estimates range from
1.25 to 2.5 persons per km² (3.3 to 6.7 persons per mi
2). It has been estimated that the Luiseño
included approximately 50 villages of 200 individuals each, or using Portolá expedition observations, that village size was c loser to 60. Recent research with mission records suggests that village size varied significantly in the eighteenth century, with larger villages such as Topome along the Santa Margarita River consisting of multiple clans (ASM 2024).
The Luiseño are divided into several autonomous lineages or kin groups based on patrilineal descent groups and a patrilocal residential pattern. Each Luiseño lineage is based around an autonomous village that held collective ownership over a well- defined territory for hunting and gathering, and violations of trespass were punished. Village territories may have ranged from as little as 10 km² near the coast along major drainages such as the San Luis Rey River to as much as 100 km² elsewhere. A variety of sho rter-term residential camps (such as for acorn gathering) and specialized localities occurred within each village territory. There are varied estimates for the length of the annual stay at the main village, and it has even been suggested that a bipolar pattern with two permanent base camps, one in a major valley and another in the mountain region (ASM 2024).
Notably, strong differences in social status, ascribed leadership roles, and elaborate ritual paraphernalia existed. Leadership include s hereditary chiefs and council members who ha ve specialized knowledge and authority over specific religious, economic, and warfare issues. Leaders conduct elaborate ceremonies; ritual and ceremonial specialists maintained ceremonial knowledge in
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secrecy and passed on the knowledge to only one heir . These leaders and specialists made use of fenced-in ceremonial structures, located in the village center (ASM 2024).
Economic activities t ake place on the community and the extended household level and varied significantly between coastal and inland areas. Community-wide efforts included fire management for game drives, and systematic use of fire to facilitate grasslands and increase yields of key plants and animals. Such burning was regularly mentioned in early Spanish accounts. Acorns, gathered in upland areas, have been considered the most important food source. Seeds from grasses, manzanita, sage, sunflowers, lemonade berry, chia, and other plants were also used, along with various wild greens and fruits. Deer, antelope, small game, and birds were exploited. Coastal marine animals utilized as food included sea mammals, fish, crustaceans, and mollusks. Near-shore fishing was done from light balsa reed or dugout canoes. Some accounts indicate that coastal communities exploited local shellfish in the winter, and during times of stress the interior Luiseño traveled to the coast to obtain shellfish, fish, and even some land mammals . Most inland groups also had fishing and gathering locations on the coast which they visited annually when the tides were low or when the inland resources were scarce, typically from January through March (ASM 2024).
Rigid gender division of labor did not exist, but women generally collected plant resources and men hunted. Houses were dispersed throughout villages. Lowland village houses were conical structures covered with tule bundles, and other structures included sweathouses, ceremonial enclosures, ramadas, and acorn granaries. Domestic implements included wooden utensi ls, baskets, ceramic cooking and storage vessels, and milling tools. Hunting implements included bow and arrow, curved throwing sticks, nets, and snares. Nets and hooks made of shell and bone were used for fishing (ASM 2024).
Project Specific Ethnographic Context
Villages were often located in sheltered areas in valley bottoms, along streams, or along coastal strands near mountain ranges. Along with being located near water sources, keeping in mind that modern development has drastically changed the presence and frequency of water sources. While no placenames or villages were identified as being directly associated with the project area there are several in the larger vicinity of the project (ASM 2024). Many place names have multiple possible spellings and meanings derived from different sources. Nearby place names include Panakara and Mehel-om-pom-pauvo to the south and multiple habitation areas along the San Luis Rey River watershed to the north including Wiasamai, (a village east of Mission San Luis Rey) Wagaumaj (village site near Guajome), Kwalam (village site along the San Luis Rey River) and Tomkav (village at Monserrate) (ASM 2024).
In addition to placenames there are several habitation areas in the larger vicinity of the project area.
SDI-5633 located approximately 2 -miles west of the project area was identified as a habitation or specialized area. A data recovery at SDI-5633 placed the occupation of the site circa A.D. 1170 to A.D. 1690. The site also contains evidence of an earlier occupation, likely during the Archaic Period, based on the presence of large milling tools and Coso obsidian. It was identified as a habitation area used primarily for hunting and for projectile point production and milling of plant seeds. W-1556 / SDI-5641 located approximately two miles west of the project area is recorded as a habitation site consisting of an artifact laden midden soil overlooking the S an Marcos Valley flood plain. The site contained an extensive artifact deposit with hearths, milling features, and human remains. SDI -11068A/B (known as the Twin Oaks Valley Ranch site), located approximately two miles north of the project area, contained large amount of shell fragments and fish bone, bedrock milling features. It also contains a
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high number of ceramics and ceramic types, bow pipes, effigies and a wide variety of milling implements.
Other major habitation areas within the region include SDI -9822 (known as the Deer Springs Site) located approximately four miles north of the project area and included a red pictograph that also contained pecking. SDI -12,209, located approximately three and one- half miles to the south east, contains a habitation area with significant subsurface deposits and a rock art panel, showing this habitation area was an important location along Escondido Creek (ASM 2024).
Tribal Correspondence and Coordination
ASM coordinated with Native American tribes as part of the archaeological study. A summary is provided below. The results of separate government-to-government consultation between the City and tribes are provided in Section 3.12 of this EIR.
On January 25, 2023, ASM requested a search of the Sacred Lands File (SLF) by the Native American Heritage Commission (NAHC) for the project area. The SLF consists of a database of known Native American resources. The NAHC replied on March 1, 2023, and the SLF search came back negative.
The NAHC provided a list of Native American tribes and individuals/organizations with traditional geographic association that might have knowledge of cultural resources in this area. Due to the long response time from the NA HC, the City advised that a Native American monitor from Rincon should participate in the survey. Shuuluk Linton and Destiny Cocholo, monitors for Rincon, attended the survey.
Outreach letters were mailed March 1, 2023, to all Native American representatives included on the NAHC contact list. These letters attempted to solicit additional information relating to Native American resources that may be impacted by the p roject. Native American representatives were requested to define a general area where known resources intersect the project area. The following responses have been received to date:
• On March 2, 2023, Ray Teran of the Viejas Band of Kumeyaay Indians responded that the project site has cultural significance to the Kumeyaay Nation and to contact the San Pasqual Band of Mission Indians.
• March 14, 2023, Cami Mojado of the San Luis Rey Band of Mission Indians responded via phone call that the San Luis Rey Band would like formal consultation with the City and would like to be involved in the project. Ms. Castells from ASM informed Ms. Mojado of the survey results and that testing of the resource would be taking place and the San Luis Rey could provide a Native American monitor for the testing. Shelly Padilla attended the testing on March 17, 2023.
• On March 20, 2023, Shuuluk Linton, Triba l Historic Preservation Coordinator of the Rincon Band of Luiseño Indians responded that the Rincon Band has specific concerns that the project may impact resources and recommends conducting an archaeological study and that a Rincon Tribal Monitor attend the survey. The Rincon Band also requested to consult directly with the lead agency.
• On March 21, 2023, Daniel Tsosie of the Campo Band of Mission Indians responded that an archaeologist and Native American monitor should be on site.
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• On April 4, 2023, Charlene Elliott, Director Sycuan Cultural Resources Center and Museum responded that the project is within the boundaries of the Kumeyaay Nation’s traditional territory and Sycuan would like to engage in consultation with the City. • On April 26, 2023, Cami Mojado of the San Luis Rey Band of Mission Indians responded by letter requesting further discussion of the project and Native American monitoring. • On April 28, 2023, Angelina Gutierrez, THPO, San Pasqual Band of Mission Indians responded that they would like to engage in formal government to government consultation under AB-52.
Archaeological (Prehistoric) Resources
An ASM archaeologist conducted an intensive level pedestrian survey of the proposed project area on January 6, 2023. ASM surveyed the entire 8.6-acre project site in transects spaced approximately 15 meters (m) apart wherever possible. Rincon Native American monitor s Shuuluk Linton and Destiny Colocho were also present and assisted in the survey. Most of the survey area was covered in dense vegetation which limited movement and obscured the ground surface, so efforts were primarily focused on examining bedrock outcrops for evidence of milling and available visible soils.
The project area is located on a hillside slope and was covered with mature coastal sage scrub habitat.
The soils in the upland portions of the property were noted to be shallow with granitic rock outcrops occurring throughout. There was a section of the s outhern end of the property, which was relatively flat. However, this appears to be the result of extensive grading in the past. An open concrete drain was present along the eastern boundary of the parcel, following slope contours. There appears to have been a graded access road that passes through the property in a roughly south -to-north orientation, however, this roadway was overgrown with dense vegetation. An abandoned transient campsite was noted in the northwestern portion of the project area.
The pedestrian survey identified a small prehistoric site, described below. Site recording included the definition of site boundaries and documentation of features. Detailed sketch maps were made, demonstrating the relationship of the site’s location to topographic features and other landmarks. ASM then completed California State DPR 523 site records for submittal to the SCIC and assignment of primary numbers and site trinomials. Recordation efforts included the plotting of the site on a USGS
7.5-minute quad map. Digital phot ographs were taken to document specific features of the s ite, as well as the general character of the survey area. These are on file at ASM (ASM 2024).
P-37-040572/CA-SDI-23456
During the survey, a small prehistoric site , comprised of two bedrock milling outcrops was identified .
The surrounding vicinity was intensively surveyed, but no associated artifacts were located. The site was located in an area of dense vegetation with extremely limited (<5%) ground surface visibility. The bedrock milling features were recorded as P-37-040572/CA-SDI-23456. Bedrock milling feature 1 measures 3x2 m and contains an 18x9 centimeter (cm) milling slick. The bedrock was nearly flush with the groun d surface and covered in lichen and was highly exfoliated due to natural weathering processes. Bedrock milling feature 2 was on a multifaceted 10x10 m granitic bedrock outcrop and the milling slick measured 10x9 cm. The milling slick is located on a 1 m ta ll component of the outcrop and was in very poor condition due to extensive exfoliation caused by natural weathering. The two slicks were both relatively ephemeral and did not appear to be well developed as a result of extensive use. No associated artifacts or cultural materials were identified at the site (ASM 2024).
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Subsurface Testing Methods and Results
Subsurface testing was conducted on March 17, 2023, by ASM Archaeologists and Saving Sacred Sites Luiseño Native American Monitor Shelly Padilla. Due to a lack of ground surface visibility and scarcity of artifacts on the surface a two-phase approach to resource evaluation was implemented to evaluate the significance of P-37-040572/CA-SDI-23456. First, testing included site mapping, surface collection, and excavation of a series of shovel test pits (STPs) to define site boundaries and to establish whether s ubsurface deposits were present . STPs excavation consisted of 30 -cm diameter holes excavated in 20-cm levels. The excavation continued until either two sterile levels were reached, or decomposing granite or bedrock was reached. All soils were dry screened using 1/8 th inch mesh screening.
In total, six STPs were excavated within P -37-040572/CA-SDI-23456. As no artifacts were identified on the surface the placement of the STPs were based on the proximity to the milling features, slope, and available ground surface. The STPs were placed adjacent to and between the bedrock milling outcrops to explore the potential for intact subsurface deposits. The six 30 -cm diameter STPs were distributed throughout the site, based on an attempt to place units near each milling outcrop while also being heavily limited in placement by dense vegetation and rock outcrops.
The STPs were negative for artifacts or evidence of intact archaeological deposits. As no artifacts were recovered, additional excavation of a 1x1m unit was not required and no laboratory processing, artifact analysis, or curation was needed.
Resource Evaluation
During the survey, P-37-040572/CA-SDI-23456 was identified as a prehistoric archaeological site containing two bedrock milling features containing a single milling slick each. The two slicks were both relatively ephemeral and did not appear to be well developed as a result of extensive use. No associated artifacts or cultural materials were identified at the site. To determine if any subsurface archaeological deposits were present six STPs were excavated in the vicinity of the bedrock milling. All six STPs were negative.
In the assessment of the historical significance of the site in the project area, a number of factors were considered, including:
• the poor condition of the bedrock milling outcrops;
• the lack of artifacts associated with the bedrock milling features; • the lack of surficial or subsurface cultural deposits associated with the features; and • the lack of ability to make a temporal assessment of the site’s period of occupation.
As a prehistoric site , any potential for eligibility lies in the research potential of the bedrock milling outcrops or in associated archaeological deposits associated with the bedrock milling features. The poor condition of the milling features and total lack of any surficial or subsurface deposits precludes the possibility of the site being considered eligible to the CRHR. The site was not found to have any temporally diagnostic artifacts or features . In addition, the poor condition of the discovered milling slicks prevents additional investigation of the slicks themselves via protein residue analysis, microbotanical study, or other analytical methods. Subsurface testing determined that the site has a complete lack of subsurface component, and no surficial deposits were identifi ed. Therefore, the research potential of P -37-040572/CA-SDI-23456 has been exhausted by the ASM testing program
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and it does not have the potential to provide additional information. Therefore, P-37-040572/CA-SDI- 23456 is recommended as not eligible for listing in the CRHR under Criterion 4 because it has poor research potential. The site is limited to prehistoric materials and thus is not eligible under Criteria 1- 3 of the CRHR. Site P-37-040572/CA-SDI-23456 does not qualify as a historical resource or unique archaeological resource under CEQA (PRC §5024.1, Title 14 CCR, Section 4852).
3.4.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to cultural resources, including state and local guidelines.
Federal/State
Native American Heritage Values
Federal and state laws mandate that consideration be given to the concerns of contemporary Native Americans with regards to potentially ancestral human remains associated funerary objects, and items of cultural patrimony. Consequently, an important element in assessing the significance of the study site has been to evaluate the likelihood that these classes of items are present in areas that would be affected by the proposed project.
The category termed “Traditional Cultural Properties” in discussions of cultural resource management performed under federal auspices is also potentially relevant to prehistoric sites. “Traditional” in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. The traditional cultural significance of a historic property, then, is significance derived from the role the property plays in a community’s historically rooted beliefs, customs, and practices. Examples of properties possessing such significance include the following:
1 A location associated with the traditional beliefs of a Native American group about its origins, its cultural history, or the nature of the world;
2 A rural community whose organization, buildings and structures, or patterns of land use reflect the cultural traditions valued by its long-term residents; 3 An urban neighborhood that is the traditional home of a particular cultural group, and that reflects its beliefs and practices;
4 A location where Native American religious practitioners have historically gone, and are known or thought to go today, to perform ceremonial activities in accordance with traditional cultural rules of practice; and/or
5 A location where a community has traditionally carried out economic, artistic, or other cultural practices important in maintaining its historic identity.
State
Native American Historic Cultural Sites
The Native American Historic Cultural Sites law addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be implemented if Native American skeletal remains are
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discovered during construction of a project; and establishes the N AHC to resolve disputes regarding the disposition of such remains. In addition, the Native American Historic Resource Protection Act makes it a misdemeanor punishable by up to one year in jail to deface or destroy an Indian historic or cultural site that is listed or may be eligible for listing in the CRHR.
California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act), enacted in 2001, required all state agencies and museums that receive state funding and that have possession or control over collections of human remains or cultural items, as defined, to complete an inventory and summary of these remains and items on or before January 1, 2003, with certain exceptions. The California Repatriation Act also provides a process for the identification and repatriation of these items to the appropriate tribes.
Health and Safety Code 7050.5
This code establishes that any person who knowingly mutilates, disinters, wantonly disturbs, or willfully removes any human remain in or from any location without authority of the law is guilty of a misdemeanor. It further defines procedures for the discovery and treatment of Native American remains.
Health and Safety Code 8010-8011
This code is intended to provide consistent state policy to ensure that all California Indian human remains and cultural material are treated with dignity and respect. The code extends policy coverage to non-federally recognized tribes and federally recognized groups.
Assembly Bill 2461
The section provides procedures for private land owners to follow upon discovering Native American human remains. Land owners are encouraged to consider culturally appropriate measures if they discover Native American human remains as set forth in California PRC 5097.98.
Local
San Marcos General Plan Conservation and Open Space Element The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of archaeological and historic resources. The following goals and policies apply to the project:
o Policy COS-2.5: Continue to review future development proposals to ensure that cultural resources (including prehistoric, historic, paleontological, and SB 18 Tribal resources) are analyzed and conserved in compliance with CEQA requirements. • Goal COS -11: Continue to identify and evaluate cultural, historic, archaeological, paleontological, and architectural resources for protection from demolition and inappropriate actions.
o Policy COS-11.1: Identify and protect historic and cultural resources including individual properties, districts, and sites (e.g., archaeological sites) in compliance with CEQA.
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o Policy COS -11.2: Prohibit the demolition or removal of a historic structure without evaluation of the condition of the structure, the cost of rehabilitation, and the feasibility of alternatives to preservation in place including but not limited to relocati on, or reconstruction offsite, and/or photo-preservation.
o Policy COS-11.3: Identify opportunities for adaptive reuse of historic sites and buildings to preserve and maintain their viability.
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As detailed in Table 3.8 -12, the project is consistent with the applicable General Plan goals and policies pertaining to cultural resources.
San Marcos Archaeological and Historical Resources Consultant Guidelines The City of San Marcos published guidelines for archaeological and historical resources consultants in January 2023. The guidelines are generally meant to aid third party consultants who prepare archaeological or architectural history inventories, surveys, evaluations, and other technical documents. These guidelines include information pertaining to the minimum qualifications, records searches, tribal outreach, pedestrian surveys, reporting, research design, findings, discussion and evaluations, management conclusions, references, and appendices of inventories, surveys, evaluations, and other technical documents (City of San Marcos 2023). ASM prepared the archaeological resources inventory report in accordance with these guidelines.
3.4.3 Thresholds of Significance
The determination of significance for cultural resources is based on CEQA Guidelines Appendix G .
Impacts to cultural resources would be significant if the proposed project would:
• Threshold #1: Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.
• Threshold #2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5;
• Threshold #3: Disturb any human remains, including those interred outside of dedicated cemeteries.
3.4.4 Project Impact Analysis
The project site is vacant. Ground disturbing activities can result in impacts to arch aeological resources if they are present on the project site. The following analysis discusses the potential for the project to have cultural resources.
Threshold #1: Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.
As detailed in Section 15064.5(a) of the CEQA Guidelines, the term "historical resources" shall include the following:
(1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 14 CCR, Section 4850 et seq.)
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(2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code, or identified as significant in a historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, mi litary, or cultural annals of California may be considered to be a historical resource, provided the lead agency's determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code, § 5024.1, Title 14 CCR, Section 14 CCR, Section 4852) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage;
(B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
(D) Has yielded, or may be likely to yield, information important in prehistory or history. (E) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k) of the Public Resources Code), or identified in an historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code sec tions 5020.1(j) or 5024.1.
ASM carried out a formal evaluation of significance of site P -37-040572/CA-SDI-23456. Because it was found to not meet the eligibility criteria for the CRHR or NRPP, P -37-040572/CA-SDI-23456 was determined to not be a historical resource under CEQA. Therefore, there would be no impact to known historical resources by the proposed project.
Threshold #2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.
The project will include the removal of a portion of site P -37-040572/CA-SDI-23456. The eastern feature of the site will be capped and preserved in place. However, this site is recommended not eligible for listing in the CRHR, and therefore it does not qua lify as a historical resource or unique archaeological resource under CEQA. No other archaeological resources were identified during the survey of this project (ASM 2024).
Due to the presence of a prehistoric cultural resource within the project area and additional prehistoric and historic resources recorded in very close proximity to the project area, as well as low ground
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surface visibility across the project area, there is the potential that vegetation clearing and ground disturbing activities at the project area may reveal previously undiscovered archaeological resources on the project site. In addition, since the project area is near the confluence of an unnamed drainage and San Marcos Creek, it has a high sensitivity for prehistoric archaeological resources. This represents a
potentially significant impact (Impact CR-1) and mitigation is required. • Impact CR-1 Due to grading and ground disturbing activities, the proposed project has the potential to impact unidentified archaeological resources on the project site.
Threshold #3: Disturb any human remains, including those interred outside of dedicated cemeteries.
The archaeological resources field survey conducted for the project did not identify any human remains or find any indications that they would be expected to be found on the project site. However, there are several habitation areas in the larger vicinity of the project area. If human remains are encountered during project construction, there is a
potential for a significant impact (Impact CR-2).
• Impact CR-2 There is a potential for project construction activities to disturb previously unidentified human remains on the project site.
State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. Adherence to State Health and Safety C ode Section 7050.5 is mandated and is reiterated as a mitigation measure in Section 3.4.6.
3.4.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to cultural resources, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on cultural resources. All of the cumulative projects identified in Table 2 -4 are considered in this cumulative analysis.
Archaeological Resources
While removal of a portion of site P-37-040572, CA -SDI-23456 was determined to be less than significant, it was determined that there could be a potential for unidentified resources to be encountered subsurface during project grading. Other cumulative projects would be required to assess the potential for impacts to archaeological resources and provide mitigation measures or avoidance measures to reduce significant impacts to cultural resources consistent with the requirements of CEQA and the City. Addition ally, the lead agency is required to consult with tribes pursuant to the requirements of SB 18 and/or AB 52. The City requires standard conditions of approval related to construction monitoring by an arch aeologist to ensure there are no inadvertent impacts to archaeological resources. Cumulative impacts would be
less than significant.
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3.4.6 Mitigation Measures
Mitigation measures MM-CR-1 and MM-CR-2 would reduce potential impacts to cultural resources and human remains to below a level of significance. Additional measures for tribal cultural resources are provided in Section 3.12.
MM-CR-1: Unanticipated Discovery Procedures
In the event of the unanticipated discovery of cultural resources, all ground disturbing activity at that location shall temporarily halt or be diverted. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. A Qualified Archaeologist shall be retained to assess the discovery. If the resource is determined to be associated with Native American culture, it will be considered a tribal cultural resource and subject to MM -TCR-8. Non-Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture, then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.
Isolates and clearly non -significant archaeological resources (as determined by the Qualified Archaeologist) will be minimally documented in the field. All unearthed archaeological resources will be collected, temporarily stored in a secure location until analysis and documentation are complete. If a determination is made that the archaeological resources are considered potentially significant by the Qualified Archaeologist, then an adequate artifact sample to address research avenues previously identified for sites in the area will be collected using professional archaeological collection methods.
In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project c onstruction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the curation facility that the curation has been completed.
MM-CR-2: Human Remains
As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excav ation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.
If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American monitor), and consultation and treatment
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could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two working days of being notified if the remains are subject to his or her authority. If the Medical Examiner recognizes the remains to be Native American, and not under his or her jurisdiction, then he or she shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.
If suspected Native American remains are discovered, the remains shall be kept in situ (in place) until after the Medical Examiner makes its determination and notifications, and until after the Most Likely Descendent is identified, at which time the archaeological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public.
According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a location free from future disturbance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).
3.4.7 Conclusion
Based upon the analysis presented in Section 3.4.4, the potential exists for impacts to previously unidentified archaeological resources during project grading. These potentially significant impacts to archaeological resources and human remains would be mitigated to below a level of significance through implementation of mitigation measures MM-CR-1 and MM-CR-2. With incorporation of these mitigation measures, cultural resources impacts would be reduced to below a level of significance.
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3.5 Energy
Introduction
This section describes the existing setting of the project site with respect to energy use and conservation, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed project.
Appendix G and Appendix F of the California Environmental Quality Act (CEQA) Guidelines requires that an environmental impact report (EIR) discusses the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy to ensure that energy implications are considered in project -related decision -making processes. As such, this section analyzes the energy impacts of the proposed project. Specifically, this section summarizes the existing conditions in the project area, discusses the regulatory framework, and discloses estimated energy use during the construction and operational phases of the proposed project. This analysis considers the electricity, natural gas, and transportation fuel (petroleum) demand of the proposed project.
The analysis is based on the following report, which is included as Appendix E of this document6:
• Energy Usage Letter, Woodward 46 Specific Plan (SP-22-0005, SP22-0006, GPA22-0004 MFSD22-0005, TSM22-0004), prepared by LDN Consulting, September 6, 2023. (LDN 2023) Table 3.5-1 summarizes the project- and cumulative-level energy impacts, by threshold.
Table 3.5-1. Energy Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
Threshold #1: Result in
potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation.
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
Threshold #2: Conflict with or
obstruct a state or local plan for
renewable energy or energy
efficiency.
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
6 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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3.5.1 Existing Conditions
The environmental setting for the proposed project related to electricity, natural gas, and petroleum, including associated service providers, supply sources, and estimated consumption, is discussed below.
Electricity
California uses more energy than all other states except Texas. However, due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s energy use per capita is less than in almost all other states (except Hawaii). In 2022, California was the nation's fourth- largest electricity producer and accounted for about 5% of all U.S. utility-scale (1-megawatt and larger) power generation. Renewable resources, including hydropower and small -scale (less than 1 - megawatt) customer-sited solar photovoltaic (PV) systems, supplied about half of California's total in- state electricity generation. In 2022, natural gas -fired power plants provided 42% of the state's total net generation. Coal fuels only a small amount of California's in-state net generation, all of it from one industrial cogeneration plant. California imports more electricity than any other state and typically receives between one-fifth and one-third of its electricity supply from outside of the state. In 2022, in- state utility-scale electricity generation equaled about four -fifths of California's electricity sales, and the rest of the state's supply came from out of state. Wildfires in California and surrounding states threaten both imports of electricity and transmission within the state (EIA 2023a). California consumed 251,869,136gigawatt hours of electricity in 2022 (EIA 2023b).
San Diego Gas & Electric (SDG&E) provides electric and natural gas services to a population of 1.4 million business and residential accounts. SDG&E distributes energy service through 1.49 million electric meters and 905,000 natural gas meters in a 4,100-square-mile service area that includes San Diego County and southern Orange County (SDG&E 2022a). SDG&E is a subsidiary of Sempra Energy and would provide electricity to the proposed project.
The Path to Net Zero: A Decarbonization Roadmap for California (Roadmap) examines the implications to the State and SDG&E service area of transitioning to a carbon neutral (net zero emissions) economy by 2045, as mandated in the California Climate Crisis (See Section 3.5.2 Regulatory Setting below).
Electricity is expected to play a central role in decarbonization. Clear priorities include the need to expand electrification and supplies of solar and wind power, invest in a diverse set of electric generation resources that will help ensure the electric grid is reliable and lastly, to provide much larger volumes of clean fuels.
Electrification is central to decarbonizing the transportation and building sectors. As such, electricity usage and demand are expected to increase. According to the Roadmap, the State of California can expect a 96% projected increase in electric consumption between 2020-2045 and a 60% projected increase in net peak demand for the same period. SDG&E projects approximately a 100% increase in electric consumption for its service area between 2020 and 2045 and an 85% increase in net peak demand. California had 85 gigawatt (GW) total capacity in 2020 and is projected to need 356 GW of capacity by 2045. As described in the California Air Resources Board (CARB) 2022 Scoping Plan for Achieving Carbon Neutrality, the scale of transformation needed over the next decade to avoid the worst impacts of climate change and meet ambitious climate goals is extraordin ary. This is why Governor Newsom and the Legislature invested over $15 billion in climate action through the 2021/2022 California Comeback Plan, and why the 2022 –2023 budget marks the beginning of the California Climate Commitment—the governor’s multi-year plan to invest $54 billion in climate action.
This plan includes $2.1 billion for clean energy investments, such as long duration storage, offshore
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wind, green hydrogen, and industrial decarbonization (CARB 2022a). California is planning to expand and reinforce its electrical grid through investment and regional cooperation, increase in -state renewable energy as well as renewable energy imports, increase storage, particularly behind the meter PV storage, work toward changing consumer behavior (e.g., charging electric vehicles during the day when solar energy is available) and investing in development and implementation of technology that allow electric vehicles (EVs) to transmit energy back into the grid.
SDG&E believes meeting carbon neutrality will require installing 40 GW of new battery storage as well as 20 GW of dispatchable generation from 100% clean hydrogen generation by 2045. Moreover, in addition to existing natural gas generation, they believe that 4 GW of electricity from natural gas with carbon capture and sequestration will be needed to support reliability as the electric sector decarbonizes. Combined, these flexible resources can provide clean electricity when the sun is not shining and the wind is not blowing and ensure that high electricity demand during the summer months can be reliably met (SDG&E 2022b). SDG&E’s 2022 Individual Integrated Resource Plan (IIRP) is designed to meet key statutory requirements related to ensuring system reliabil ity, reducing greenhouse gas (GHG) emissions with the best-fit resources at the lowest possible cost, and satisfying the State’s Renewables Portfolio Standard program goals. To that end, SDG&E is anticipating procuring 56 percent of its power from renewabl e resources for the 2021- 2024 RPS Compliance Period, which is well above the State’s 38.4-percent requirement.
Additionally, within SDG&E’s service area, charging infrastructure will help to enable transportation electrification. SDG&E projects 900,000 EVs will operate in their service area in 2030 and 3,230,000 EVs in 2045. Similarly, 180,000 EV chargers are projected in SDG&E’s service area in 2030 and 640,000 EV chargers are projected in 2045 (SDG&E 2022b).
Natural Gas
California is the nation's second -largest natural gas consumer (after Texas). Total natural gas consumption in 2021 totaled 2,101 billion cubic feet. In 2021, about 33% of the natural gas delivered to California consumers went to the state's industrial sector, and about 31% went to the electric power sector, where it fuels more than two -fifths of the state's total electricity generation. The residential sector, where three in five California households use natural gas for home heating, accounted for 22% of natural gas use, and the commercial sector consumed about 12%. The transportation sector used about 1% as compressed natural gas vehicle fuel. California's natural gas output has declined steadily since 1985, and the state now accounts for less than 1% of the nation's total natural gas reserves and production. California's natural gas production is less than one-tenth of the state's total consumption (EIA 2023a).
The California Public Utility Commission (CPUC) regulates natural gas utility rates and services provided by Pacific Gas and Electric Company (PG&E), Southern California Gas Company , SDG&E, Southwest Gas and several smaller natural gas utilities. SDG&E provides natural gas service to the Counties of San Diego and Orange and would provide natural gas to the proposed project. SDG&E is a wholesale customer of SoCalGas and currently receiv es all its natural gas from the SoCalGas system (CPUC 2021).
Petroleum
California is the nation's second-largest consumer of refined petroleum products, after Texas, and accounts for about 8% of U.S. total consumption. In 2021, California was the nation's largest consumer of jet fuel and the second-largest consumer of motor gasoline, after Texas. The transportation sector
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used about 83% of the petroleum consumed in the state. The industrial sector accounted for about 13% of state petroleum use, and the commercial sector consumed about 3%. The residential sector, where about 1 in 27 California households heat with petroleum products, mostly propane, used about 1%.A minimal amount of petroleum is used for electricity generation . Total petroleum consumption was estimated to be 605 million barrels (EIA 2023a).
Technological advances, market trends, consumer behavior, and government policies could result in significant changes in fuel consumption by type and in total. At the federal and state levels, various policies, rules, and regulations have been enacted to i mprove vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation ‐source air pollutants and GHG emissions, and reduce vehicle miles traveled (VMT). Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible.
California requires that motorists use, at a minimum, a specific blend of motor gasoline called CaRFG (California Reformulated Gasoline) to reduce emissions from motor vehicles. California refineries produce cleaner fuels in order to meet state environment al regulations. Refineries in the state often operate at or near maximum capacity because of the high demand for those petroleum products and the lack of interstate pipelines that can deliver those cleaner fuels into the state (EIA 2023a).
Largely as a result of and in response to these multiple factors, gasoline consumption within the state has declined in recent years, and availability of other alternative fuels/energy sources has increased.
The quantity, availability, and reliability of t ransportation energy resources have increased in recent years, and this trend may likely continue and accelerate. Increasingly available and diversified transportation energy resources act to promote continuing reliable and affordable means to support vehicular transportation within the state. California is part of the West Coast Green Highway, an extensive network of electric vehicle DC fast charging stations located along Interstate 5, and the state has more than 14,000 public electric vehicle charging stations. As of December 31, 2021, California had more than 563,000 registered all-electric vehicles, the most of any state. California also requires all public transit agencies to gradually transition to 100% zero-emission bus (ZEB) fleets. Beginning in 2029, all transit agency new bus purchases must be ZEBs (EIA 2023a ). Further, Executive Order N- 79-20 calls for elimination of new internal combustion passenger vehicles by 2035. By setting a course to end sales of internal combustion passenger vehicles by 2035, the Governor’s Executive Order establishes a target for the transportation sector that helps put the state on a path to carbon neutrality by 2045. It is important to note that the Executive Order focuses on new vehicle sales for automakers, and therefore does not require Californians to give up the existing cars and trucks they already own.
The primary mechanism for achieving the Zero-Emission-Vehicle target for passenger cars and light trucks is the Advanced Clean Cars II Program discussed below in Section 3.5.2 Regulatory Setting.
As stated above, SDG&E’s Decarbonization Roadmap projects 900,000 EVs will operate in their service area in 2030 and 3,230,000 EVs in 2045. Similarly, 180,000 EV chargers are projected in SDG&E’s service area in 2030 and 640,000 EV chargers are projected in 2045 (SDG&E 2022b).
Gasoline and other vehicle fuels are commercially provided commodities and would be available to the proposed project through commercial outlets.
Existing Infrastructure
The proposed project is within the SDG&E service area and would connect to the existing SDG&E infrastructure within Woodward Street, within the existing right-of-way.
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3.5.2 Regulatory Setting
Federal, state, and local agencies regulate energy use and consumption through various means and programs. On the federal level, the U.S. Department of Transportation, the U.S. Department of Energy, and the U.S. Environmental Protection Agency are three fe deral agencies with substantial influence over energy policies and programs. On the state level, CPUC and California Energy Commission (CEC) are two agencies with authority over different aspects of energy. Relevant federal, state, and local energy-related regulations are summarized below. This information helps to place the impact analysis within its proper regulatory context.
Federal
Federal Energy Policy and Conservation Act (1975)
The Federal Energy Policy and Conservation Act established the first fuel economy standards for on - road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.
Energy Independence and Security Act (2007)
The Energy Independence and Security Act of 2007 (EISA) aims to increase energy security, develop renewable energy production and improve vehicle fuel economy. The following are provisions related to energy efficiency:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325) • Building Energy Efficiency (Sections 411–441)
This federal legislation requires ever -increasing levels of renewable fuels (the RFS) to replace petroleum. The U.S. Environmental Protection Agency (EPA) is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains a minimum volume of renewable fuel. The RFS program regulations were developed in collaboration with refiners, renewable fuel producers, and many other stakeholders.
The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel volume mandate in the United States. As required under the act, the original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the EISA, the RFS program was expanded in several key ways that lay the foundation for achieving significant reductions in GHG emissions from the use of renewable fuels, reducing imported petroleum, and encouraging the development and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:
• EISA expanded the RFS program to include diesel, in addition to gasoline. • EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022.
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• EISA established new categories of renewable fuel, and set separate volume requirements for each one.
• EISA required the U.S. Environmental Protection Agency to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.
Additional provisions of the EISA address energy savings in government and public institutions, research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green” jobs.
State
The discussion below focuses primarily on those policies, regulations, and laws that directly pertain to energy-related resources . Many policies, regulations, and laws targeted to the reduction of GHG emissions are expected to achieve co -benefits in the form of reduced demand for energy -related resources and enhanced efficiencies in the consumption of energy-related resources.
State of California Energy Action Plan
The CEC and CPUC approved the first State of California Energy Action Plan in 2003. The plan established shared goals and specific actions to ensure that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and actions that are cost-effective and environmentally sound for California's consumers and taxpayers. In 2005, a second Energy Action Plan was adopted by the CEC and CPUC to reflect various policy changes and actions of the prior two years.
At the beginning of 2008, the CEC and CPUC determined that it was not necessary or productive to prepare a new energy action plan. This determination was based in part on a finding that the state’s energy policies have been significantly influenced by the passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed below). Rather than produce a new energy action plan, the CEC and CPUC prepared an “update” that examines the state’s ongoing actions in the context of global climate change.
Integrated Energy Policy Report
Senate Bill (SB) 1389 (2002) requires the California Energy Commission to conduct assessments and forecasts of all aspects of energy industry supply, production, transportation, delivery and distribution, demand, and prices. The Energy Commission shall use these assessments and forec asts to develop energy policies that conserve resources, protect the environment, ensure energy reliability, enhance the state's economy, and protect public health and safety. (Pub. Res. Code § 25301(a)).
The CEC adopts an Integrated Energy Policy Report (IEPR, pronounced eye'-per) every two years and an update every other year. The most current report is the 2023 Integrated Energy Policy Report Update which covers a broad range of topics, including accelerated connection of clean energy, California energy demand forecast, potential growth of hydrogen in California, updates on key issues including gas system decarbonization, benefits of the clean transportation program and energy efficiency.
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California Renewables Portfolio Standards
Senate Bill 1078 (2002)
This bill established the California Renewables Portfolio Standards (RPS) Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year, culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill relatedly required the CEC to certify eligible renewable energy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover above -market costs of renewable energy.
Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018) Senate Bill (SB) 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California utilities to generate 33% of their electricity from eligible renewable energy resources by 2020. Specifically, SB X1 -2 set a three -stage compliance period: by December 31, 2013, 20% shall come from renewables; by December 31, 2016, 25% shall come from renewables; and by December 31, 2020, 33% shall come from renewables.
SB 350 (2015) requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.
In addition, SB 350 includes the goal to double the energy efficiency savings in electricity and natural gas final end uses (such as heating, cooling, lighting, or class of energy uses on which an energy - efficiency program is focused) of retail customers through energy conservation and efficiency.
SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030 be secur ed from qualifying renewable energy sources. SB 100 also states that it is the policy of the state that eligible renewable energy resources and zero-carbon resources supply 100% of the retail sales of electricity to California by 2045. This bill requires that the achievement of 100% zero-carbon electricity resources does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.
Greenhouse Gas Reduction
Assembly Bill 32 (2006) and Senate Bill 32 (2016)
In 2006, the Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32, which extended the horizon year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32, the California Air Resources Board ( CARB) prepares scoping plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing energy efficiencies and the use of renewable resources and reducing the consumption of petroleum-based fuels (such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits for energy-related resources.
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SB 375 Sustainable Communities and Climate Protection Act (2008) The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinates land use planning, regional transportation plans, and funding priorities to help California meet its GHG emissions reduction mandates. As codified in California Governme nt Code, Section 65080, SB 375 requires metropolitan planning organizations (San Diego Association of Governments) to include a Sustainable Communities Strategy in its regional transportation plan. The main focus of the Sustainable Communities Strategy is to plan for growth in a fashion that will ultimately reduce GHG emissions, but the strategy is also a part of a bigger effort to address other development issues within the general vicinity, including transit and VMT, which influence the consumption of pet roleum-based fuels.
Assembly Bill 1279, California Climate Crisis Act (September 2022) This Bill requires the state to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative greenhouse gas emissions thereafter. The bill also requires California to reduce statewide GHG emissions by 85 percent compared to 1990 levels and directs CARB to work with relevant state agencies to achieve these goals.
Senate Bill 1020, 100% Clean Electric Grid (September 2022) This bill creates clean electricity targets of 90% by 2035 and 95% by 2040 with the intent of advancing the state’s trajectory to the existing 100% clean electricity retail sales by 2045 goal.
The 2022 CARB Scoping Plan for Achieving Carbon Neutrality The 2022 Plan lays out a path to achieve targets for carbon neutrality and reduce anthropogenic greenhouse gas emissions by 85 percent below 1990 levels no later than 2045, as directed by Assembly Bill 1279. The actions and outcomes in the plan will achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reduction s in short -lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon. The plan calls for a need to take an unprecedented transformation and aggressively seek reductions to reduce the need of fossil fuels by moving to zero emission transportation, electrifying the cars, buses, trucks, and trains.
The plan relays on external controls and requires partnership and collaboration with the federal government, other U.S. states, and other jurisdictions around the world for California to succeed in achieving its climate targets.
California Title 24 Building Energy Efficiency Standards The Title 24 Building Energy Efficiency Standards serve to reduce wasteful, uneconomical, and unnecessary uses of energy for the state. They are designed to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality. They include requirements in the Energy Code (Title 24, Part 6) and voluntary energy efficiency provisions in CALGreen (Title 24, Part 11). The California Energy Commission is responsible for adopting, implementing, and updating these standards every three years.
Energy Code (Title 24, Part 6) Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Because homes and businesses use nearly 70 percent of California’s electricity and are responsible for a quarter of GHG emissions, the CEC was mandated
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to periodically update and adopt building standards to increase energy efficiency of buildings and reduce GHGs. Part 6 of Title 24 implemented this mandate so that every three years the CEC updates the Energy Code for new construction and renovations to existing residential and non -residential buildings (CEC 2022).
The 2019 Title 24 standards were approved and adopted by the California Building Standards Commission in December 2018. The standards required that all low -rise residential buildings shall have a photovoltaic system meeting the minimum qualification requirements such that annual electrical output is equal to or greater than the dwelling’s annual electrical usage. Notably, net energy metering rules limit residential rooftop solar generation to produce no more electricity than the home is expected to consume on an annual basis. Single-family homes built with the 2019 standards used about 7% less energy due to energy efficiency measures versus those built under the 2016 standards, while new nonresidential buildings used about 30% less energy mainly to lighting upgrades (CEC 2018).
The 2022 Building Energy Efficiency Standards (Energy Code) improve s upon the 2019 Energy Code for new construction of, and additions and alterations to, residential and nonresidential buildings. The 2022 building code went into effect January 1, 2023 and focused on four key areas in new construction: encouraging electric heat pump technology and use, establishing electric -ready requirements when natural gas is installed, expanding solar PV system and battery storage standards, and strengthening ventilation standards to improve indoor air quality (CEC 2022).
California Green Building Standards Code (Title 24, Part 11).
In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen and establis hes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and i nterior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low-rise residential and state-owned buildings and schools and hospitals.
The CALGreen 2016 standards require d mandatory reduction in indoor and outdoor water use, diversion of demolition waste, mandatory inspections of energy systems, inclusion of electric vehicle charging stations for designated parking spaces and use of low-pollutant-emitting exterior and interior finish materials.
The current CALGreen standards were last updated in 2022 and went into effect January 1, 2023. The standards focus on battery storage system controls, demand management, heat pump space and water heating, and building electrification. The 2022 CALGreen update eliminates the two-tiered menu of compliance prerequisites and enforces a single tiered menu of provisionary options. Mandatory requirements include many updated EV charging requirements for multi and single family developments.
State Vehicle Standards
Although the focus of the state’s vehicle standards is on the reduction of air pollutants and GHG emissions, one co-benefit of implementation of these standards is a reduced demand for petroleum- based fuels.
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Assembly Bill 1007 (2005)
AB 1007 (2005) required the CEC to prepare a statewide plan (State Alternative Fuels Plan) to increase the use of alternative fuels in California . The CEC prepared the plan in partnership with CARB and in consultation with the other state, federal, and local agencies. The plan assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in- state production of biofuels without causing a significant degradation of public health and environmental quality.
AB 1493 (2002), EO S-1-07 (2007), and EO B-16-12 (2012) In response to the transportation sector accounting for more than half of California’s carbon dioxide (CO2) emissions, AB 1493 was enacted in 2002. AB 1493 requires CARB to set GHG emission standards for passenger vehicles and Executive Order ( EO) S-1-07 sets a declining Low Carbon Fuel Standard to reduce the carbon intensity of California passenger vehicle fuels. EO B -16-12 supports and facilitates the development and distribution of Zero Emissions Vehicles (ZEVs).
Advanced Clean Cars Program (2012 and 2022), EO N-79-20 (2020), and Clean Miles Standard and Incentive Program (2018)
In January 2012, CARB approved the Advanced Clean Cars program, an emissions-control program for model years 2015 through 2025 that combined standards for smog producing pollutants and greenhouse gases into one program. The package includes elements to red uce smog -forming pollution, reduce GHG emissions, promote clean cars, and provide fuels for clean cars.
CARB’s latest rule (2022) is known as Advanced Clean Cars II which continues the concept of increasing stringency for fuel -efficiency standards and increasing the number of ZEVs. California enjoys the largest zero-emission vehicle market in the nation with more than 16% of new vehicles sold being zero-emissions or plug -in hybrids. The regulations are two -pronged. First, it amends the Zero - emission Vehicle Regulation to require an increasing number of zero-emission vehicles, and relies on currently available advanced vehicle technologies, including battery-electric, hydrogen fuel cell electric and plug -in hybrid electric -vehicles, to meet air quality and climate change emissions standards.
Second, the Low -emission Vehicle Regulations were amended to include increasingly stringent standards for gasoline cars and heavier passenger trucks to continue to reduce smog -forming emissions (CARB 2023).
EO N-79-20 calls for elimination of new internal combustion passenger vehicles by 2035. By setting a course to end sales of internal combustion passenger vehicles by 2035, the Governor’s Executive Order establishes a target for the transportation sector that helps put the state on a path to carbon neutrality by 2045. It is important to note t hat the Executive Order focuses on new vehicle sales for automakers, and therefore does not require Californians to give up the existing cars and trucks they already own. The primary mechanism for achieving the ZEV target for passenger cars and light trucks is the Advanced Clean Cars II Program discussed above.
As part of the Executive Order, the Governor’s Office of Business and Economic Development (GO-Biz) was tasked with preparing a Zero-Emission Vehicle Market Development Strategy along with the accompanying California State agency ZEV Action Plans.
In addition to the Advanced Clean Cars II, the Clean Miles Standard regulation will also help enable the goal of 100 percent ZEV sales in 2035 by creating demand for ZEVs. This regulation has aggressive
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requirements for electric miles that will transition ride -hailing fleets to zero -emission operations starting in 2023 and ramping up through 2030.
AB 2700, Transportation Electrification: Electrical Distribution and Grid Updates (2022) This law will enable more strategic -grid planning and investment to ensure California has the grid it needs to accommodate widespread transportation electrification when needed to meet the state’s carbon neutrality goals. With more -strategic planning and i nvestment, AB 2700 will help ensure the electrification of the transportation sector is cost -effective, facilitates progress towards the state’s goals, and maximizes benefits for all utility customers. Supported by a broad coalition of environmental, equity, labor, fleet, utility, and EV charging organizations, AB 2700 directs utilities to conduct strategic grid planning and investment to ensure the grid is proactively prepared to accommodate all the new electric cars and trucks coming over the next decade thanks to state goals and regulations like the Advanced Clean Cars , Advanced Clean Trucks , and Advanced Clean Fleets rules. It requires fleet data already collected by state agencies to be shared with California utilities, so that they can use that data in their existing grid planning processes to better anticipate electricity demand and propose necessary upgrades.
Local
SDG&E Integrated Resource Plan
The Integrated Resource Planning (“IRP”) process is the statewide approach to electric resource planning established by SB 350 that is intended to achieve California’s GHG emissions reduction goals for the electric sector in a manner that preserves reliability and ensures reasonable cost. According to SDGE’s 2022 Individual Integrated Resource Plan (IIRP), SDG&E supports the State’s ambitious efforts to reduce GHG emissions and is committed to the State’s vision of a clean energy future. In its study, The Path to Net Zero: A Decarbonization Roadmap for California, SDG&E lays out an implementable strategy for achieving statewide decarbonization while continuing to prioritize grid reliability, affordability, and equity. SDG&E’s IIRP is designed to meet key statutory requirements related to ensuring system reliability, reducing GHG emissions with the best-fit resources at the lowest possible cost, and satisfying the State’s Renewables Portfolio Standard program goals. To that end, SDG&E is anticipating procuring 56 percent of its power from renewable resources for the 2021- 2024 RPS Compliance Period, which is well above the State’s 38.4-percent requirement.
SDG&E’s IIRP submits two Conforming Portfolios that achieve targets of 30 and 25 million metric tons (MMT) for the year 2035. SDG&E’s Conforming Portfolios demonstrate that it is well positioned to achieve the State’s climate and reliability goals under both the 25 MMT and 30 MMT benchmark scenarios. This advantage is due in part to the following:
• SDG&E’s early compliance with RPS requirements, with around 56 percent of its energy mix expected from renewable resources in Compliance Period 4 (2021- 2024); • SDG&E’s aggressive adoption of energy storage; and
• The absence of coal resources in SDG&E’s portfolio.
While SDG&E’s portfolio is primarily made up of solar and natural gas resources, SDG&E’s modeling resulted in planned existing and new resources consisting primarily of solar, storage, and wind resources, with small amounts of demand response and firm, zer o-emitting resources (e.g., geothermal). The total capacity of these planned existing and new resources in 2035 is 1,546
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megawatts (MW). SDG&E is fully compliant with RPS and long-term contracting requirements (SDG&E 2022a).
SDG&E Path to Net Zero
The SDG&E Roadmap examines the implications of the transition to net zero emissions for the state and the region that SDG&E serves. It also includes SDG&E’s recommendation for California to achieve carbon neutrality and is the first publicly available analysis to use the industry standard for electric reliability and industry modeling software in modeling how to decarbonize California by 2045. Although the state reduced GHG emissions by ~36 MMT from 2009 to 2019 , it will need to reduce emissions at 4.5 times the pace of historical reductions going forward to reach Net Zero by 2045. The Roadmap aims to advance current research on California’s decarbonization pathways. As many other studies have highlighted, electricity is expected to play a central role in decarbonization. Clear priorities include the need to expand electrification and supplies of solar and wind power, invest in a diverse set of electric generation resources that will help ensure the electric grid is reliable and lastly, to provide much larger volumes of clean fuels.
Electrification is central to decarbonizing the transportation and building sectors under the Roadmap.
It is estimated that electric generation capacity will need to increase to 356 gigawatts (GW) by 2045 in California to meet this increasing demand for clean electricity, approximately four times the capacity that existed in 2020. The Roadmap foresees in-state solar and wind generation providing the bulk of this capacity. Wind and solar are excellent resources for providing low -cost clean energy, but to hel p ensure reliability, the California electric system must also develop more flexible resources, such as energy storage and clean dispatchable generation. This is especially important as the need for clean, reliable electricity increases from transportation and building electrification. SDG&E believes this will require installing 40 GW of new battery storage as well as 20 GW of dispatchable generation from 100% clean hydrogen generation by 2045. Moreover, in addition to existing natural gas generation, they believe that 4 GW of electricity from natural gas with carbon capture and sequestration will be needed to support reliability as the electric sector decarbonizes. Combined, these flexible resources can provide clean electricity when the sun is not shining and the wind is not blowing and ensure that high electricity demand during the summer months can be reliably met (SDG&E 2022b).
City of San Marcos General Plan
The City’s General Plan includes various policies related to reducing GHG emissions and the co-benefit of reducing energy consumption. Applicable policies include the following:
Land Use and Community Design Element
• Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. • Policy LU -2.3: Promote landscaping (e.g., native, drought tolerant plants) that minimizes demands on water supply.
• Policy LU -2.7: Promote the inst allation of trees to reduce the urban heat -island effect and green infrastructure to reduce storm water runoff.
• Policy LU-3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.
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Conservation and Open Space Element
• Policy COS -4.5: Encourage energy conservation and the use of alternative energy sources within the community.
• Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
• Policy COS-4.8: Encourage and support the generation, transmission, and use of renewable energy.
Environmental Justice
• Policy EJ-1.13: Encourage energy conservation and the use of alternative energy sources within the community.
• Policy EJ-1.14: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
• Policy EJ-1.15: Encourage and support the generation, transmission, and use of renewable energy.
The project’s consistency with applicable General Plan goals and policies is discussed in Table 3.8-12 of Section 3.8, Land Use. As detailed in Section 3.8.4, the project is consistent with the applicable General Plan goals and policies pertaining to energy.
City of San Marcos Climate Action Plan
Consistent with AB 32, the City adopted a Climate Action Plan ( CAP) in September 2013 as a long - range plan to reduce GHG emissions and mitigate climate change impacts associated with City government operations and with implementation of the City’s General Plan. An updated CAP was adopted on December 8, 2020. The 2020 CAP builds on the efforts and strategies identified in the City’s 2013 CAP, and establishes GHG emission targets and identifies achievable, locally based actions to reduce GHG emissions from municipal and community activities.
According to the CAP, energy use in the City includes electricity and natural gas consumption, which accounted for 39 percent of the City’s total emissions in 2012. Two strategies would reduce emissions from electricity and natural gas consumption by incre asing building energy efficiency and the use of renewable energy sources. Legislative reductions from State energy efficiency and renewable energy programs will contribute to reducing transportation emissions by increasing the amount of renewable energy available statewide and improving energy efficiency requirements for new developments. At the local level, GHG emissions reductions would be achieved by improving energy efficiency of new developments beyond State requirements, both increasing the amount of renewable energy generated locally, and reducing the amount of non -renewable energy consumed locally. The success of these strategies relies on coordination with local utilities, organizations, and agencies, participation from the community, and administration of new or revised local policies and programs.
The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets. Strategies and measures related to energy include the following:
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• Strategy 4: Increase Building Energy Efficiency Electricity and natural gas consumption in buildings accounts for a majority of GHG emissions from the energy sector. Although legislative reductions related to State actions will help reduce emissions associated with building energy, additional reductions are achievable by increasing building efficiency in the City. This strategy aims to reduce emissions by reducing energy used by residential consumers through increased energy efficiency. This strategy includes one measure that would reduce the City’s emissions by approximately 1,280 MTCO2e in 2030.
o Measure E-1: Require New Residential Developments to Install Alternatively-Fueled Water Heaters. Starting in 2022, require all new single-family and multi-family residential projects to install non -natural gas water heaters. Non -natural gas water heater options include electric HPWH, instantaneous electric, electric tank solar water heater with HPWH backup, or solar water heater with electric tank backup
• Strategy 5: Increase Renewable and Zero -Carbon Energy: Over a quarter of the City’s GHG emissions in 2012 were generated through the consumption of fossil fuels for the purpose of electricity generation (i.e., natural gas —fired or coal power plants). Trans itioning from fossil fuels to renewable energy electricity generation will reduce emissions and provide a more sustainable source of electricity. The City would reduce emissions by increasing renewable energy generated locally and participating in a community choice aggregation (CCA) or similar program to increase the amount of grid supplied renewable energy. This strategy includes two measures that would reduce the City’s emissions by approximately 35,100 MTCO2e in 2030.
Additional activities that would su pport this strategy would occur through partnerships with local and regional agencies.
o Measure E-2: Require Installation of PV systems at New Non -Residential Developments.
Starting in 2022, require all new non-residential developments to install PV systems with a minimum of two watts per square foot of gross floor area. o Measure E-3: Increase Grid-Supply Renewable and Zero-Carbon Electricity. Join a program to increase grid-supply renewables and zero-carbon electricity to 95 percent by 2030 with a maximum customer opt-out rate of three percent.
As part of the CAP, the City developed a CAP Consistency Review Checklist (CAP Checklist). The purpose of the checklist is to implement the GHG emissions reduction measures from the CAP that apply to new discretionary development. New developments that dem onstrate consistency with relevant CAP strategies would not conflict with the City’s ability to achieve the identified GHG reduction target through implementation of applicable measures. Projects that emit fewer than 500 metric tons (MT) of carbon dioxide equivalent (CO
2e) per year would not be subject to the measures of the CAP. Per the CAP Checklist, multifamily residential projects of 55 dwelling units or less are considered to emit fewer than 500 MT CO 2e per year. Since the project proposes 46 multifamily units, the CAP measures are not required.
3.5.3 Thresholds of Significance
According to Appendix G of the State CEQA Guidelines, the proposed project would have a significant impact related to energy if it would:
• Threshold #1: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.
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• Threshold #2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
3.5.4 Project Impact Analysis
Threshold #1: Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? The project proposes up to 46 multi-family residential units situated on an 8.57-acre site. Each garage would be wired to accommodate an electric vehicle (EV) charger. The project would meet the latest Title 24 requirements at the time building permits are requested.
The Energy Usage Letter ( LDN 2023) prepared for the proposed project includes a quantification of anticipated energy consumption during construction and operation. As explained in more detail below, the Energy Usage Letter concluded that implementation of the proposed project would not resu lt in wasteful, inefficient, or unnecessary impacts related to electricity, natural gas or petroleum during construction or operations and impacts would be less than significant.
Construction
Construction of the proposed project is expected to occur over a 10 to 11-month duration. Grading will consist of approximately 41,989 cubic yards (CY) of cut material and 50,270 CY of fill material . It is possible that the site may balance but to be conservative, the environmental analysis assumes that the export of approximately 8,281 CY of material would be required. Assuming 15 cy per truck, that would equate to 553 trips spread over approximately 23 working days for a total of 24 truck trips per day associated with export.
Electricity
Temporary electric power usage during construction would stem primarily from electronic equipment, including electrically powered hand tools, lighting, computers and heating, ventilation, and air conditioning inside temporary construction trailers. Electricity used for construction activities would be temporary and would not be considered wasteful, inefficient, or unnecessary consumption of energy resources. Impacts related to electricity consumption during project construction are determined to be less than significant.
Natural Gas
Natural gas is not anticipated to be required during construction of the proposed project. Any minor amounts of natural gas that may be consumed as a result of construction would be temporary and negligible and would not have an adverse effect on the environment; therefore, impacts would be less
than significant.
Petroleum
The majority of the energy used during construction would be from petroleum. Energy usage for construction equipment is best estimated using total horsepower hours (HP -h) and an assumed thermal efficiency of 30%. Based on the equipment, quantity, work time, and horsepower, the project would require a total of 712,343 HP-h as shown in Table 3.5 -2. Based on this, the project would consume roughly 4 3,172 gallons of diesel for construction. Proper maintenance of all construction equipment per manufacturer recommendations is included as a project design feature.
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Construction energy from workers, vendors and haulage are based on the estimated VMT for the total construction duration which is 141,769 miles for the proposed project. In California, the average fuel economy for on-road vehicles is 24.1 miles per gallon or 0.0415 gallon per mile. Based on this, the vehicular trips would consume roughly 5,883 gallons during construction (LDN 2023).
In total, construction of the project is estimated to consume a total of 4 9,055 gallons of petroleum from off-road equipment and worker vehicle and vendor truck trips during the construction phase.
Within the County, the estimated petroleum use in 2024 would be 1.5 billion gallons per year (CARB 2022b). On-road vehicles are regulated by state and federal regulations and vehicular fleet efficiencies are improving each year. Additionally, all construction equipment shall be maintained as needed per manufacturer recommendations. The project would be required to comply with CARB’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. While construction activities would consume petroleum-based fuels, consumption of such resources would be temporary and would cease upon the completion of construction. Further, the petroleum consumed related to construction would be typical of construction projects of similar types and sizes and would not necessitate new petroleum resources beyond what are typically consumed in California. Therefore, because petroleum use during project construction would be temporary and minimal and would not be wasteful or inefficient, impacts related to energy use during construction would be less than
significant.
Table 3.5-2 Proposed Construction Phase and Duration Equipment Equipment
Identification
Duration
(Days)
Hours per
Day
Horsepower
(HP) Load Factor Quantity Horsepower
Hours (HP-h)
Site Preparation 10
Rubber Tired
Dozers
8 367 0.4 3 35,232
Tractors/
Loaders/
Backhoes
8 84 0.37 4 9,945.6
Grading 30
Excavators 8 36 0.38 1 3,283.20
Crushing
Processing
Equipment
8 310 0.30 1 22,320.00
Graders 8 148 0.41 1 14,563.20
Rubber Tired
Dozers
8 367 0.4 3 105,696.00
Tractors/
Loaders/
Backhoes
8 84 0.37 3 22,377.60
Building
Construction
230
Cranes 7 367 0.29 1 171,352.30
Forklifts 8 82 0.2 3 90,528.00
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Equipment
Identification
Duration
(Days)
Hours per
Day
Horsepower
(HP) Load Factor Quantity Horsepower
Hours (HP-h)
Generator Sets 8 14 0.74 1 19,062.40
Tractors/
Loaders/
Backhoes
7 84 0.37 3 150,116.40
Welders 8 46 0.45 1 38,088.00
Paving 20
Pavers 8 81 0.42 2 10,886.40
Paving
Equipment
8 89 0.36 2 10,252.80
Rollers 8 36 0.38 2 4,377.60
Architectural
Coating
40 Air Compressors 6 37 0.48 1 4,262.40
Total Horsepower Hours 712,343.90
Total Diesel Fuel (Gal) @ 16.5 hp-h/gal 43,172.36
Source: LDN 2023.
Notes: The equipment list is based upon equipment inventory and estimates within CalEEMod 2020.4.0 Operations
Electricity
The operation of the project would require electricity for multiple purposes, including cooling, lighting, appliances, and various equipment. Additionally, the supply, conveyance, treatment, and distribution of water would indirectly result in electricity usage.
Based on the air quality modeling, the project would on average consume 155,980 kilowatt hours (kWH) of electricity each year. California consumed 251,869,136gigawatt hours of electricity in 2022 (EIA 2023b and consumption is expected to increase as a result of electrification of the building and transportation sectors needed to meet ambitions climate goals. To meet these goals, the State has created a multi -year plan to invest $54 billion in climate action including clean/renewable energy investments, expansion and reinforcement of the energy grid and increasing energy storage (CARB 2022a). Reductions from Title 24 of the California Building Code (2019) were accounted for in the calculations and would improve the efficiency of the project in terms of energy consumption. The 2022 Title 24 standards have not yet been included into CalEEMod 2020.4.0 but would essentially further reduce energy consumption.
In summary, although electricity consumption would increase at the project site due to project implementation, the project would be required to comply with Title 24 by implementing energy - efficiency measures. Furthermore, the project would be subject to th e Title 24 building code that is adopted at the time building permits are obtained and thus may be subject to a more stringent energy standard than what was assumed herein. For these reasons, electricity consumption of the project would not be considered inefficient, wasteful, or unnecessary, and impacts would be less than significant.
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Natural Gas
Based on the air quality modeling, the project would on average consume 325,608 thousand British thermal units (kBTU) of natural gas per year. As previously discussed, the project would be subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code of Regulations. Prior to building permit application, the applicant would ensure that project plans would meet Title 24 requirements applicable at that time, as required by state regulations, through their plan review process.
In summary, although natural gas usage would increase due to project implementation, project design features would be implemented, and usage would be decreased through green building standards.
For these reasons, the natural gas consumption of the project would not be considered inefficient or wasteful, and impacts would be less than significant.
Petroleum
Vehicle travel to and from the project site would be the largest contributor to petroleum use. At full buildout, the project would generate 368 average daily trips (ADT). Based on CalEEMod outputs, the estimated project trips would account for 887,661 miles traveled annually. As noted above, the average fuel economy for on-road vehicles is 24.1 miles per gallon or 0.0415 gallon per mile. Based on this, vehicular trips would consume roughly 36,838 gallons annually during operations. Over the lifetime of the proposed project, the fuel efficiency of the vehicles being used by residents is expected to increase. As RPS increases and as electric vehicle operations become more standardized, energy consumption and efficiency will decrease. Additionally, each garage would be wired to accommodate EV chargers. As such, the amount of petroleum consumed as a result of vehicular trips to and from the project site during operation would decrease over time.
In summary, although the project would increase petroleum use during operation, the use would be a small fraction of the statewide use (605 million barrels) and due to efficiency increases, would diminish over time. Given these considerations, petroleum co nsumption associated with the project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, and impacts would be less than significant.
Threshold #2: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Construction
The majority of the energy used during construction would be from petroleum. On -road vehicles are regulated by state and federal regulations and vehicular fleet efficiencies are improving each year.
Additionally, all construction equipment shall be maintai ned as needed per manufacturer recommendations. The project would be required to comply with CARB’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes. Therefore, the proposed project would not obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.
Operation
Section 3.5.2 includes a description of all the federal, state, and local policies and programs that the project would be required to comply with. The proposed project would follow applicable energy standards and regulations during the construction phases. The proposed project would be built and
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operated in accordance with all existing, applicable building regulations at the time of construction, including Title 24 Building Standards, Building Energy Efficiency Standards (Energy Code), and California Green Building Standards. Additionally, each ga rage would be wired to accommodate EV chargers, which will help meet state goals toward carbon neutrality and elimination of new internal combustion passenger vehicles. For the reasons stated, the proposed project would not obstruct a state or local plan f or renewable energy or energy efficiency, and impacts would be less than significant.
3.5.5 Cumulative Impact Analysis
Potential cumulative impacts on energy would result if the proposed project, in combination with past, present, and future projects, would result in the wasteful or inefficient use of energy. This could result from development that would not incorporate sufficient building energy efficiency features, would not achieve building energy efficiency standards, or would result in the unnecessary use of energy during construction and/or operation. The cumulative projects within the areas serviced by the energy service providers would be applicable to this analysis; this includes existing aging structures that are energy inefficient. Projects that include development of large buildings or other structures that would have the potential to consume energy in an ineffic ient manner would have the potential to contribute to a cumulative impact. Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use.
As described previously, the proposed project would not result in significant environmental impacts due to wasteful, inefficient, or unnecessary use of energy due to various design features and adherence to applicable requirements. Similar to the proposed project, the cumulative projects would be subject to CALGreen, which provides energy efficiency standards for commercial and residential buildings. CALGreen would implement increasingly stringent energy efficiency standards that would require the proposed project and the cumulative projects to minimize the wasteful and inefficient use of energy. In addition, cumulative projects would be required to meet or exceed the Title 24 building standards, further reducing the inefficient use of energy. Future development would also be required to meet even more stringent requirements, including the objectives set in the AB 32 Scoping Plan.
Furthermore, various federal and state regulations, including the Low Carbon Fuel Standard, Advanced Clean Cars Program and Clean Miles Standard would serve to reduce the transportation fuel demand of cumulative projects. In consideration of cumulative energy use, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. Thus, the proposed project would not contribute to a cumulative impact to the wasteful or inefficient use of energy. As such, the proposed project would not result in a cumulatively considerable contribution to a potential cumulative impact.
Impacts are less than significant.
3.5.6 Mitigation Measures
Impacts would be less than significant, and no mitigation measures are required.
3.5.7 Conclusion
The Energy Usage Letter prepared by LDN (2023) included a quantitative analysis of energy use during construction and operation. The analysis demonstrated that construction energy consumption (primarily petroleum) would be temporary and minimal. The proposed project would comply with regulatory requirements and building standards as well as ensuring that all construction equipment is
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maintained per manufacturer’s specifications. As such, the proposed project would not result in the wasteful or inefficient use of energy, and impacts would be less than significant.
The analysis concluded that while operations of the proposed project would consume more energy at the project site under existing conditions, the project would be required to comply with Title 24 by implementing energy efficiency measures. For these reasons, the project’s energy consumption (electricity, natural gas, and petroleum) would not be considered inefficient, wasteful, or unnecessary, and impacts would be
less than significant.
Additionally, the proposed project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing energy consumption, including the City’s General Plan policies.
As a result, impacts would be
less than significant.
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3.6 Geology and Soils
Introduction
This section analyzes the potential for impacts related to geology and soils for the proposed project, including seismic activity, liquefaction, landslides, loss of topsoil, soil erosion, soil stability and soil expansion.
The following report has been prepared to help analyze the geological and geotechnical impacts of the proposed project and is included in its entirety in Appendix G of the Draft Environmental Impact Report (EIR):
• Preliminary Geotechnical Evaluation – Proposed Residential Development, APN 220-210-49- 00, Northeast of Woodward & Mission, San Marcos, California . Prepared by GeoTek. Dated May 16, 2019.
In the Initial Study checklist prepared for the proposed project (Appendix B.1), it was determined that there would be no potential for the project to have an adverse impact associated with the ability of soils to support the use of septic or alternative wastewater systems as no septic or alternative wastewater systems are included as part of the project. Since the proposed project would be served by Vallecitos Water Di strict for sewer service, no septic or alternative wastewater systems are proposed. Section 5.4, Environmental Effects Found Not to be Significant – Geology and Soils, of this EIR provides additional information on these topics.
A summary of the project- and cumulative-level geology and soils analysis, by threshold, is provided in Table 3.6-1.
Table 3.6-1. Geology and Soils Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#1 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
Rupture of a known earthquake fault, as
delineated on the most recent Alquist-
Priolo Earthquake Fault Zoning map,
issued by the State Geologist for the area
or based on other substantial evidence of
a known fault?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#2 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving
strong seismic ground shaking?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#3 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving
seismic-related ground failure, including
liquefaction?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
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Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#4 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving
landslides?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#5 - Result in substantial soil erosion or
the loss of topsoil?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#6 - Be located on a geologic unit or soil
that is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-
site landslide,
lateral spreading, subsidence, liquefaction,
or collapse?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#7 - Be located on expansive soil, as
defined in Table 18-1-B of the Uniform
Building Code (1994), creating substantial
risks to life or property?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#8 - Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
3.6.1 Existing Conditions
This section details the existing conditions on the project site including topography, soils, groundwater, and the project site’s location to major faults.
Site Conditions
The project site is located northeast of Woodward Street and E. Mission Road in San Marcos. The site is generally bounded to the west by Woodward Street, to the north by a natural slope, to the east by residential development, and to the south by a natural slope descending to E . Mission Road and a multi-family residential development. The site is located in a hillside setting with topography generally ascending from the north, west, and south site boundaries to the eastern boundary of the site. Site surface conditions generally consist of dense natural vegetation and outcrops of boulders. The site area appears vacant, with a local area which appears to have been cut to a level pad. Access is achieved via an unpaved road off Woodward Street and wraps around the west side of the slope to a localized level pad. Fill areas appear to be attributed to the access road and level pad. Total relief across the site is on the order of 100± feet, with surface drainage directed towards the southwest.
Topographically, elevation ranges from 754 feet above mean sea level (amsl) in the eastern portion of the project site down to 615 feet amsl in the southwestern portion of the project site. Steep natural gradients exist in the central, northeastern, and northwestern portions of the property. These slope areas are locally as steep as 1:1 (horizontal to vertical) in gradient and expose Monzogranite (granitic)
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bedrock materials. Relatively small earthen fill slope areas (unmapped) were also noted along the access road and edges of the level pad (Geotek 2019).
Soils
Regionally, the project site is located in the Peninsular Ranges geomorphic province. The Peninsular Ranges province is one of the largest geomorphic units in western North America. The Peninsular Ranges extend roughly 975 miles from the north and northeasterly adjacent the Transverse Ranges geomorphic province to the tip of Baja California. This province varies in width from about 30 to 100 miles. It is bounded on the west by the Pacific Ocean, on the south by the Gulf of California and on the east by the Colorado Desert Province. The Peninsular Ranges are essentially a series of northwest - southeast oriented fault blocks (Geotek 2019).
Based on field observations and review of published geologic maps, the project site area is locally underlain by sporadic undocumented fill materials, colluvium, and Cretaceous age crystalline bedrock.
The following is a brief description of the subsurface materials encountered (Geotek 2019).
Undocumented Fill
Some undocumented fill soils were locally observed in the vicinity of the level pad in the southern vicinity of the site and along the unpaved access road that wraps around the western side of the site.
As observed, the undocumented fill generally consisted of silty sand with some cobbles and small boulders. Other areas of undocumented fill (unmapped) are also likely present on the site.
Undocumented fill soils are not considered suitable for support of structural site improvements but may be re-used as engineered fill if properly placed (Geotek 2019).
Colluvium (Not Mapped)
Colluvial soils are anticipated to be present in drainage swales or in localized areas on the site in relatively lower gradient slopes. Colluvial materials were not directly observed, however are anticipated to generally consist of clayey sands that are organic in nature. In general, the colluvium is likely thinner (i.e., bedrock is shallower) where slope gradients are steeper and in steep areas, might not be present at all (Geotek 2019).
Bedrock
The most recent regional geologic map showing the overall site geology shows Mesozoic -aged meta- sedimentary bedrock at the surface across the site, however during Geotek’s site evaluation , Cretaceous age plutonic bedrock tonalite -monzogranite (granite) was observed across the property, with outcrops and partially exposed core stones of bedrock materials. In the exploratory trenches, weathered to less weathered tonalite bedrock materials were encountered and observed to excavate primarily as red brown silty sand with gravel, cobble, and small boulder size fragments. Granitic bedrock materials were also observed on the adjacent surrounding properties, most notably to the east, north and south (Geotek 2019).
Groundwater
Groundwater is not anticipated to be within 50 feet of the ground surface at the project site and is not anticipated to be a factor in site development. Localized perched groundwater could be present but is also not anticipated to be a factor in site development (Geotek 2019).
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Seismicity
The geologic structure of the entire southern California area is dominated mainly by northwest-trending faults associated with the San Andreas system. The project site is in a seismically active region. No active or potentially active fault is known to exist at this site nor is the site situated within an Alquist - Priolo Earthquake Fault Zone or a Special Studies Zone. No faults were identified on geologic maps for the immediate study area (Geotek 2019).
Seismic hazards may be primary, such as surface rupture and/or ground shaking, or secondary, such as liquefaction or dynamic settlement.
Surface Fault Rupture
Surface fault rupture is a break in the ground surface during, or as a consequence of, seismic activity.
Fault rupture occurs most often along pre -existing fault traces. As discussed above, n o active or potentially active fault is known to exist at this site nor is the site situated within an Alquist -Priolo Earthquake Fault Zone or a Special Studies Zone. No faults are identified for the immediate study area. Accordingly, the potential for fault surface rupture on the project site is low.
Liquefaction/ Seismic Settlement
Liquefaction describes a phenomenon in which cyclic stresses, produced by earthquake induced ground motion, create excess pore pressures in relatively cohesionless soils. These soils may thereby acquire a high degree of mobility, which can lead to lateral movement, sliding, consolidation and settlement of loose sediments, sand boils and other damaging deformations. This phenomenon occurs only below the water table, but, aft er liquefaction has developed, the effects can propagate upward into overlying non-saturated soil as excess pore water dissipates.
The factors known to influence liquefaction potential include soil type and grain size, relative density, groundwater level, confining pressures, and both intensity and duration of ground shaking. In general, materials that are susceptible to liquefaction are loose, saturated granular soils having low fines content under low confining pressures.
The liquefaction potential and seismic settlement potential on this site is considered to be negligible, due to shallow bedrock and absence of a shallow groundwater table (Geotek 2019). The project site is identified as having Zero Susceptibility for liquefaction per Figure 6 -1 of the Safety Element of the City’s General Plan (City of San Marcos 2012).
Other Seismic Hazards
Evidence of ancient landslides or slope instabilities at th e site was not observed during the investigation. Thus, the potential for landslides is considered negligible. Rockfall potential should be further assessed when site development plans become available and during grading construction. The potential for secondary seismic hazards such as seiche and tsunami is considered to be remote due to site elevation and distance from an open body of water (Geotek 2019).
Paleontological Resources
The project site lies within the Peninsular Ranges Geomorphic Province of southern California. This province consists of a series of ranges separated by northwest trending valleys; subparallel to branches of the San Andreas Fault. The Peninsular Ranges geomorphic province is one of the largest
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geomorphic units in western North America, extends from the Transverse Ranges geomorphic province and the Los Angeles Basin, south to Baja California. It is bound on the west by the Pacific Ocean, on the south by the Gulf of California and on the east by the Colorado Desert Province. Peninsular Ranges are essentially a series of northwest -southeast oriented fault blocks. Major fault zones and subordinate fault zones found in the Peninsular Ranges Province typically trend in a northwest - southeast direction.
Within the Peninsular Ranges Geomorphic Province, the project site lies within the Peninsular Ranges Region. This region is primarily underlain by plutonic igneous rocks that formed from the cooling of molten magmas deep within the earth's crust. These mag mas were generated during subduction of an oceanic crustal plate that was converging on the North American Plate between 120 and 90 million years ago. Over this long period of time, extensive masses of plutonic rocks accumulated within the crust. Intense heat associated with these plutonic intrusions metamorphosed the ancient sedimentary rocks that were already there. These metasediments are now preserved in the Peninsular Ranges Region as marbles, slates, schist, quartzites, and gneiss. Younger undeformed sedimentary rocks occur in various areas of the Peninsular Ranges Region. According to the County of San Diego Guidelines for Determining Significance of Paleontological Resources, known fossil occurrences in the Peninsular Range are extremely rare though some areas may have a high to moderate potential to contain paleontological resources (County of San Diego 2009).
The Peninsular Ranges Region contains paleontological resources in Quaternary alluvial and alluvial fan deposits in many of the mountain valleys . Geologic formations that are composed either of volcaniclastic (derived from volcanic sources) or metasedimentary rocks, are considered to have marginal resource potential. No resource potential is assigned to geologic formations that are composed entirely of volcanic or plutonic igneous rock, such as basalt or granite, and therefore do not have any potential for producing fossil remains (County of San Diego 2009).
According to the Preliminary Geotechnical Evaluation prepared for the project (Geotek 2019), the geologic conditions underlying the site consist of undocumented artificial soils and colluvium (not mapped). The most recent geologic map showing overall site geology (Kennedy 2007 as cited in Geotek 2019) shows Mesozoic- aged meta -sedimentary bedrock at the surface across the site.
However, based on Geotek’s site evaluation, Cretaceous age plutonic bedrock granite was observed across the property, with outcrops and partially exposed core stones of bedrock materials.
Given the project site supports plutonic bedrock granite and colluvium, it would not be characterized as having a high or moderate potential for paleontological resources.
3.6.2 Regulatory Setting
This section describes the federal, state, and local regulations related to geology and soils.
Federal
Federal Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 provides a set of mitigation plan requirements that emphasize State and local jurisdictions to coordinate disaster mitigation planning and implementation. States are encouraged to complete a “Standard” or an “Enhanced” N atural Mitigation Plan. “Enhanced” plans demonstrate increased coordination of mitigation activities at the State level, and if completed and approved, will increase the amount of funding through the Hazard Mitigation Grant Program.
California’s updated St ate Hazard Mitigation Plan was adopted and approved by the Federal
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Emergency Management Agency (FEMA) Region IX in 2007. The City of San Marcos is one of the communities covered by the 2023 County of San Diego Multi -Jurisdictional Hazard Mitigation Plan, which is a countywide plan that identifies risks posed by natural and manmade disasters.
Federal Response Plan
The Federal Response Plan of 1999 is a signed agreement among 27 federal departments and agencies, including the American Red Cross, that (1) provides the mechanism for coordinating delivery of federal assistance and resources to augment efforts of state and local governments overwhelmed by a major disaster or emergency; (2) supports implementation of the Robert T. Stafford Disaster Relief and Emergency Act, as well as individual agency statutory authorities; and (3) supplements other federal emergency oper ations plans developed to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant event likely to result in a need for federal assistance or in response to an actual event requiring federal assistance under a pre sidential declaration of a major disaster or emergency.
USGS Landslide Hazard Identification Program
The United States Geological Survey (USGS), in fulfillment of the requirements of Public Law 106-113, created the National Landslide Hazards Program to reduce long -term losses from landslide hazards by improving understanding of the causes of ground failure and suggesting mitigation strategies. FEMA is the agency responsible for the long-term management of natural hazards.
International Building Code
The International Building Code (IBC) is a model building code developed by the International Code Council that provides the basis for the CBC. The purpose of the IBC is to provide minimum standards for building construction to ensure public safety, health, and welfare. Prior to the creation of the IBC, several different building codes were used; however, by the year 2000, the IBC had replaced these previous codes and is updated every three years. The 2021 IBC code is currently in effect.
State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act is the State law that focuses on hazards from earthquake fault zones. The purpose of this law is to mitigate the hazard of surface fault rupture by regulating structures designated for human occupancy near active faults. As required by the act, the California Geological Survey has delineated Earthquake Fault Zones along known active faults in California.
California Geologic Survey
The California Geologic Survey provides guidance with regard to seismic hazards. The California Geologic Survey’s Special Publication 117A, Guidelines for Evaluating and Mitigating Seismic Hazards in California (2008), provides guidance for evaluation and mitigation of earthquake-related hazards for projects within designated zones of required investigation.
California Surface Mining and Reclamation Act
Enacted to promote conservation and protection of significant mineral deposits, the California Surface Mining and Reclamation Act requires that all cities address in their General Plans the significant
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aggregate resources classified by the State Geologist and designated by the State Mining and Geology Board. The law also ensures that significant aggregate resources are recognized and considered before land use decisions are made that may compromise the availability of these resources.
Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (SHMA) was enacted in 1997 to protect the public from the effects of strong ground shaking, liquefaction, landslides, or other ground failure, and from other hazards caused by earthquakes. This act requires the State Geologist to map areas subject to seismic hazards.
A geotechnical investigation of the site must be conducted and appropriate mitigation measures incorporated into the project design before development permits will be granted. Additionally, the Act requires a Standardized Natural Hazards Disclosure Statement form to be completed by real estate sellers if a property is within one of the designated natural hazards areas.
Natural Hazards Disclosure Act
The Natural Hazards Disclosure Act (effective June 1, 1998), requires “that sellers of real property and their agents provide prospective buyers with a ‘Natural Hazard Disclosure Statement’ when the property being sold lies within one or more state -mapped hazard areas, including a Seismic Hazard Zone.” SHMA specifies two ways in which this disclosure can be made:
• The Local Option Real Estate Transfer Disclosure Statement as provided in Section 1102.6a of the Civil Code; or
• The Natural Hazard Disclosure Statement as provided in Section 1103.2 of the Civil Code.
The Local Option Real Estate Disclosure Statement can be substituted for the Natural Hazards Disclosure Statement if it contains substantially the same information and substantially the same warning as the Natural Hazards Disclosure Statement. Both the Alquist -Priolo Act and the SHMA require that real estate agents, or sellers of real estate acting without an agent, disclose to prospective buyers that the property is located in an Alquist -Priolo Earthquake Fault Zone or Seismic Hazard Mapping Zone.
California Uniform Building Code
The California Code of Regulations (CCR), also known as Title 24, California Building Standards Codes contain the laws regarding the construction of buildings. Title 24, Part 2 of the California Uniform Building Code (UBC) specifies standards for geologic and seismic hazards, other than surface faulting.
Chapter 23 of the California UBC addresses seismic safety, and includes regulations for earthquake - resistant design and construction. The 20 22 Triennial Edition of the Title 24, California Building Standards Code went into effect January 1, 2023.
Local
County of San Diego Multi-Jurisdictional Hazard Mitigation Plan To comply with the Disaster Mitigation Act of 2000, the County of San Diego prepared the Multi - Jurisdictional Hazard Mitigation Plan in 2010. The plan serves as both a county-wide plan and a plan for local jurisdictions that identifies risks posed by natural and human-made disasters before a hazard event occurs. This plan was last revised in 2023 to reflect changes to both the hazards threatening San Diego County, as well as the programs in place to minimize or eliminate those hazards. The plan includes overall goals and objectives shared by many jurisdictions, as well as specific goals, objectives,
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and mitigation action items for each of the participating jurisdictions, including the City of San Marcos, developed to help minimize the effects of the specified hazards that potentially affect their jurisdiction.
San Marcos General Plan Safety Element
The Safety Element of the San Marcos General Plan contains several policies pertaining to natural geologic hazards. The following goal and policies apply to the project:
• Goal S-1: Reduce risks to the community from earthquakes by regulating new development and redevelopment to prevent the creation of new geologic and seismic hazards. o Policy S-1.1: Reduce the risk of impacts from geologic and seismic hazards by applying current and proper land use planning, development engineering, building construction, and retrofitting requirements.
o Policy S-1.2: Investigate specific groundwater levels and geologic conditions underlying all new development or redevelopment proposals in areas where potential fault rupture, liquefaction, or other geologic hazards are suspected.
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use. As detailed in Table 3.8-12, the project is consistent with the applicable goals and policies.
3.6.3 Thresholds of Significance
As defined in Appendix G of the California Environmental Quality Act (CEQA) Guidelines , project impacts to geological resources are considered significant if the project would:
• Threshold #1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault; • Threshold #2: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking; • Threshold #3: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction; • Threshold #4: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides;
• Threshold #5: Result in substantial soil erosion or the loss of topsoil; • Threshold #6: Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse;
• Threshold #7: Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property; • Threshold #8: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
As noted above, it was determined that there would be no impact associated with the ability of soils to support the use of septic or alternative wastewater systems. Section 5.4, Environmental Effects Found
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Not to Be Significant – Geology and Soils, provides additional information on these topics. The Initial Study is included in Appendix B.1.
3.6.4 Project Impact Analysis
This section provides a project -level impact analysis for the eight thresholds related to geology and soils. The proposed project would be graded to create building pads for future multi-family residential uses, and associated infrastructure. Grading for the project w ould consist of approximately 41,989 cubic yards (CY) of cut material and 50,270 CY of fill material for a difference of 8,281 CY. If suitable, the excess material would be used as backfill and the site would balance. If it is not suitable, the fill would be exported from the site. The project design incorporates retaining walls to manage the topography of the site and create areas for the access driveway and building pads. The proposed retaining walls include slump block, geogrid, and soil nail styles, depending on the location within the project. There is existing netting along the Woodward Street frontage to minimize the potential for rock and debris fall onto the roadway. As noted on the proposed grading plans for the project, a portion of this netting would be removed to accommodate the project grading. The netting would be re-anchored to the new top of slope or as recommended by the soils engineer during project construction.
The import and export of earth material is guided by Section 17.32.080 of the City’s Municipal Code and prior to any import of soils, a haul route w ould be submitted for review and approval by the City Engineer. Additionally, grading and other earth moving activities are restricted to the hours of 7:00 AM and 4:30 PM, Monday through Friday, per Section 17.32.180 of the City’s Municipal Code.
The project would implement all recommendations from the preliminary geotechnical investigation (Geotek 2019). These recommendations include general provisions related to the site as well as specific recommendations related to foundation design, concrete design, and corrosion. The detailed recommendations are included in Chapter 5 of the geotechnical report, which is included as Appendix G of this document.
Threshold #1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning map, issued by the Stat e Geologist for the area or based on other substantial evidence of a known fault?
The project site is located within a seismically active region, as is all of southern California; however, the project site is not located on or adjacent to any known active faults. According to the California Earthquake Hazard Zone Application, the City of San Marcos is not identified as a jurisdiction affected by Alquist-Priolo Earthquake Fault Zones (California Department of Conservation 2023). Therefore, the site is not located within a currently established Alquist-Priolo Earthquake Fault Zone.
Project structures would be designed in accordance with the California Building Code (CBC) (2022 or most current version at time of building ) for resistance to seismic shaking . The project would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of the State of California Occupational Safety and Health Administration (Cal/OSHA).
As stated above, the project would implement all recommendations from the preliminary geotechnical investigation (Geotek 2019). These recommendations include general provisions related to the site as well as specific recommendations related to foundation design, concrete design, and corrosion.
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With adherence to all regulations and recommendations, the project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault. Impacts would be
less than significant.
Threshold #2: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? The proposed project is located in tectonically -active southern California. The type and magnitude of seismic hazards affecting the site are dependent on the distance to causative faults, and the intensity and the magnitude of the seismic event. Per the geotechnical study , the site is not located within a currently established Alquist-Priolo Earthquake Fault Zone.
As described in Threshold #1, the project would be designed in accordance with the latest CBC, current design specification of the Structural Engineers Association of California, other applicable regulations, all applicable requirements of Cal/OSHA, and re commendations from the preliminary geotechnical investigation (Geotek 2019). With adherence to all regulations and recommendations, impacts related to seismic ground shaking would be
less than significant.
Threshold #3: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Seismic-related ground failure, including liquefaction? Seismic-related Ground Failure
The geotechnical study indicated that there are no active faults mapped on the project site and the site is not located within a mapped Alquist-Priolo Earthquake Fault Zone. Accordingly, the potential for fault surface rupture on the project site is low.
Liquefaction
Liquefaction occurs when loose, saturated, generally fine sands and silts are subjected to strong ground shaking. The soils lose shear strength and become liquid; potentially resulting in large total and differential ground surface settlements as well as possible lateral spreading during an earthquake. Seismically induced settlement can occur in response to liquefaction of saturated loose granular soils, as well as the reorientation of soil particles during strong shaking of loose, unsaturated sands.
The project site is identified as having Zero Susceptibility for liquefaction per Figure 6 -1 of the Safety Element of the City’s General Plan ( City of San Marcos 2012). Per the geotechnical study, the liquefaction potential and seismic settlement potential on the project site is considered to be negligible, due to shallow bedrock and absence of a shallow groundwater table (Geotek 2019).
Therefore, the project would not result in seismic -related ground failure, including liquefaction.
Impacts would be less than significant.
Threshold #4: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides?
Per the geotechnical report, evidence of ancient landslides or slope instabilities at the project site was not observed during the investigation. Thus, the potential for landslides is considered negligible.
Rockfall potential would be further assessed during grading and construction. Further, the project site is identified as having Zero Susceptibility for soil slip, surficial landslides, or liquefaction per Figure 6- 1 of the Safety Element of the City’s General Plan (City of San Marcos 2012). Therefore, the project
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would not directly or indirectly cause potentially substantial adverse effects, including the risk of loss, injury or death involving landslides. Impacts would be less than significant.
Threshold #5: Result in substantial soil erosion or the loss of topsoil? Proposed site improvements require grading and possible soil export of approximately 8,281 cy of material. The project would be under the State Water Resources Control Board (SWRCB) General Construction Permit, which prohibits sediment or pollutant release from the project site and requires preparation of a Stormwater Pollution Prevention Plan (SWPPP) and implementation of best management practices (BMPs) that would incorporate erosion and sediment control measures during and after grading operations to sta bilize these areas. Therefore, the proposed project would incorporate BMPs and recommendations that would minimize erosion and loss of topsoil. Additionally, the project’s proposed landscape plan includes a mix of trees, shrubs, and groundcover which would further minimize soil erosion and top soil loss. The landscape plan and planting palette is included in Appendix A.3. Therefore, the proposed project would not result in substantial soil erosion of the loss of topsoil. Impacts would be less than significant.
Threshold #6: Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Based upon the geotechnical report prepared for the project (Geotek 2019), evidence of ancient landslides or slope instabilities at this site was not observed during the geotechnical investigation.
Thus, the potential for landslides is considered negligible. Rockfall potential would be further assessed during grading. Further, the project site is identified as having Zero Susceptibility for soil slip, surficial landslides, or liquefaction per Figure 6-1 of the Safety Element of the City’s General Plan (City of San Marcos 2012).
Site preparation and fill material replacement w ould be completed consistent with the recommendations in the geotechnical investigation ( Geotek 2019). Grading would be accomplished under the observation and testing of the project geotechnical engineer and engineering geologist or their authorized representative in accordance with the recommendations and earthwork specifications of the geotechnical investigation and the current grading ordinance of the City of San Marcos.
In summary, the proposed project would incorporate techniques and recommendations that would minimize the potential for unstable conditions that could result in on - or off-site, landslide, lateral spread, subsidence, liquefaction, or collapse. Impacts would be less than significant.
Threshold #7: Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial risks to life or property? According to the geotechnical investigation , the surficial soils consist of undocumented artificial fill, colluvium, and Cretaceous age plutonic bedrock. Soil near subgrade would be classified as “very low” expansive. With adherence to the geotechnical report recommendations, which include removal and compaction during grading, impacts related to expansive soils would be less than significant.
Threshold #8: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The proposed project site lies within the Peninsular Ranges Geomorphic Province of southern California. According to the Preliminary Geotechnical Evaluation prepared for the project (Geotek
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2019), the geologic conditions underlying the site consist of undocumented artificial soils and colluvium (not mapped). The most recent geologic map showing overall site geology (Kennedy 2007 as cited in Geotek 2019) shows Mesozoic-aged meta-sedimentary bedrock at the surface across the site. However , based on Geotek’s site evaluation, Cretaceous age plutonic bedrock granite was observed across the property, with outcrops and partially exposed core stones of bedrock materials.
According to the San Diego County Guidelines for Determining Significance of Paleontological Resources, no resource potential is assigned to geologic formations that are composed entirely of volcanic or plutonic igneous rock, such as basalt or granite, and therefore do not have any potential for producing fossil remains. Given the project site supports plutonic bedrock granite and colluvium, it would not be characterized as having a high or moderate potential for paleontological resources.
Therefore, it is very unlikely that paleontological resources Would be disturbed during grading activities for the project, and impacts would be less than significant.
3.6.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to geology and soils, the cumulative analysis is bas ed upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to geology and soils. All of the cumulative projects identified in Table 2 -4 are considered in this cumulative analysis.
Due to the localized nature of geology and soils, cumulative projects would address potential impacts to geology and soils on a project -by-project basis, as potential geologic hazards and soil composition varies by site. Each cumulative project would be required to assess individual and site-specific geologic conditions, which would inform construction and development of each site. All cumulative development would be subject to similar requirements to those imposed and implemented for the proposed project a nd would be required to adhere to applicable regulations, standards, and procedures.
Further, as discussed in Section 3.6.4, the project site has very low potential to yield paleontological resources. Thus, impacts to paleontological resources from implementation of the project would be less than significant. It is expected that cultural resources studies would be prepared for all cumulative projects to assess potential paleontological impacts. For the cumulative projects that are within sensitive areas for paleontological resources, the expectation is that mit igation measures would be included to require consultation with a paleontologist or a construction monitor to ensure that impacts to this resource do not occur. As such, the proposed project would not result in significant cumulative impacts for geology and soils. Impacts would be
less than significant.
3.6.6 Mitigation Measures
Based upon the analysis presented in Sections 3. 6.4 and 3. 6.5, project and cumulative impacts related to geology and soils would be less than significant. Therefore, no mitigation measures are required.
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3.6.7 Conclusion
Based upon the analysis presented in Sections 3.6. 4 and 3.6.5, impacts associated with seismicity, liquefaction, landslides, erosion/loss of topsoil, compressible soils, and expansive soils, would be less than significant. The project w ould adhere to all recommendations in the preliminary geotechnical investigation prepared for the project ( Geotek 2019). Due to the fact that the project site supports plutonic bedrock granite and colluvium, it would not be characterized as having a high or moderate potential for paleontological resources and impacts would be less than significant.
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3.7 Hydrology and Water Quality
Introduction
This section identifies the existing hydrologic and water quality conditions on the project site and analyzes the potential impacts of the proposed project on hydrology and water quality. The analysis in this section is based upon the following reports whi ch are included as Appendix H and I of this
Environmental Impact Report7:
• Priority Project Hydrology Study for Cornerstone Communities Woodward, APN No. 220 -210- 49, prepared by Excel Engineering, June 14, 2023 (Excel 2023). • Priority Development Project Stormwater Quality Management Plan (SWQMP) Cornerstone Communities Woodward, Woodward Street, San Marcos, CA , prepared by Excel Engineering, September 22, 2022 (Excel 2022).
The preliminary drainage report and SWQMP discusses applicable hydrologic volume and storm water requirements and analyzes peak flow anticipated for preliminary design of the on- site storm drain system. The analysis in this section also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan.
In the Initial Study prepared for the proposed project (Appendix B.1), it was determined that the project would have no impact on the following hydrology/water quality -related issue areas: groundwater supplies depletion, and risk release of pollutants due to project inundation in flood hazard, tsunami or seiche zones. Therefore, these issue s are not discussed further in this EIR section. Section 5.8, Environmental Effects Found Not to be Significant – Hydrology and Water Quality of this EIR provides additional information on these topics.
Table 3.7-1 summarizes the project- and cumulative-level hydrology and water quality impact analysis by threshold.
Table 3.7-1. Hydrology/Water Quality Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-
Level
Impact
Impact After
Mitigation
#1: Violate any water quality standards or
waste discharge requirements or other
substantially degrade surface or groundwater
quality?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#2: Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would: result in substantial
erosion or siltation on- or off-site?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
7 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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Threshold of Significance Project-Level
Impact
Cumulative-
Level
Impact
Impact After
Mitigation
#3: Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would: substantially
increase the rate or amount of surface runoff
in a manner which would result in flooding on-
or off-site?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#4: Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would: create or contribute
to runoff water which would exceed the
capacity of existing or planned stormwater
drainage systems or provide substantial
additional sources of polluted runoff?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#5: Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would: impede or redirect
flood flows?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#6: Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#7: Result in significant alteration of receiving
water quality during or following construction?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#8: Result in an increase in pollutant
discharges to receiving waters? Consider
water quality parameters such as temperature,
dissolved oxygen, turbidity, and other typical
storm water pollutants (e.g., heavy metals,
pathogens, petroleum derivatives, synthetic
organics, sediment, nutrients, oxygen-
demanding substances, and trash).
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#9: Be tributary to an already impaired water
body as listed on the Clean Water Act Section
303(d) list? If so, can it result in an increase in
any pollutant for which the water body is
already impaired?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
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Threshold of Significance Project-Level
Impact
Cumulative-
Level
Impact
Impact After
Mitigation
#10: Be tributary to environmentally sensitive
areas (e.g., MSCP, RARE, Areas of Special
Biological Significance, etc.)? If so, can it
exacerbate already existing sensitive
conditions?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
#11: Have a potentially significant
environmental impact on surface water
quality, to either marine, fresh or wetland
waters?
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
3.7.1 Existing Conditions
This section details the existing hydrology, water quality and groundwater conditions on the project site.
Site Hydrology
The project site is currently vacant and undeveloped. The project fronts onto Woodward Street and E.
Mission Road. The property drains primarily by overland flow to an existing storm drain system located at the southwest corner of the project site. There are three discharge locations, or points of confluence (POC) on the site. POC-1 is located at the southwest corner of th e project site with a 100-year peak flow of 16.14 cubic feet per second ( cfs). POC-2 is located at the southeastern corner of the project site with the 100-year peak flow of 7.87 cfs, and POC-3 is at the northwest edge of the project site with the 100-year peak flow of 2.17 cfs (Excel 2023).
On-Site Drainage
The upper east side of the project site drains westerly to the existing 18 - and 24-inch storm drain pipes, then drains to POC-1 (southwest corner of the site). The lower east side of the project site drains southerly to the existing 1 8- and 24-inch storm drain pipes, then to POC- 2 (southeast corner of the site). AT the most northern portion of the project site , surface runoff drains northerly to POC -3 (northwest edge of the site).
Off-Site Drainage
At the northeast part of the project site, approximately 0.2 acres offsite are conveyed through the site, then drains to POC-3. At the middle east edge of the project site, approximately 0.15 acres of offsite areas drainage is conveyed through the site then drains to POC-1. In addition, at the lower east part of the project site, approximately 1.21 offsite acres, drains to POC-2.
Water Quality
The proposed project is located within the jurisdiction of the San Diego Regional Water Quality Control Board (RWQCB). The San Diego Region is divided into eleven hydrologic units. The project site is located in the Richland Hydrologic Subarea (904.52) wit hin the San Marcos Hydrologic Area (HA) (904.5) of the Carlsbad Watershed (Hydrologic Unit (904). The project site discharges to a public storm
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drain system which flows to an un -named tributary that flows to San Marcos Creek (passing through Lake San Marcos) to Batiquitos Lagoon, which discharges to the Pacific Ocean.
The Carlsbad Watershed Management Area (WMA) is approximately 211 square miles and is formed by a group of six individual watersheds in northern San Diego County. The WMA is bordered by the San Luis Rey River WMA to the north and by the San Dieguito River WMA to the south. It reaches inland nearly 24 miles to just northeast of Lake Wohlford. The maximum elevation of the WMA is approximately 2,400 feet and it extends to sea level at the Pacific Ocean. The Carlsbad WMA is made up of six distinct Hydrologic Areas (HA)s: Loma Alta, Buena Vista Creek, Agua Hedionda, Encinas, San Marcos, and Escondido Creek. The WMA includes the entire Cities of Carlsbad, San Marcos and Encinitas and portions of the cities of Oceanside, Vista, Escondido, Solana Beach, and San Dieg o County unincorporated areas.
The San Marcos HA is the second largest within the WMA. It is about 36,000 acres in area and comprises approximately 28% of the Carlsbad WMA. The major receiving waters within the Hydrologic Area are San Marcos Creek, Encinitas Creek, Batiquitos Lagoon, and the Pacific Oce an. San Marcos Creek originates on the western slopes of the Merriam Mountains in west central San Diego County and discharges to the Pacific Ocean, 14.6 miles away, via Batiquitos Lagoon. Encinitas Creek is another one of the major tributaries in the HA, originating in the hills southwest of Questhaven Road and paralleling El Camino Real before it converges with San Marcos Creek at the southeastern corner of Batiquitos Lagoon. The highest elevation within the HA is approximately 1,540 feet above mean sea level (amsl). Lake San Marcos is the largest impoundment within the HA. The San Marcos HA is primarily located in the cities of San Marcos, Carlsbad, Encinitas, and the County of San Diego, with a small portion in Escondido.
The San Marcos HA has two distinctive areas separated by the Lake San Marcos impoundment – the Upper and Lower San Marcos HA areas. The Upper Hydrologic Area includes drainage areas in the County of San Diego, and the cities of San Marcos and Escondido, th at runoff through Upper San Marcos Creek to Lake San Marcos. The Lower Hydrologic Area consists of portions of the cities of Carlsbad, Encinitas, San Marcos, and Vista (Carlsbad Watershed Management Area 2022).
Within the Water Quality Control Plan for the San Diego Basin (San Diego Basin Plan), San Marcos Creek and Batiquitos Lagoon, located downstream of the project site, are identified as having numerous beneficial uses. For San Marcos Creek, these beneficial uses are: Agricultural Supply (AGR), Contact Water Recreation (REC1), Non -Contact Water Recreation (REC2), Warm Freshwater Habitat (WARM) and Wildlife Habitat (WILD). For Batiquitos Lagoon, these uses are: REC1, REC2, Preservation of Biological Habitats of Special Significance (BIOL), Estuarine Habitat (EST), WILD, Rare, Threatened, or Endangered Species (RARE), Marine Habitat (MAR), Migration of Aquatic Organisms (MIGR), and Spawning, Reproduction, and/or Early Development (SPWN). The Basin Plan includes numerical and qualitative water quality objectives to protect the listed beneficial uses for each water body.
The San Marcos Creek system consists of a number of water bodies that are listed as impaired under Section 303(d) of the Clean Water Act. In accordance with Section 303(d) of the 1972 Federal Clean Water Act (CWA), the State Water Resources Control Board (SWRCB) has established a list of “impaired water bodies.” San Marcos Creek is listed on the 2020-2022 Integrated Report (CWA Section 303(d)/ 305(b)) List of Impaired Water Segments as being impaired for Nutrients (nitrogen and phosphorus), Metals ( selenium), Total Toxics (toxicity), Other Causes (Benthic Community Effects), Pesticides (bifenthrin, dichlorodiphenyldichloroethylene (DDE) and pyrethroids), Pathogens (indicator bacteria), and total dissolved solids. Further downstream, Batiquitos Lagoon is also listed as being impaired for
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toxicity. Furthermore, San Marcos Lake was identified under Section 303(d) of the Clean Water Act as impaired due nutrients (ammonia as nitrogen and phosphorous, and metals (copper) (SWRCB 2022).
3.7.2 Regulatory Setting
This section details the applicable federal, state, and local regulations pertaining to hydrology and water quality.
Federal
Federal Emergency Management Agency
The Federal Emergency Management Agency (FEMA) administers the National Flood Insurance Program to provide subsidized flood insurance to communities that comply with FEMA regulations limiting development in floodplains. FEMA also issues Flood Insurance Rate Maps that identify which land areas are subject to flooding. These maps provide flood information and identify flood hazard zones in the community. The standard for flood protection is established by FEMA, with the minimum level of flood protection for n ew development determined to be the one percent -annual exceedance probability (i.e., the 100 -year flood event). Per FEMA’s Flood Insurance Rate Map Number 06073C0793G , the project site is not located within a 100-year flood hazard area (FEMA 2012).
Federal Clean Water Act
The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the U.S. and regulating quality standards for surface waters. The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control Act, but the Act was significantly reorganized and expanded in 1972. “Clean Water Act” became the Act’s common name with amendments in 1977.
Under the CWA, the U.S. Environmental Protection Agency (USEPA) has implemented pollution control programs such as setting wastewater discharge standards for industry. The USEPA has also set water quality standards for contaminants in surface waters. The CWA made it unlawful to discharge any pollutant from a point source into navigable waters unless a permit was obtained.
Section 303(d) of the Clean Water Act
Under Section 303(d) of the CWA, states are required to develop lists of water bodies that would not attain water quality objectives after implementation of required levels of treatment by point -source dischargers (municipalities and industries). Section 3 03(d) requires that the state develop a total maximum daily load (TMDL) for each of the listed pollutants. The TMDL is the amount of loading that the water body can receive and still be in compliance with water quality objectives. The TMDL can also act as a plan to reduce loading of a specific pollutant from various sources to achieve compliance with water quality objectives. The TMDL prepared by the state must include an allocation of allowable loadings to point and non -point sources, with consideration of background loadings and a margin of safety. The TMDL must also include an analysis that shows the linkage between loading reductions and the attainment of water quality objectives. The USEPA must either approve a TMDL prepared by the state or, if it disapproves the state’s TMDL, issue its own. National Pollutant Discharge Elimination System (NPDES) permit limits for listed pollutants must be consistent with the waste load allocation prescribed in the TMDL. After implementation of the TMDL, it is anticipated that the problems that led to placement of a given pollutant on the Section 303(d) list would be remediated.
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National Pollutant Discharge Elimination System
The NPDES permit system was established in the federal CWA to regulate municipal and industrial discharges to surface waters of the U.S. Sections 401 and 402 of the CWA contain general requirements regarding NPDES permits. Section 307 of the CWA describes the factors that US EPA must consider in setting effluent limits for priority pollutants.
Non-point sources are diffuse and originate from a wide area rather than from a definable point. Non- point pollution often enters receiving waters in the form of surface runoff but is not conveyed by way of pipelines or discrete conveyances. As defined in the federal regulations, such non-point sources are generally exempt from federal NPDES permit program requirements. However, three types of non-point source discharges are controlled by the NPDES program: non -point source discharge caused by general construction activities, the general quality of stormwater in municipal stormwater systems, and discharges associated with industrial operations. The 1987 amendments to the CWA directed the federal EPA to implement the stormwater program in two phases. Phase I addressed discharges from large (population 250,000 or above) and medium (population 100,000 to 250,000) municipalities and certain industrial activities. Phase II addresses all other discharges defined by USEPA that are not included in Phase I.
In accordance with NPDES regulations, in order to minimize the potential effects of construction runoff on receiving water quality, the State requires that any construction activity that disturbs one acre or more must obtain a General Construction Activity Stormwater Permit. Permit applicants are required to prepare a stormwater pollution prevention plan (SWPPP) and implement b est management practices (BMPs), such as erosion and sediment control and non-stormwater management measures, to reduce construction effects on receiving water quality.
Examples of typical BMPs implemented in SWPPPs include using temporary mulching, seeding, or other suitable stabilization measures to protect uncovered soils; storing materials and equipment to ensure that spills or leaks cannot enter the storm drain syste m or surface water; developing and implementing a spill prevention and cleanup plan; installing traps, filters, or other devices at drop inlets to prevent contaminants from entering storm drains; and using barriers, such as straw bales or plastic, to minimize the amount of uncontrolled runoff that could enter drains or surface water.
State
California Water Code Division 7 (Porter-Cologne Act)
The California Water Code contains provisions regulating water and its use. Division 7 establishes a program to protect water quality and beneficial uses of the state water resources including groundwater and surface water. The SWRCB and RWQCB administer the program and are responsible for control and water quality. They establish waste discharge requirements, oversee water quality control planning and monitoring, enforce discharge permits, and establish ground and surface water quality objectives.
State Water Resources Control Board
In California, the SWRCB has broad authority over water -quality control issues for the State. The SWRCB is responsible for developing statewide water quality policy and exercises the powers delegated to the State by the Federal government under the CWA. Ot her State agencies with jurisdiction over water quality regulation in California include California Department of Public Health
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(for drinking water regulations), the California Department of Pesticide Regulation, the California Department of Fish and Wildlife, and the Office of Environmental Health and Hazard Assessment.
In accordance with Section 303(d) of the CWA, the SWRCB has established a list of “impaired water bodies.” Impaired water bodies in this watershed, as listed in the SWRCB 303(d) impaired waters list, include San Marcos Creek. San Marcos Creek is listed on the 2014-2016 CWA Section 303(d) List of Impaired Water Segments as being impaired for DDE, phosphorus, sediment, toxicity, and selenium.
Batiquitos Lagoon is also listed as being impaired for eutrophic, indicator bacteria, sediment, siltation, and toxicity. San Marcos Lake was identified under Section 303(d) of the Clean Water Act as impaired due to high concentrations of nitrogen and nutrients.
Regional Water Quality Control Board
The project site is situated within the jurisdiction of the San Diego RWQCB (Region 9). The San Diego RWQCB has the authority to implement water quality protection standards through the issuance of permits for discharges to waters at locations within its jurisdiction.
The project site is located within the Richland Hydrologic Subarea (904.52) of the San Marcos Hydrologic Area (904.5) of the Carlsbad Watershed Hydrologic Unit (904). Water quality objectives for San Marcos Creek and Batiquitos Lagoon are specified in the Water Quality Control Plan for the San Diego Basin (Basin Plan) prepared by the RWQCB in compliance with the federal CWA and the Porter- Cologne Act. The Basin Plan establishes water quality objectives and implementation programs to meet stated objectives and to protect the beneficial uses of water in the lagoon and creek. Because the City of San Marcos is located within the RWQCB’s jurisdiction, all discharges to surface water or groundwater are subject to the Basin Plan requirements.
In May 2013, the San Diego RWQCB adopted Order R9-2013-0001, the new municipal NPDES permit for 39 municipal, county government, and special district entities located in southern Orange County, southwestern Riverside County, and San Diego County who own and operate large municipal separate storm sewer systems (MS4s) which discharge storm water runoff and non -storm water runoff to surface waters throughout the San Diego Region. This permit has requirements for development projects to minimize or eliminate th e impacts of such development on water quality. The proposed project is subject to the requirements of the municipal permit as it is implemented via the Carlsbad Watershed Jurisdictional Urban Runoff Management Program. The specific requirements include th e selection of appropriate BMPs to avoid, prevent, or reduce the pollutant loads entering the storm drain system and receiving waters. The permit was amended in February 2015 by Order R9-2015-0001 and in November 2015 by Order R9-2015-0100.
Provision D.1.a of Order R9-2013-0001 requires the San Diego Stormwater Co-permittees to continue water monitoring programs established within previous Orders and pursuant to the approved Hydromodification Management Plan (HMP) (January 2011). The City of San Marcos is one of the co- permittees.
To comply with Order R9-2013-0001, as amended, the updated September 2018 County of San Diego BMP Design Manual was developed to provide County -specific project design and post -construction storm water requirements for development projects and replace the prior San Diego Regional Model Standard Urban Stormwater Mitigation Plan (SUSMP). The City of San Marcos adopted its own BMP Design Manual in February 2016 and updated it in February 2023. The BMP Design Manual was used to recommend BMPs and low impact dev elopment (LID) features for the proposed project. LID is an approach to land development that uses multiple small-scale natural detention and filtration features to manage stormwater as close to its source as possible. LID employs principles such as preser ving
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and re-creating natural landscape features, minimizing effective imperviousness to create functional and appealing site drainage that treats stormwater as a resource rather than a waste product.
Local
Carlsbad Watershed Management Area Water Quality Improvement Plan The Carlsbad WMA Water Quality Improvement Plan (WQIP) is a requirement of stormwater regulations adopted by the RWQCB according to Order No. R9 -2013-0001, as amended by Order Nos. R9 2015- 0001 and R9-2015-0100. The goal of the WQIP is to protect, preserve, enhance, and restore water quality of receiving water bodies. These improvements in water quality will be accomplished through an adaptive planning and management process that identifies the highest priority water quality conditions within the watershed and implements strategies to address them. Agencies involved in the development of the WQIP include the County of San Diego and the cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista. The purpose of the Carlsbad WMA WQIP is to guide the Responsible Agencies’ Jurisdictional Runoff Management Programs (JRMP)s toward achieving improved water quality in MS4 discharges and receiving waters. Through the WQIP, priorities and goals are established, and strategies selected for i mplementation through the Responsible Agencies’ JRMPs to progress toward improvements in water quality. This approach establishes the WQIP as the overarching plan that each Responsible Agency will use to develop and implement their jurisdictional programs. Responsible Parties’ JRMPs contain the strategies, standards, and protocols by which each Responsible Agency will implement their individual program in response to the priorities and goals established in the WQIP. The WMA collective watershed strategy identifies nutrients as high priority water quality pollutants in the San Marcos Creek HA (Carlsbad Watershed Management Area 2022).
The Carlsbad WMA WQIP includes several major components:
• Priority Water Quality Conditions: after assessing available data sets, the water quality conditions in the watershed were prioritized and several were identified as those on which Responsible Agencies would focus their program efforts. These are identified as highest and priority water quality conditions. This does not mean that other water quality conditions or pollutants are to be ignored. To the contrary, many water quality conditions are related to one another in terms of the strategies selected to add ress them. Selected strategies to address priority water quality conditions are also effective at addressing many other pollutants and water quality conditions. The highest priority water quality condition for Escondido Creek and San Elijo Lagoon are indicator bacteria.
• Numeric Goals and Schedules: the WQIP establishes goals related to the highest priority water quality conditions. Furthermore, schedules for achieving these goals are included in the WQIP.
Together, the goals and schedules establish the targets that the Responsible Agencies use for both establishing their programs as well as measuring progress and achievement. Each highest priority water quality condition has established interim and final goals and schedules. • Strategies and Schedules: the WQIP identifies the strategies, or activities/BMPs, that the Responsible Agencies will implement to address the priority water quality conditions to progress towards achieving the numeric goals within the schedules identified . In addition to identifying the strategies, the WQIP identifies schedules for development (in some cases) and implementation of the strategies.
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The Carlsbad WQIP was originally submitted to the RWQCB in June 2015 and after revisions based on RWQCB comments, an acceptance letter from the Regional Board was issued on November 22, 2016.
A 2021 update has been initiated, primarily to incorporate an as sessment of bacteria data for Agua Hedionda Lagoon and revisions noted in prior Annual Reports. The 2021 WQIP was submitted to the Regional Board in January 2021 and the revised WQIP was accepted in December 2021.
City of San Marcos Jurisdictional Runoff Management Plan The Order (NPDES Permit CAS0109266) requires the City of San Marcos to develop and implement a JRMP that identifies and describes the methods that the City will use to eliminate significant pollutants from the City’s Storm Water Conveyance System. The purp ose of the City’s JRMP is to implement strategies that effectively prohibit non-stormwater discharges to the MS4 and reduce the discharge of pollutants in stormwater to the maximum extent practicable (MEP). Improving the quality of the discharge from the MS4 should have beneficial effects on the local receiving water bodies (City of San Marcos 2017).
San Marcos Storm Water Standards
The City has adopted its own BMP Design Manual (updated in February 2023) and the proposed project must comply with the standards and regulations contained therein. General requirements include the following:
• Onsite BMPs must be located so as to remove pollutants from runoff prior to its discharge to any receiving waters, and as close to the source as possible. • Structural BMPs must not be constructed within waters of the United States. • Onsite BMPs must be designed and implemented with measures to avoid the creation of nuisance or pollution associated with vectors (e.g., mosquitos, rodents, or flies).
San Marcos General Plan
Conservation and Open Space Element
The following are applicable goals and policies from the City of San Marcos General, Conservation and Open Space Element related to hydrology and water quality:
• Goal COS-6: Protect and restore appropriate surface water and groundwater beneficial uses through prioritizing the improvement of locally impaired water bodies within the City of San Marcos subwatersheds.
• Policy COS-6.2: Promote watershed stewardship as the community norm. • Goal COS-7: Achieve sustainable watershed protection for surface and ground water quality that balances social, economical, and environmental needs. • Goal COS-8: Focus watershed protection, surface and groundwater quality management on sources and practices that the City has the ability to affect. o Policy COS-8.1: Identify pollutants of concern in each subwatershed for groundwater and surface water.
o Policy COS -8.4: Require new development and redevelopment to protect the quality of water bodies and natural drainage systems through site design, source controls, storm
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water treatment, runoff reduction measures, BMPs, LID, hydromodification strategies consistent with the Current San Diego RWQCB Municipal Stormwater NPDES Permit, and all future municipal stormwater permits.
Safety Element
The following goal and policy in the City of San Marcos General Plan, Safety Element are applicable to flooding and flood control:
• Goal S-2: Minimize the risk to people, property, and the environment due to flooding hazards. o Policy S-2.2: Require existing private development to take responsibility for maintenance and repair of structures to resist flood damage.
Land Use and Community Design Element
The following goal and policies in the City of San Marcos General Plan, Land Use and Community Design Element are applicable to storm water drainage facilities:
• Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU-2.7: Promote the installation of trees to reduce the urban heat-island effect and green infrastructure to reduce storm water runoff.
• Goal LU-15: Flood control and storm water drainage facilities: ensure adequate flood control and storm water drainage is provided by the community.
o Policy LU-15.1: Implement activities, practices, procedures, or facilities that avoid, prevent, or reduce pollution of the San Marcos Storm Water Conveyance System and receiving waters.
o Policy LU-15.2: Improve inadequate or undersized drainage/flood control facilities to solve both small neighborhood and large regional drainage and flood control problems. o Policy LU-15.3: Avoid, to the extent possible, development in floodplain and flood prone areas.
o Policy LU-15.4: Retain drainage courses in their natural condition, to the extent possible.
Consider smaller -scale drainage improvements to protect the environment and avoid disturbing natural drainage courses; consider detention areas and raised building pads.
Environmental Justice Element
The following goal and policies in the City of San Marcos General Plan, Environmental Justice Element are applicable to storm water drainage facilities:
• Goal EJ -1: Reduce greenhouse gas emissions, enhance air quality, and reduce impacts associated with climate change.
o Policy EJ-.1.5: Promote the installation of trees to reduce the urban heat-island effect and green infrastructure to reduce stormwater runoff (See Policy LU-2.7). o Policy EJ-1.17: Identify pollutants of concern in each subwatershed for groundwater and surface water (See Policy COS-8.1).
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The proposed project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As detailed in Table 3. 8-12, the project is consistent with the applicable goals and policies.
City of San Marcos Ordinances
The Storm Water Management and Discharge Control Ordinance (San Marcos Municipal Code Chapter
14.15) requires that all new development and redevelopment activities comply with the stormwater pollution prevention requirements. These stormwater pollution pre vention requirements, which are described in detail in Section 14.15.050 of the Municipal Code “Reduction of Pollutants in Storm Water,” include construction, development, and redevelopment, and residential BMPs.
3.7.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts related to hydrology and water quality. In addition to the Appendix G thresholds, the City has included additional thresholds for analysis of hydrology and water quality topics. A project may be deemed to have a significant impact on hydrology/water quality if the project would:
• Threshold #1: Violate any water quality standards or waste discharge requirements or other substantially degrade surface or groundwater quality.
• Threshold #2: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: result in substantial erosion or siltation on- or off-site. • Threshold #3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. • Threshold #4: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: create or contribute to runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.
• Threshold #5: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: impede or redirect flood flows. • Threshold #6: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
• Threshold #7: Result in significant alteration of receiving water quality during or following construction.
• Threshold #8: Result in an increase in pollutant discharges to receiving waters? Consider water quality parameters such as temperature, dissolved oxygen, turbidity, and other typical storm water pollutants (e.g., heavy metals, pathogens, petroleum derivati ves, synthetic organics, sediment, nutrients, oxygen-demanding substances, and trash).
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• Threshold #9: Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pollutant for which the water body is already impaired?
• Threshold #10: Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.)? If so, can it exacerbate already existing sensitive conditions?
• Threshold #11: Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters?
As identified earlier in this section, impacts related issue area: risk release of pollutants due to project inundation in flood hazard, tsunami or seiche zones as well as impacts to groundwater recharge are not discussed in this section. Chapter 5.0, Environmental Issues Found Not to be Significant, provides additional information on this topic.
3.7.4 Project Impact Analysis
The following analysis discusses the potential for the proposed project to result in impacts to hydrology and water quality. A Hydrology Study and Priority Development Project (PDP) Storm Water Quality Management Plan were prepared for the project by Excel Engineering (2022 and 2023) and are included in Appendices I and J. As a condition of project approval, the applicant/developer/property owner shall pay Public Facility Fees, a portion of which go towards City-wide drainage improvements.
Post-Development Drainage Pattern
This proposed project is a mixed-use multifamily residential construction of 46 residential units on an
8.57 acre lot. Improvements include new storm drain pipe systems, which includes stormwater filtration and detention features, driveways, parking areas, and associated landscape areas.
The proposed grading plan would maintain the location of the existing three outfalls (POC -1, POC-2, and POC-3). The project proposes two bio-filtration basins, BMP-A in the northeast and BMP-B in the west. In general, the post development runoff would pass through an underground storage pipe and biofiltration basins prior to exiting the site. Underground storage pipe 1 would be designed to be used for peak flow detention and low flow control , meeting hydromodification requirements as well as reducing increased runoff. Surface flow generated by proposed impervious surfaces would first drain to storage pipe 1, then to BMP-A, and finally to POC-1. Storage pipe 2 would only be used for peak flow detention. Surface flow would drain to storage pipe 2 and then POC-3. All off-site water will be conveyed around the project site through brow ditches and there will be no co -mingled flows on site. (Excel 2022).
Post- Development Outfall POC-1
Both bio-filtration basins ( BMP-A on the northeast and BMP-B on the northwest) would drain to the existing outfall POC-1. The outfall of this system is tied into an existing curb inlet box. This plate has an orifice that meets the hydromodification criteria. The middle part of the project site would include proposed multifamily units, parks, and street improvements. The proposed impervious area would route surface runoff northerly through proposed storm drain storage pipe 1 then to BMP-A (northeast side of the site). After the runoff gets treated in BMP -A, it would then flow southwesterly to POC-1 (southwest corner of the site). The western part of the project site would include a proposed graded
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slope, existing slope, and the proposed driveway. This part of the project would drain surface flow southwesterly to POC-1 (Excel 2022).
Post- Development Outfall POC-2
The rest of the project, the eastern part, would route stormwater southeasterly to the existing 12- and 18- inch storm drain pipes and then to POC-2, which is located at the southeast corner of the project site.
Post- Development Outfall POC-3
At the east side of the property, the project proposes to build brow ditches to direct surface flow northerly to the proposed 36-inch storage pipe 2, then follow the existing site slope and drain to POC- 3, which is located at the north edge of the site near Woodward Street.
Biofiltration and Site BMPs
As discussed above, two biofiltration basins are proposed to mitigate the storm water quality for the project (BMP-A and BMP-B). Biofiltration facilities are vegetated surface water systems that filter water through vegetation, and soil or engineered media prior to discharge via underdrain or overflow to the downstream conveyance system. Biofiltration facilities have limited or no infiltration. They are typically designed to provide enough hydraulic head to move flows through the underdrain connection to th e storm drain system. Nutrient sensitive media will be used in the biofiltration basins to provide treatment as San Marcos Creek is a 303(d) listed water body impaired by nutrient pollutant sources.
The biofiltration basins would be constructed in conformance with the City’s BMP Design Manual which includes requirements for vector control. Per the BMP Design Manual (Pages 4 -1 and 4 -2), onsite BMPs must be designed and implemented with measures to avoi d the creation of nuisances or pollution associated with vectors (e.g., mosquitos, rodents, or flies). Projects shall comply with this requirement by incorporating design, construction, and maintenance principles to drain retained water within 96 hours and minimize standing water. Design calculations shall be provided to demonstrate the potential for standi ng water ponding at surface level and accessible to mosquitos has been addressed. For water retained in biofiltration facilities that are not accessible to mosquitoes this criteria is not applicable ( i.e., water ponding in the gravel layer, water retained in the amended soil, etc.). (City of San Marcos 2023). The BMP Design Manual further states (Page 6 -11), “This standard applies to, but is not limited to, detention basins, underground storage vaults, and the above -ground storage portion of LID facilities. When this standard cannot be met due to large, stored runoff volumes with limited maximum release rates, a vector management plan may be an acceptable solution if approved by the City of San Marcos (City of San Marcos 2023).
The biofiltration basins would be subject to regular inspection and maintenance. The property owner is required, pursuant to the City’s Municipal Code Section 14.15 and the BMP Design Manual, to enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to issuance of permits. A maintenance agreement shall be recorded with the City of San Marcos, clarifying maintenance roles and responsibilities. These comprehensive inspection and maintenance requirements will be included as conditions of approval for the proposed project.
In addition to the biofiltration features and underground storage pipes for peak flow retention, which are considered structural BMPs, the proposed project would also incorporate source control and site design BMPs as identified in the preliminary SWQMP for the proposed project (Appendix I). Source control BMPs include but are not limited to 1) preventing illicit discharges into the MS4; 2) stenciling
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the future on-site public road storm drain inlets; and 3) protecting trash storage areas from rainfall, run-on, runoff, and wind dispersal.
Site design BMPs include but are not limited to 1) maintaining natural drainage pathways and hydrologic features; 2) conserving natural areas, soils, and vegetation; 3) minimizing impervious areas; 4) minimizing soil compaction; 5) runoff collection; and 6) landscaping with native or drought tolerant species.
Threshold #1: Violate any water quality standards or waste discharge requirements or other substantially degrade surface or groundwater quality?
Pollutants generated by development projects could include sediments, nutrients, trash and debris, oxygen demanding substances, oil and grease, bacteria and viruses, and pesticides. These pollutants can make their way to drainages and watercourses where they can degrade surface water quality, and in some cases groundwater quality. The project would discharge to an un -named tributary that flows to San Marcos Creek, which discharges to Batiquitos Lagoon, which discharges to the Pacific Ocean (Excel 2022).
The proposed project would comply with all applicable water quality standards and waste discharge requirements. The proposed project includes a comprehensive water quality management approach that includes the use of underground storage pipes, brow ditches, biofiltration features and source control and site design BMPs to ensure that there would not be an increase in pollutant discharge to receiving waters. No flow- thru treatment BMPs are proposed to be implemented on site in lieu of retention or biofiltration. The stormwater management design for the project was developed following the forms and checklists found in the BMP Design Manual for Permanent Site Design, Storm Water Treatment and Hydromodification Management (City of San Marcos 2023).
The BMP Design Manual provides the guidance necessary to comply with the performance standards presented in Order R9-2013-0001 as amended (RWQCB 2015). This order indicates that discharges from MS4s must not cause or contribute to the violation of water quality standards in any receiving water (RWQCB 2015, Page 18).
Potential construction-related impacts to receiving water quality could include siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site. In accordance with NPDES regulations, the State requires that any construction activity that disturbs one acre or more must obtain a General Construction Activity Stormwater Permit.
Permit applicants are required to prepare a SWPPP and implement BMPs, incl uding erosion and sediment control and no n-stormwater management measures, to reduce construction effects on receiving water quality. Since the proposed project includes disturbance to more than one acre, a General Construction Activity Stormwater Permit from the SWRCB would be required prior to the issuance of a grading permit. A SWPPP would also be developed and implemented in accordance with the appropriate Risk Level, as determined by the City Engineer. Preparation and implementation of the SWPPP would ensure compliance with the provisions of the NPDES General Permit.
As previously noted, the proposed project has been designed to comply with the land development requirements of Order R9-2013-0001 as amended and the BMP Design Manual. These requirements were used to recommend BMPs for the proposed project to ensure there would be no impacts. Long- term water quality and HMP requirements are mitigated through appropriate design requirements for commercial, parking lot, and street land uses. The proposed project is therefore in compliance with the RWQCB MS4 permit.
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In summary, the proposed project would not violate any water quality standards or waste discharge requirements. Impacts would be less than significant.
Threshold #2: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: result in substantial erosion or siltation on- or off-site? This section analyzes the potential for the proposed project to alter existing drainage patterns in a way that results in substantial erosion or siltation on- or off-site.
Short Term (Project Construction)
The project site is currently vacant. Grading will consist of approximately 41,989 cubic yards (cy) of cut material and 50,270 cy of fill material requiring an export of approximately 8,281 cy of material.
The proposed project would incorporate construction BMPs in compliance with the General Construction Permit and SWPPP. In addition to underground storage pipes, brow ditches and the biofiltration features, which are considered structural BMPs, the proposed project would also incorporate construction BMPs which could include measures to avoid temporary erosion and sedimentation, pollutant prevention BMPs to avoid stormwater pollutants during construction and general good housekeeping of the construction site . These requirements are detailed in Appendix B (Construction BMP Manual) of the City’s JRMP. These BMPs have been designed in a manner to be consistent with the requirements of the BMP Design Manual (City of San Marcos 2023) which requires that no pollutants are discharged to the MS4s. Per the BMP Design Manual (Page 1-4) all development projects, or phases of development projects, are required to implement temporary erosion, sediment, good housekeeping, and pollution prevention BMPs to mitigate storm water pollutants during the construction phase. Short term, construction-related impacts would be less than significant.
Long Term (Project Operation)
The proposed project would increase the area of impervious surface on the project site. If not carefully planned for, increased runoff from impervious surfaces could cause alterations to drainage courses, increases in erosion and siltation . H owever, the proposed project has been designed to carefully handle runoff and to meet regulatory requirements to ensure that post-development runoff quantities and rates are similar to or less than the pre-development condition.
The drainage study for the proposed project identifies the pre - and post-development conditions for runoff rates and quantities (Excel 2023, Table 1, Q100 Analysis Results). The 100-year existing/predevelopment total flows from the project area are approxi mately 26.18 cubic feet per second (cfs). In the post development condition, the flows would increase to 29.68 cfs. However, with storage and retention, the flows would be 18.51 cfs. Runoff quantities and rates would be less than in the post-development condition due to the incorporation of biofiltration and source control and site design BMPs.
As discussed above, the post–development condition of the project site includes underground storage pipes, brow ditches and two biofiltration basins. These biofiltration features would include hydromodification and water quality treatment before discharging runoff to the storm drain system.
The storm drain system would convey discharge to an un -named tributary that flows to San Marcos Creek which discharges to Batiquitos Lagoon, and ultimately the Pacific Ocean. Additionally, the project would implement source control and site design BMPs, which could include but are not limited to 1) preventing illicit discharges into the MS4; 2) stenciling the future on-site public road storm drain inlets; and 3) protecting trash storage areas from rainfall, run -on, runoff, and wind dispersal. Site design
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BMPs include but are not limited to 1) maintaining natural drainage pathways and hydrologic features; 2) conserving natural areas, soils, and vegetation; 3) minimizing impervious areas; 4) minimizing soil compaction; 5) runoff collection; and 6) landscaping with native or drought tolerant species.
Attachment 2 C of the preliminary SWQMP (Appendix I) includes a critical course sediment yield analysis. The project boundary was compared with the areas of the County with Potential Critical Coarse Sediment Yield Areas (CCSYA). There are two areas of the project site that have the potential to provide critical coarse sediment to downstream waterbodies. Area 1 is located northwesterly of the project adjacent to the proposed driveway. This potential critical coarse sediment is located under the existing roadway (Woodward Street) and is therefore developed. This area has a 5.7% (or category 1) slope. Category slope 1 areas are not relevant for critical coarse sediment assessment. Runoff from this area flows southwesterly away from the project site and would not impact the site. Area 2 is located northeasterly and upstream of the project site. This potential critical coarse area is classified as scrub/shrub vegetation cover with greater than 40% (or category 4) slope. Runoff from this area drains toward the site . The assessment concluded that while the project site has limited areas with the potential to contribute coarse sediment, the local area in which the site is situated does not produce enough annual soil loss to be considered a source of Coarse Critical Se diment and warrants no protection or further action. This is based on evaluation of the ground cover, underlying geology, and the average slope of the local site areas (Excel 2022).
In summary, implementation of the proposed project would not increase the rate or quantities of runoff beyond the pre-development condition. The proposed project therefore meets the applicable peak flow discharge requirements (Excel 2023). The proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on - or off-site (e.g., downstream) .
Long term impacts would be
less than significant.
Threshold #3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: substantially increase the rat e or amount of surface runoff in a manner which would result in flooding on- or off-site?
As identified in response to Threshold #2, the proposed project would increase the area of impervious surface on the project site which could increase runoff flow rates or volumes. However, the proposed project has been designed to carefully handle runoff and meet regulatory requirements to ensure that post-development runoff quantities and rates are similar or less than the pre-development condition.
Specifically, post-development runoff rates would be less than in the pre- development condition due to the incorporation of structural (storage pipes, brow ditches and biofiltration basins), source control and site design BMPs (Excel 2023). Therefore, the proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Impacts would be less than significant.
Threshold #4: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: create or contribute to runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? The project proposes a comprehensive approach to stormwater and drainage management. This includes two biofiltration basins and source control and site design BMPs that would detain and retain
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stormwater flows from the project site. The treated stormwater from the biofiltration features (water quality and hydromodification) would be discharged to the storm drain system. Since the runoff will be treated for hydromodification before it enters the system, no changes to downstream flow rates or storm drain capacity are expected.
As described above, the proposed project would not generate increased runoff volumes. Additionally, project-related runoff would be adequately treated prior to discharge into planned drainage systems via storage pipes, brow ditches, biofiltration basins and other BMPs such that the proposed project would not provide substantial additional sources of polluted runoff (Excel 2023). Off-site storm drains will not be adversely affected by the proposed project as the project would mitigate all storm water flows to be less than existing conditions. The proposed project would not contribute any increase in flows to existing storm drain infrastructure. The proposed project would meet all current storm water and hydrology requirements, including hydromodification. An expansion of existing facilities would not be required to serve the proposed project.
Therefore, the proposed project would not create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. Impacts would be
less than significant.
Threshold #5: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: impede or redirect flood flows?
As identified in response to Threshold #2, the proposed project would increase the area of impervious surface on the project site which could increase runoff flow rates or volumes; however, the project has been designed to carefully handle runoff and meet regulatory requirements to ensure that post - development runoff quantities and rates are similar or les s than the pre -development condition.
Specifically, post-development runoff rates would be less than in the pre- development condition due to the incorporation of storage pipes, brow ditches, biofiltration basins, source control and site design BMPs (Excel 2023). Therefore, the proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would impede or redirect flood flows. Impacts would be less than significant.
Threshold #6: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The project site is not located within a sustainable groundwater management plan area. It is located within the Carlsbad Management Area WQIP. The goal of the WQIP is to protect, preserve, enhance, and restore water quality of receiving water bodies. These improvements in water quality will be accomplished through an adaptive planning and ma nagement process that identifies the highest priority water quality conditions within the watershed and implements strategies to address them. The purpose of the City of San Marco JRMP is to implement strategies that reduce the discharge of pollutants in stormwater to the maximum extent practicable, leading to beneficial effects on the local receiving water bodies. If a project would not result in a significant alteration of receiving water through the discharge of pollutants, it would be consistent with the WQIP and JRMP.
Short Term (Project Construction)
The proposed project would incorporate construction BMPs in compliance with the General Construction Permit and SWPPP. Potential construction -related impacts to receiving water quality
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could include siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site. In accordance with NPDES regulations, the project will be required to secure a General Construction Activit y Stormwater Permit, which will require the preparation of a SWPPP and implementation of BMPs. Examples of typical BMPs implemented in SWPPPs that could be applicable to the project include using temporary mulching, seeding, or other suitable stabilization measures to protect uncovered soils; storing materials and equipment to ensure that spills or leaks cannot enter the storm drain system or surface water; developing and implementing a spill prevention and cleanup plan; installing traps, filters, or other devices at drop inlets to prevent contaminants from entering storm drains; and using barriers, such as straw bales or plastic, to minimize the amount of uncontrolled runoff that could enter drains or surface water. These measures are designed to minimize the generation of pollutants, including sediment and trash/debris and would ensure that the proposed project would not result in significant alteration of receiving water quality during construction. Impacts would be
less than significant.
Long Term (Project Operation)
Buildout of the proposed project would increase the amount of imperviousness at the project site; however, based upon the analysis in the preliminary SWQMP prepared for the proposed project, the proposed project includes a comprehensive water quality manag ement approach that incorporates storage pipes, brow ditches, biofiltration features, and source control and site design BMPs to ensure that there would not be an increase in pollutant discharge to receiving waters. The biofiltration features and BMPs would also be subject to regular inspection and maintenance as per the preliminary SWQMP (Appendix I).
As identified above, impaired water bodies in the Carlsbad Watershed, within which the project site is located, include San Marcos Creek, Batiquitos Lagoon, and the Pacific Ocean. Potential pollutants to be generated by development projects include sediment, nutrients, trash and debris, oxygen demanding substances, oil and grease, bacteria and viruses, and pesticides.
The BMP Design Manual (Page 2 -8) requires Biofiltration BMPs be designed to have an appropriate hydraulic loading rate to maximize storm water retention and pollutant removal, as well as to prevent erosion, scour, and channeling within the BMP (City of San Marcos 2023). This requirement results in reductions in pollutants. Biofiltration has a high efficiency for removal of sediments, nutrients, trash, metals, oil/grease, organics, and oxygen demanding substances and has a medium efficiency for removal of ba cteria. No flow -thru BMPs are proposed in lieu of retention or biofiltration BMP s.
Therefore, the project’s water quality management approach would effectively treat stormwater runoff prior to discharge from the site and to receiving waters. The proposed project would not result in significant alteration of receiving water quality following construction and would be consistent with the Carlsbad Management Area WQIP and the City of San Marcos JRMP. Impacts would be less than
significant.
Threshold #7: Result in significant alteration of receiving water quality during or following construction?
As identified in response to Threshold #2, short -term, construction -related impacts resulting from siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site would be minimized through project design features and construction-related water quality BMPs identified in the project’s SWPPP. For long-term impacts, and in compliance with the BMP Design Manual, the proposed project includes a comprehensive water quality approach, including biofiltration features and source control and site design BMPs that would
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pre-treat storm water discharge from impervious areas to a medium pollutant removal efficiency or better, to ensure that there would not be an increase in pollutant discharge to receiving waters.
Therefore, the proposed project would not result in an increase in pollutant discharges to receiving waters during or following construction. Impacts would be less than significant.
Threshold #8: Result in an increase in pollutant discharges to receiving waters? Consider water quality parameters such as temperature, dissolved oxygen, turbidity, and other typical storm water pollutants (e.g., heavy metals, pathogens, petroleum derivatives, synthetic organics, sediment, nutrients, oxygen- demanding substances, and trash).
As identified above, impaired water bodies in the Carlsbad Watershed, within which the project site is located, include San Marcos Creek, Batiquitos Lagoon, and the Pacific Ocean. Potential pollutants to be generated by development projects include sediment, nutrients, trash and debris, oxygen demanding substances, oil and grease, bacteria and viruses, and pesticides.
The proposed project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. The comprehensive use of underground storage pipes, brow ditches, biofiltration features and source control and site design BMPs would effectively retain and treat stormwater runoff prior to discharge from the site and to receiving waters in compliance with the requirements of the BMP Design Manual. No flow -thru treatment BMPs are proposed to be implemented on site in lieu of retention or biofiltration. As identified above, biofiltration has a medium to high efficacy for pollutant removal. Therefore, the project would not result in an increase in pollutant discharges to receiving waters. Impacts would be less than significant.
Threshold #9: Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pollutant for which the water body is already impaired?
As identified above, impaired water bodies in the Carlsbad Watershed, within which the project site is located, include San Marcos Creek, Batiquitos Lagoon, and the Pacific Ocean. Potential pollutants to be generated by development projects include sediment, nutrients, trash and debris, oxygen demanding substances, oil and grease, bacteria and viruses, and pesticides.
The proposed project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. Nutrient sensitive media will be used in the biofiltration basin s to provide treatment. The comprehensive use of biofiltration and source control and site design BMPs would effectively treat stormwater runoff prior to discharge from the site and to receiving waters in compliance with the requirements of the BMP Design Manual. As identified above, biofiltration has a medium to high efficacy for pollutant removal. Therefore, while the project site is tributary to already impaired water bodies as listed on the CWA Section 303(d) list, the project would not result in an increase in any pollutant for which those water bodies are already impaired. Impacts would be
less than significant.
Threshold #10: Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.)? If so, can it exacerbate already existing sensitive conditions? As discussed in Section 3.3 Biological Resources, the project site is located within the Multiple Habitat Conservation Program (MHCP). However, the project site is not located within a Focused Planning area as defined in the MHCP and the draft San Marcos Subarea Plan. From a water quality and hydrology
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perspective, conditions in environmentally sensitive areas could be exacerbated by increases in erosion, increases in pollutants, and impacts related to hydrology and flooding.
Erosion – As discussed above in Threshold #2, the critical coarse sediment yield analysis concluded that while the project site has limited areas with the potential to contribute coarse sediment, the local area in which the site is situated does not produce enough annual soil loss to be considered a source of Coarse Critical Sediment and warran ts no protection or further action (Excel 2022). As identified above, with the proposed development and incorporation of storage pipes, brow ditches, biofiltration basins, and other BMPs, project site runoff would be reduced compared to existing conditions. The proposed biofiltration features and BMPs would also minimize the potential for erosion and siltation.
Thus, through a combination of reduced runoff and adequately stabilized soils as required by provisions in the NPDES General Permit, Order R9 -2013-0001 as amended and the BMP Design Manual, the proposed project would not increase erosion on or offsite and would not exacerbate already existing sensitive conditions at environmentally sensitive areas.
Pollutants/Water Quality – The proposed project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. The use of storage pipes, brow ditches, biofiltration features and source control and site design BMPs would effectively treat stormwater runoff prior to discharge from the site and to receiving waters. As identified above, biofiltration has a high efficiency for removal of sediments, nutrients, trash, metals, oil/grease, organics, and oxygen demanding substances and has a medium efficiency for removal of bacteria. The biofiltration features would be subject to regular inspection and maintenance as per the preliminary SWQMP (Appendix I). Furthermore, the property owner would also enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to issuance of permits.
Hydrology/Flooding - The proposed project has been designed such that the proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rat e or amount of surface runoff in a manner which would result in flooding on or off site. Per the FEMA Flood Insurance Rate Map Number 06073CO789H, the project site is not located within a 100-year flood hazard area (FEMA 2012).
Additionally, as identified above, the runoff would be reduced from existing conditions under post - development conditions. Therefore, the proposed project would adequately attenuate stormwater runoff during storm events and not contribute to flooding or hydrology disruptions in sensitive environments.
In conclusion, the proposed project w ould control erosion, pollutants, and flooding and would not exacerbate already existing sensitive conditions at environmentally sensitive areas. Impacts would be less than significant.
Threshold #11: Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters?
To reduce potential impacts to marine, fresh, or wetland waters downstream, the proposed project includes a comprehensive water quality management approach that includes the use of retention, biofiltration and source control and site design BMPs to effectively treat stormwater runoff prior to discharge into San Marcos Creek and Batiquitos Lagoon. Biofiltration has a high efficiency for removal of sediments, nutrients, trash, metals, oil/grease, organics, and oxygen demanding substances and a medium efficiency for removal of bacteria. The biofiltration features would be subject to regular inspection and maintenance as per the preliminary SWQMP (Appendix I). Furthermore , the property
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owner would also enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to issuance of permits.
Therefore, the proposed project would not have a potentially significant en vironmental impact on surface water quality to either marine, fresh, or wetland waters. Impacts would be less than significant.
3.7.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to hydrology/water quality, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on hydrology/water quality. All of the cumulative projects identified in Table 2 -4 are considered in this cumulative analysis.
Hydrology
Development of the proposed project, along with the related projects, could incrementally increase the cumulative total of impervious surfaces in the project area. This would potentially result in increased surface runoff, alteration of the regional draina ge pattern, and flooding. However, like the proposed project, each individual project applicant would be required per state and local requirements to hydrologically engineer the respective project sites to ensure that post-development surface runoff flows can be accommodated by the regional drainage system. Similar to the related projects, runoff volume from the project site in the post -development condition is less than in the pre -development condition due to the implementation of a comprehensive drainage plan, including the use of biofiltration facilities and BMPs. Therefore, the proposed project’s contribution to a cumulative impact from a hydrology perspective is
less than significant.
Water Quality
Development of the proposed project, in conjunction with cumulative projects that drain to the San Marcos Hydrologic Area, has the potential to increase the concentration of pollutants in surface runoff and downstream water quality. However, all related pr ojects would be subject to the same federal water quality standards and state waste discharge requirements as the proposed project. This includes preparation of project -specific SWPPPs per the NPDES permit program and implementation of associated BMPs to prevent construction-related runoff from polluting receiving waters. Additionally, similar to related projects, the proposed project has been designed to incorporate biofiltration and BMPs to limit the potential for water quality impacts to the greatest ext ent feasible. By incorporating these features into the project design, the proposed project would not substantially contribute to a significant cumulative impact to water quality. Impacts would be less than significant.
3.7.6 Mitigation Measures
Based upon the analysis presented in Section 3. 7.4 and 3. 7.5, no impacts were identified, and no mitigation measures are required.
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3.7.7 Conclusion
The proposed project would increase the amount of impervious surface at the project site; however, the project site would be hydrologically engineered such that post-development runoff would be less than in the pre -development condition. Therefore, hydrologic impacts resulting from the proposed project would be less than significant. Additionally, with incorporation of regulatory measures, such as biofiltration facilities and BMPs that would treat and eliminate the pollutants of concern prior to discharging to San Marcos Creek, as well as implementation of a project-specific SWPPP, construction and operation of the proposed project would not result in substantial adverse water quality impacts and potential impacts would be less than significant prior to mitigation.
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3.8 Land Use and Planning
Introduction
This section analyzes the potential for the proposed project to have impacts related to land use and planning. This section considers consistency with applicable land use plans and habitat conservation plans. The transportation portion of the analysis is based on the following report, which is included as Appendix J of the Environmental Impact Report (EIR)8:
• Local Transportation Analysis Woodward 46 Apartment Project, San Marcos, California. prepared by Linscott, Law and Greenspan Engineers (LLG) (February 2023).
Although not required under the California Environmental Quality Act (CEQA), the Local Transportation Analysis (LTA) focuses on automobile delay/Level of Service (LOS), consistent with the City’s Transportation Impact Analysis Guidelines (TIAG) (San Marcos 2020). The LOS analysis was conducted to identify roadway deficiencies in the project study area and to recommend project improvements to address such deficiencies. The Local Transportation Analysis is incorporated and addressed in this section as it rela tes to consistency with the City’s Mobility Element policies in the General Plan. A vehicle miles traveled (VMT) analysis, which is required under CEQA, is included as Appendix M of the EIR and summarized in Section 3.11, Transportation.
In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to have an adverse impact related to physical division of an established community. Therefore, this issue is not discussed further in this EIR section. Section 5.9, Environmental Effects Found not to be Significant - Land Use provides additional information on this topic.
Table 3.8-1 summarizes the project- and cumulative-level land use impact analysis for the proposed project.
Table 3.8-1. Land Use Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
Threshold #1: Cause a significant
environmental impact due to a
conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
3.8.1 Existing Conditions
This section describes the existing planning context for the project site, including the General Plan and Zoning designations that currently apply to the site.
8 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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Project Site
As shown in Figure 2 -1 in Chapter 2, Project Description, the 8.57 -acre project site is located in the City of San Marcos in northern San Diego County. Specifically, the project site is located on the east side of Woodward Street, generally between E. Mission Road to the south and Vineyard Road to the north in the Richland neighborhood. The project site is approximately 0.5 mile s north of State Route 78 (SR-78) and 0.1 miles north from the Civic Center SPRINTER rail station.
The project site is currently undeveloped, vacant land. The earliest -available aerial images of the property, dating to 1928, appear to show two graded areas with a dirt road connecting the two. By 1938, at least one of the roadways appears to have been abandoned. Between 1953 and 1964, another episode of disturbance is visible on the aerial imagery, with grading over a portion of the project area and possibly the widening of Woodward Street. By 1980, a four-sided feature is visible in these graded areas. B y 1987, this feature is no longer visible. Post-1987, activity in the project site appears to be sporadic and included clearing of some of the previously cut roadways. In the most - recent Google Earth images dating to 2021, a small approximately 7 by 10-feet (ft) feature is visible in the southern portion of the project area. During the cultural resources survey, it was determined that this feature was an abandoned asphalt-related machine (ASM 2024).
Existing General Plan Designation
The project site has a General Plan Designation of Specific Plan Area (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, such as 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.
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 project proposes a Specific Plan Amendment of the HOCSP to remove the Richmar Sub -Plan designation from the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan which would allow for 5.7 dwelling units per acre. The General Plan Amendment of the Land Use Element would amend land use maps and text related to changing the sub-plan designation of the project site from Richmar Specific Plan to Woodward 46 Specific Plan.
Existing Zoning Designation
The zoning on the project site is SPA and is associated with the HOCSP Area. No change in zoning is proposed as part of the project.
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Surrounding Land Uses
The project site is in a developed portion of the City. The project vicinity is primarily within the HOCSP and includes single -family residential neighborhoods to the north and east, multi -family residential developments to the south, and undeveloped land to the west across Woodward Street. Directly north of the project site is an area designated as Open Space in the City’s General Plan and north of that is single family residential. The City of San Marcos Civic Center is located south of the project site a nd contains a mix of institutional, office, and medical office uses as well as adjacent commercial land uses which offer a variety of retail space, restaurants, service uses, and shopping. The Civic Center SPRINTER rail station is located approximately 0.1 miles from the project site at the intersection of E.
Mission Road and San Marcos Boulevard.
Roadway Circulation System
The study area includes five intersections and three roadway segments based on guidance provided in the TIAG (San Marcos 2020). Per the City’s TIAG, the study area was defined using the following criteria:
• Signalized and unsignalized intersections along and adjacent to the project site; • Site access driveways; and
• Any classified (non-residential) roadway segments that are linked to the intersections that are being studied.
Figure 3.8 -1 shows existing conditions and the project study area ’s roadway segments and intersections.
Study Intersections
• #1 – Woodward Street/Project Driveway
• #2 – Mission Road/Pico Avenue (Signal)
• #3 – Mission Road/Woodward Street (San Marcos Boulevard) (Signal) • #4 – San Marcos Boulevard/Twin Oaks Valley Road (Signal) • #5 – San Marcos Boulevard/Rancheros Drive (Signal)
Study Roadway Segments
• Mission Road, from Pico Avenue to Woodward Street
• Mission Road, from Woodward Street to Mission Villas Road • San Marcos Boulevard, from Rancheros Drive to Mission Road Existing Levels of Service for Intersections and Roadway Segments Table 3.8-2 summarizes the LOS criteria for signalized intersections and Table 3.8-3 summarizes the LOS criteria for stop-controlled unsignalized intersections. Table 3.8-4 summarizes roadway segments daily capacity and LOS standards. Section 3.8.4 below provides additional information regarding the LOS analysis and methodology.
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Table 3.8-2. Signalized Intersection LOS Operational Analysis Method LOS
Average Stopped
Delay Per Vehicle
(Seconds)
Description
A
<10 Operations with very low delay. This occurs when the progression is extremely favorable and most vehicles do not stop. Short cycle lengths may also contribute to low delay.
B
>10 and <20 Operations with generally good progression and/or short cycle lengths. More vehicles stop than for LOS A, causing higher levels of average delay.
C
>20 and <35 Operations with higher delays, which may result from fair progression and/or longer cycle lengths. Individual cycle failures may begin to appear at this level. The number of vehicles stopping is significant at this level, although many still pass through the intersection without stopping.
D
>35 and <55 Operations with high delay, resulting in some combination of unfavorable progression, long cycle lengths, or high volumes.
The influence of congestion, and individual cycle features is noticeable.
E >55 and <80 The limit of acceptable delay. Individual cycle failures are frequent occurrences.
F
>80 Excessively high delays considered unacceptable to most drivers. Poor progression and long cycle lengths may also be major contributing factors to such delays.
Table 3.8-3. LOS Criteria for Stop-Controlled Unsignalized Intersections Average Stopped Delay Per Vehicle
(Seconds) LOS
<10 A
>10 and <20 B
>20 and <35 C
>35 and <55 D
>55 and <80 E
>80 F
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Table 3.8-4. Roadway Segment Daily Capacity and LOS Standards Street Classification
LOS/ADT Threshold
A B C D E
Expressway (6-lane) < 30,000 < 42,000 < 60,000 < 70,000 < 80,000 Prime Arterial (6-lane) < 25,000 < 35,000 < 50,000 < 55,000 < 60,000 Major Arterial (6-lane, divided) < 20,000 < 28,000 < 40,000 < 45,000 < 50,000 Major Arterial (4-lane, divided) < 15,000 < 21,000 < 30,000 < 35,000 < 40,000 Major Arterial (3-lane, one-way) < 12,500 < 16,500 < 22,500 < 25,000 < 27,500 Major Arterial (2-lane, one-way) < 10,000 < 13,000 < 17,500 < 20,000 < 22,500 Secondary Arterial / Collector (4-lane
w/ center lane)
< 10,000 < 14,000 < 20,000 < 15,000 < 30,000
Collector (4-lane w/o center lane) < 5,000 < 7,000 < 10,000 <13,000 < 15,000 Collector (2-lane w/ continuous left-
turn lane)
< 5,000 < 7,000 < 10,000 < 13,000 < 15,000
Collector (2-lane no fronting property) < 4,000 < 5,500 < 7,500 < 9,000 < 10,000 Collector (2-lane w/ commercial
fronting)
< 2,500 < 3,500 < 5,000 < 6,500 < 8,000
Collector (2-lane w/ multi-family) < 2,500 < 3,500 < 5,000 < 6,500 < 8,000 Collector (3-lane, one-way) < 11,000 < 14,000 < 19,000 < 22,500 < 26,000 Collector (2-lane, one-way) < 7,500 < 9,500 < 12,500 < 15,000 < 17,500 Collector (1-lane, one-way) < 2,500 < 3,500 < 5,000 < 6,500 < 7,500 Sub-Collector (2-lane single family) - - < 2,200 - -
Source: City of San Marcos Transportation Impact Guidelines (San Marcos 2020).
Traffic Counts
The study area intersections and roadway traffic counts were conducted on January 12, 2023 when area schools were in session. Traffic count worksheets are provided in Appendix A of the LTA which is included as Appendix M of this EIR.
Intersections
Table 3.8-5 and Figure 3.8-2 display intersection LOS and average vehicle delay results for the key study area intersections under existing conditions. As shown in Table 3.8-5, all intersections currently operate at LOS D or better during both the AM and PM peak hours with the exception of:
• Mission Road/Woodward Street (San Marcos Boulevard) – LOS E (AM and PM Peak Hour)
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Table 3.8-5. Peak Hour Intersection LOS – Existing Conditions # Intersection Control
Type Peak Hour
Existing
Avg. Delay
(seconds)
LOS
1 Woodward Street/Project Driveway DNE(1) AM -- --
PM -- --
2 Mission Road/Pico Avenue Signal AM 30.5 C
PM 26.3 C
3 Mission Road/Woodward Street (San
Marcos Boulevard)
Signal AM 70.9 E
PM 59.7 E
4 San Marcos Boulevard/Twin Oaks Valley
Road
Signal AM 46.0 D
PM 46.1 D
5 San Marcos Boulevard/Rancheros Drive Signal AM 23.9 C PM 27.8 C
Source: LLG 2023a.
Notes: (1) DNE – Does not exist.
Roadway Segments
Table 3.8-6 shows the classification of each project area roadway and the current operating conditions for the study area roadway segment. As shown in Table 3.8-6, the study area segments are calculated to currently operate at an acceptable LOS.
Table 3.8-6. Roadway Segment LOS Results – Existing Conditions Roadway Segment Classification Daily
Volume
LOS
Threshold
(LOS E)
V/C(1) LOS(2)
Mission Road
Pico Avenue to
Woodward
Street
4-Lane Major Arterial
with Class II Bike
Lanes
11,590 40,000 0.290 A
Woodward
Street to
Mission Villas
Road
6-Lane Prime Arterial
with Enhanced Class II
Bike Lanes
19,810 60,000 0.330 A
San Marcos
Boulevard
Rancheros
Drive to
Mission Road
4-Lane Major Arterial
with Class II Bike
Lanes
14,860 40,000 0.372 A
Source: LLG 2023a.
Notes: (1) VC = Volume/Capacity
(2) LOS = Level of Service
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3.8.2 Regulatory Setting
This section provides an overview of the regulatory setting related to planning and land use that apply to the project, including state, regional, and local regulation and planning documents.
State
California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is provided in the California Planning and Zoning Law, Government Code Sections 65000 et seq. Under state planning law, each city and county is required to adopt a General Plan “for the physical development of the county or city, and any land outside its boundaries which bears relation to its planning” (Section 65300). The California Supreme Court has called the General Plan the “constitution for futur e development.” The General Plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private. A General Plan consists of several elements, including land use, circulation, housing, conservation, open space, noise, and safety; other elements may be included at the discretion of the jurisdiction that relate to the physical development of the county or city.
Senate Bill 743
California Senate Bill (SB) 743 mandated specific types of CEQA analysis of transportation projects effective July 1, 2020. Prior to implementation of SB 743, CEQA transportation analyses of individual projects typically determined impacts on the circulation system in terms of LOS roadway delay and/or capacity usage at specific locations, such as street intersections or roadway segments. SB 743, signed into law in September 2013, required changes to the guidelines for CEQA transportation analysis. The changes include the elimination of auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts. The purpose of SB 743 is to promote the reduction of greenhouse gas emissions, the develop ment of multimodal transportation networks, and a diversity of land uses.
Under SB 743, a project’s effect on automobile delay shall not constitute a significant environmental impact. Therefore, LOS and other similar vehicle delay or capacity metrics may no longer serve as transportation impact metrics for CEQA analysis. The California Office of Planning and Research (OPR) has updated the CEQA Guidelines and provided a final technical advisory in December 2018, which recommends VMT as the most appropriate measure of transportation impacts under CEQA. The California Natural Resour ces Agency certified and adopted the CEQA Guidelines including the Guidelines section implementing SB 743. The changes have been approved by the Office of Administrative Law and are now in effect. Section 3.11, Transportation, of this EIR analyzes potential VMT impacts related to the proposed project.
While VMT is the preferred quantitative metric for assessing potentially significant transportation impacts under CEQA, it should be noted that SB 743 does not prevent a city or county from using metrics such as LOS as part of the application of local gene ral plan policies, municipal and zoning codes, conditions of approval, or any other planning requirements through a city’s planning approval process. Cities can still ensure adequate operation of the transportation system in terms of transportation congestion measures related to vehicular delay and roadway capacity. As such, the City can continue to require congestion -related transportation analysis and mitigation projects through planning approval processes outside of CEQA.
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To comply with the requirements of SB 743, the City of San Marcos has prepared its TIAG to provide guidance on conducting transportation impact analyses in the city as follows:
• CEQA Analysis Requirements: Requirements for conducting CEQA analysis, which consists of SB 743-consistent VMT analysis as well as assessing impacts to pedestrians, bicyclists, transit, hazards, emergency access, and other impacts (See Section 3.11 Transportation). • Local Transportation Analysis Requirements: Requirements for conducting LOS analysis, site access assessments, and other local transportation analyses for non-CEQA purposes (Section
3.8 Land Use and Planning).
Regional/Local
SANDAG San Diego Forward: The Regional Plan
The Regional Comprehensive Plan (RCP), adopted in 2021 by the San Diego Association of Governments (SANDAG), provides a long -term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal ac cess to jobs, education, healthcare, and other community resources. The plan is the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies.
The Regional Plan combines the Regional Comprehensive Plan and the Regional Transportation Plan/ Sustainable Communities Strategy (RTP/SCS). By integrating land use and transportation plans, the Regional Plan is intended to achieve greenhouse gas emission reduction targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act.
The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants. The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications.
Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Di ego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.
The Regional Plan also supports other regional transportation planning and programming efforts, including overseeing which projects are funded under the Regional Transportation Improvement Program and the TransNet program. SANDAG is applying data -driven strategies, innovative technologies, and stakeholder input to create a future system that is faster, fairer, and cleaner. Part of this data-driven approach includes the implementation of five key transportation strategies referred to as the 5 Big Moves. Thes e strategies provide the framework for the Regional Plan and consider policies and programs, changes in land use and infrastructure, take advantage of the existing transportation highway and transit networks, and leverage trends in technology to optimize use of the transportation system. Together, these initiatives will create a fully integrated, world -class transportation system that offers efficient and equitable transportation choices, meets state climate targets, and supports local jurisdictions’ achievements of Climate Action Plan goals.
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In September 2022, the SANDAG Board directed staff to prepare an amendment to the 2021 Regional Plan without the regional road usage charge. The amendment to the Regional Plan was approved by the SANDAG Board in late 2023.
Multiple Habitat Conservation Program
The Multiple Habitat Conservation Program (MHCP) is a comprehensive conservation planning process that addresses the needs of multiple plant and animal species in northwestern San Diego County. The MHCP encompasses the cities of Carlsbad, Encinitas, Escond ido, Oceanside, San Marcos, Solana Beach, and Vista. Its goal is to conserve approximately 19,000 acres of habitat, of which roughly 8,800 acres (46%) are already in public ownership and contribute toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.
The City of San Marcos began preparing a draft of the City Subarea Plan of the MHCP in December 1999 and although the Subarea Plan has not yet been approved by the U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) , the plan is a component of the adopted MHCP and is currently being used as a guide for open space design and preservation within the city. The intent of the City’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as Focused Planning Areas (FPA), have been designated with parcel -level preserve goals which would contribute to achieving local and regional conservation goals while minimizing adverse effects on property rights and property values. The project site is not located within an FPA.
San Diego County Regional Airport Authority/Airport Land Use Commission The nearest public airport is the McClellan-Palomar Airport, which is located approximately five miles southwest of the project site. The McClellan -Palomar Airport Land Use Compatibility Plan (ALUCP) contains policies to promote land use compatibility betw een the McClellan-Palomar Airport and adjacent and proximate land uses, to the extent these areas are not already developed with existing uses, and to protect the public health, safety, and welfare. Using airport -related forecasts and background data appro ved by the California Department of Transportation, Division of Aeronautics, the plan reflects anticipated growth of the airport over a 20 -year horizon. The plan includes land use compatibility criteria and identifies policies applicable to the airport and surrounding land uses.
According to the McClellan-Palomar ALUCP, the project site partially lies within Review Area 2 of the airport influence area. The influence area is regulated by the Airport Land Use Commission (ALUC), which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over-flight factors through review of development proposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain. Residential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights.
City of San Marcos General Plan
The San Marcos General Plan consists of the following elements:
• Land Use and Community Design Element - Describes the desired future physical composition of the planning area in terms of location, type, and intensity of new development and open space to ensure balanced development that maximizes the long -term livability of the San Marcos community.
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• Mobility Element - Describes the mobility strategy for the City, which identifies a network of options including streets, sidewalks, trails, and transit, that connects people with the City. • Conservation and Open Space Element – Recognizes the habitat and scenic value of natural and cultural open spaces within the City and lists goals and policies that ensure long -term stewardship of these resources. This element also addresses climate change, water conservation, energy conservation, air quality, watersheds, and water quality. • Parks, Recreation and Community Health Element – Identifies the recreational amenities and community service programs offered within the City and outlines goals for increased access to parks, trails, recreational facilities, and community service programs for all community members.
• Safety Element - Establishes policies and programs to protect public health, safety, and welfare of all residents and property. This element identifies and describes plans for response to natural and human-caused safety issues, including geologic, seismic, flood, and fire hazards. • Noise Element - Identifies problematic noise sources within the City and outlines strategies to reduce overall ambient noise levels. This element also includes measures to strategically distribute land uses throughout the City.
• Housing Element - Describes the strategy for developing a variety of housing opportunities to accommodate all residents and preserve the quality of existing housing in order to promote safe, decent, and affordable housing within the 2021-2029 planning period. • Environmental Justice - Addresses priorities related to a more equitable, safe, and healthy lifestyle for all City residents.
The project’s consistency with applicable General Plan goals and policies is presented in Table 3.8- 12, at the end of this section. The City’s Land Use and Community Design Element identifies five goals and associated policies to guide well -balanced land use planning in the city. The following goals and policies from the City of San Marcos General Plan, Land Use Element pertain to land use planning:
• Goal LU -1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community. o Policy LU-1.1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices.
o Policy LU-1.3: Diversify land uses by providing mixed use land uses in strategic locations within the City that place housing adjacent to employment. o Policy LU -1.4: Maintain the natural integrity of open space preserves by ensuring development projects are sensitively integrated along the edges of preserved or protected areas.
• Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU-2.2: Encourage new development to be sited to respond to climatic conditions, such as solar orientation, wind, and shading patterns.
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o Policy LU -2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards. o Policy LU-2.5: Promote landscaping (e.g., native, drought -tolerant plants) that minimizes demands on water supply.
o Policy LU-2.7: Promote the installation of trees to reduce the urban heat island effect and green infrastructure to reduce storm water runoff.
• Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
o Policy LU-3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.
o Policy LU -3.5: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways.
o Goal LU -5: Promote community design that produces a distinctive, high -quality built environment with forms and character that create memorable places and enrich community life.
o Policy LU-5.4: Require building and site design that respects the natural topography and iconic ridgelines that serve as the visual backdrop for San Marcos. o Policy LU -5.6: Require a specific plan for strategic areas/properties that require high - quality design, orientation, and development due to their location or visibility within the community.
o Policy LU-5.7: Architecture shall be enhanced with high-end building materials, varied roof lines, and decorative details.
• Goal LU-7: Direct and sustain growth and expansion in areas of San Marcos that can support a concentration of a variety of uses and are particularly suitable for multimodal transportation and infrastructure expansion and improvements.
o Policy LU-7.2: Coordinate pedestrian, transit and infrastructure upgrades with infill and redevelopment opportunities.
The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to the land use for the proposed project are identified below. Policies associated with Goals M-2 and M-3 are analyzed in Table 3.8-12, located at the end of this section, and discussed in Section
3.11, Transportation. The following goals and policies from the City of San Marcos General Plan, Mobility Element pertain to land use and mobility planning:
• Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods. o Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map
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o Policy M -1.2: Require new development to finance and construct internal adjacent roadway circulation and City-wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian, and bicycle facilities. o Policy M-1.4: Utilize multi-modal LOS techniques to evaluate transportation facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
LOS D or better for vehicles as a prioritized mode
⸋ Generally, provides facilities that have minimum vehicle congestion during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).
o Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network. o Policy M-1.7: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor. • Goal M-2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.
o Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods, while maintaining the City’s desire to provide connectivity on the roadway network. o Policy M-2.3: Consider roundabouts, as appropriate, as an intersection control device with demonstrated air quality, traffic efficiency, and safety benefits. • Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City.
o Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance, and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate. o Policy M-3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.
o Policy M-3.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians.
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o Policy M -3.9: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian-scale lighting, way finding signage, transit shelters, and other approp riate amenities.
The General Plan includes goals and policies applicable to other areas, such as mobility, safety, noise, conservation, and environmental justice. The project’s consistency with applicable General Plan goals and policies is presented in Table 3.8-12, at the end of this section.
San Marcos Municipal Code and Zoning Ordinance, Title 20 The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.
The Zoning Ordinance is based on the official Zoning Map of the City of San Marcos. The Zoning Ordinance’s purpose is to protect and promote the public health, safety, comfort, convenience, and general welfare of the San Marcos community; to implement the policies of the General Plan; and to provide the physical, environmental, economic, and social advantages t hat result from the orderly planned use of land resources.
The zoning on the project site is SPA associated with the HOCSP Area. According to Sectio n
22.250.020 of the City’s Zoning Ordinance, this zone is intended to “provide the opportunity for a creative, comprehensive planning approach for the use and development of land through innovative building types and site design. This Zone affords flexibility to the developer in a context of City review that ensures comprehensive planning and the provision of necessary public services and facilities.
The SPA Zone is intended to implement and is consistent with the SPA land use designation of the General Plan (San Marcos 202 3).
3.8.3 Thresholds of Significance
According to Appendix G of the State CEQA Guidelines, the proposed project would have a significant impact related to land use if it would:
• Threshold #1: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect.
As identified above, impacts related to physical division of an established community are not discussed in this section. Section 5. 9, Environmental Effects Found not to be Significant – Land Use, provides additional information on this topic.
3.8.4 Project Impact Analysis
The project proposes 46 duplex residential units on 8,57 gross acres for a proposed density of 5.37 dwelling units/acre. The requested approvals for the project include:
• Specific Plan Amendment (SP22-0006) – A Specific Plan Amendment to modify the HOCSP to remove the current Richmar Sub-Plan designation on the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan. • Specific Plan (SP22 -0005) – T he Woodward 46 Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the
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Specific Plan. The Specific Plan would be required to be reviewed and approved concurrently with the Multi-Family Site Development Plan application. • General Plan Amendment (GPA22 -0004) – A General Plan Amendment to the Land Use Element for the purpose of amending land use maps and text related to changing the sub-plan designation of the subject property from Richmar Specific Plan to Woodward 46 Specific Plan. • Multi-Family Site Development Plan (MFSDP22-0005) - Site Development Plan approval would be required to construct 46 multi -family residential units and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM22-0004) - Tentative Subdivision Map would be required for formation of residential condominium units, private driveways, and open space areas. • Conditional Use Permit (CUP22-0005) - Conditional Use Permit would be required for potential use of a temporary rock crusher.
Threshold #1: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect.
Plans and policies considered in this analysis include the San Marcos General Plan, the City of San Marcos zoning ordinance and the MHCP.
San Marcos General Plan
The project site has a General Plan Designation of Specific Plan Area (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, such as 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.
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 project proposes a Specific Plan Amendment of the HOCSP to remove the Richmar Sub -Plan designation from the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan which would allow for 5.7 dwelling units per acre. The General Plan Amendment of the Land Use Element would amend land use maps and text related to changing the sub-plan designation of the project site from Richmar Specific Plan to Woodward 46 Specific Plan.
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Table 3.8-12 at the end of this section summarizes the applicable San Marcos General Plan goals and policies relating to land use. As shown in Table 3.8 -12, the project would be consistent with the applicable goals and policies.
Mobility Element Consistency – Level of Service Analysis The following analysis focuses on automobile delay/LOS, consistent with the City’s TIAG. The LOS analysis was conducted to identify roadway deficiencies in the project study area and to recommend project improvements to address such deficiencies. The LTA is incorporated and addressed in this section as it relates to consistency with the City’s Mobility Element policies. A VMT analysis, which is required under CEQA, is included as Appendix M of the EIR and summarized in Section 3.11, Transportation.
Analysis Methodology - Intersections
The AM intersection analysis evaluates LOS during the hour with the highest vehicular traffic between 7:00 AM and 9:00 AM. The PM intersection analysis evaluates LOS during the hour with the highest vehicular traffic between 4:00 PM and 6:00 PM. Tables 3.8 -2 and 3.8-3 summarize the LOS criteria for signalized intersections and unsignalized stop-controlled intersections.
The analysis of signalized intersections utilized the operational analysis procedure as outlined in the Highway Capacity Manual (HCM) 6th Edition signalized (Chapter 19) intersection analysis methodology. This method defines LOS in terms of delay, or more specifically, average stopped delay per vehicle. Delay is a measure of driver and/or passenger discomfort, frustration, fuel consumption and lost travel time. This technique uses 1,900 vehicles per hour per lane as the maximum saturation volume of an inter section. This saturation volume is adjusted to account for lane width, on ‐street parking, pedestrians, traffic composition (i.e., percentage trucks) and shared lane movements (i.e., through and right ‐turn movements originating from the same lane). The LOS criteria used for the analysis of signalized intersections are described in Table 3.8 -2, identifying the thresholds of control delays and the associated LOS. The computerized analysis of intersection operations was performed utilizing the Synchro Version 11 traffic analysis software by Trafficware Ltd.
Unsignalized intersections were analyzed using the Highway Capacity 6th Edition side -street stop (Chapter 20) and all -way stop (Chapter 21) intersection analysis methodology. The computerized analysis of intersection operations was performed utilizing the Synchro Version 11 traffic analysis software by Trafficware Ltd.
LOS was determined as follows:
• All-way stop intersections: Reported for the entire intersection as an average value. • Side-street stop intersections: Reported for the worst-case movement.
The LOS criteria used for the analysis of unsignalized intersections are described in Table 3.8-3.
Analysis Methodology – Roadway Segments
Roadway segment LOS standards and thresholds provide the basis for analysis of arterial roadway segment performance. The analysis of roadway segment LOS is based on the functional classification of the roadway, the maximum capacity, roadway geometrics, and existing or forecast Average Daily Traffic (ADT) volumes. Table 3.8 -4 presents the roadway segment capacity standards found in the City’s TIAG. The actual capacity of a roadway facility varies according to its physical attributes.
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City of San Marcos Page 3.8-16
Level of Service Standards
The City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards outlined in the General Plan Mobility Element. If the addition of the traffic generated from a proposed project results in any one of the followin g, improvements should be identified to increase performance to acceptable or pre-project conditions under each scenario:
• Triggers an intersection operating at acceptable LOS to operate at unacceptable LOS (LOS E or F) and increases the delay by more than 2.0 seconds. • Increases the delay for a study intersection that is already operating at unacceptable LOS (LOS E or F) by more than 2.0 seconds.
• Triggers a roadway segment operating at acceptable LOS (LOS A, B, C, D) to operate at unacceptable LOS and increases the volume/capacity (V/C) ratio by more than 0.02. • Increases the V/C ratio for a study roadway segment that is already operating at unacceptable LOS (LOS E or F) by more than 0.02.
Project Trip Generation
To determine the traffic generation of the proposed project, the April 2002 SANDAG (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002) r ates were applied to the proposed project. The “Condominium” trip rate was used to estimate the project residential trip generation.
Table 3.8 -7 presents the trip generation rates and forecasted project -generated trips for weekday conditions. As shown in Table 3.8-7, the project would generate approximately 368 average daily trips (ADT), including 29 AM peak hour trips and 37 PM peak hour trips. The project traffic was distributed based on the site location, access to SR-78, existing traffic patterns in the area and anticipated traffic routes to and from the site. The proposed project’s regional distributions assumes 75% of trips oriented to/from the south, and local distributions assumes 10% oriented to/from the west, 10% to/from the east and 5% to/from the north.
Table 3.8-7. Project Trip Generation
Land Use Quantity
Daily Trip
Ends (ADT)
AM Peak Hour PM Peak Hour
% of
ADT
In:Out
Split
Volume % of
ADT
In:Out
Split
Volume
Rate ADT In Out Total In Out Total
Condominium 46 DU 8/DU 368 8% 20:80 6 23 29 10% 70:30 26 11 37 Source: LLG2023a.
Note: Trip generation rates were obtained from the (Not so) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002 by SANDAG
DU = Dwelling Unit, ADT = Average Daily Traffic
Construction Trip Generation
Grading of the project site would consist of approximately 41,989 cubic yards (CY) of cut material and 50,270 CY of fill material requiring an export of approximately 8,281 CY of material . If suitable, the excess material would be used as wall backfill and the site would balance. If it is not suitable, it would
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City of San Marcos Page 3.8-17
be exported from the site. To be conservative, the environmental analysis assumes the materials would be exported. Assuming 15 cy truck trips, that would equate to 553 trips. These trips would be spread over approximately 23 working days for 24 trips per day associated with export. The grading phase of the project is not expected to generate trips above the trips associated with the 46-unit duplex residential development. Therefore, the grading phase would not result in any traffic related significant impacts or substantial effects above those associated with the project. No traffic related impacts are identified during construction.
Local Transportation Analysis of Near-Term (Year 2026) Conditions The following section presents the analysis of study area intersections and street segments under Near-Term Year 2026 Base conditions and Near-Term Year 2026 Base + Project conditions.
Near-Term Year 2026 Intersection Analysis
Table 3.8-8 summarizes the intersection operations through the study area for the Near -Term Year 2026 Base Condition and Base + Project conditions.
Table 3.8-8. Near-Term Year 2026 - Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour
Year 2026
Base
Conditions
Year 2026
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.
Delay
(sec.)(1)
LOS(2)
Avg.
Delay
(sec.)(1)
LOS(2)
1 Woodward
Street/Project
Driveway(6)
TWSC(5) AM -- -- 11.5 B -- Yes
PM -- -- 12.8 B -- Yes
2 Mission Road/Pico
Avenue
Signal AM 36.4 D 36.6 D 0.2 Yes
PM 29.7 C 29.9 C 0.2 Yes
3 Mission
Road/Woodward
Street (San Marcos
Boulevard)
Signal AM 81.9 F 82.0 F 0.1 Yes
PM 71.3 E 71.4 E 0.1 Yes
4 San Marcos
Boulevard/Twin Oaks
Valley Road
Signal AM 51.9 D 53.5 D 1.6 Yes
PM 48.2 D 48.5 D 0.3 Yes
5 San Marcos
Boulevard/Rancheros
Drive
Signal AM 29.4 C 29.6 C 0.2 Yes
PM 32.0 C 32.1 C 0.1 Yes
Source: LLG 2023a.
Notes: (1) Average Delay expressed in seconds per vehicle (2) LOS = Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) TWSC = Two-way stop controlled intersection.
(6) Intersection does not exist under Year 2026 Base condition
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As shown in Table 3.8-8, in the Near-Term Year 2026 Base condition, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of:
• Mission Road/Woodward (San Marcos Boulevard) – LOS F (AM Peak Hour) and LOS E (PM Peak Hour)
With the addition of project traffic (Base + Project condition) all intersections would continue to operate acceptably at LOS D with the exception of the Mission Road/Woodward (San Marcos Boulevard) intersection. The project’s increase in delay at that int ersection would be 0.1 seconds, which is less than the 2 seconds average delay. As part of the project design features (see Table 2-2) the applicant would construct an access point that provides adequate driveway sight distance and 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.
Therefore, none of the study intersections would degrade to an unacceptable level with implementation of the proposed project and no improvements would be required.
Near-Term (Year 2026) Segment Analysis
Table 3.8-9 summarizes the segment operations throughout the study area for the Near-Term Year 2026 Base and Near-Term Year 2026 Base + Project conditions. As shown in Table 3.8-9 , all of the study area segments are calculated to operate acceptably at LOS B or better with or without the project.
Table 3.8-9. Near-Term Year 2026 Roadway Segment Operations Without and With Project Roadway Segment
Capacity
(LOS
E)(1)
Year 2026 Base
Condition
Year 2065
Base + Project
Condition Δ(4)
Consistent
with City
LOS
Standards?
(5)
Daily
Volume V/C(2) LOS(3) Daily
Volume V/C(2) LOS(3)
Mission
Road
Pico
Avenue to
Woodward
Street
40,000 11,910 0.298 A 11,947 0.299 A 0.001 Yes
Woodward
Street to
Mission
Villas
Road
60,000 20,690 0.345 A 20,727 0.345 A 0.000 Yes
San
Marcos
Boulevard
Rancheros
Drive to
Mission
Road
40,000 15,980 0.400 B 16,256 0.406 B 0.006 Yes
Source: LLG 2023a.
Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Volume to Capacity
(3) LOS = Level of Service
(4) Δ denotes a project-induced increase in the Volume to Capacity (V/C) ratio. (5) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element.
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Local Transportation Analysis of Horizon Year 2050 Conditions Year 2050 Network Conditions
The Long-Term (Horizon Year 2050) street network in the SANDAG Series 14 forecast model includes the roadways built to their City Mobility Element Classification, including the planned widening of San Marcos Boulevard between Twin Oaks Valley Road and Miss ion Road to 6 -lane Major Arterial standards. For the purposes of the LTA, the network addition is assumed in the long -term traffic volumes forecast but no changes to the study area roadway geometry or intersection control were assumed.
Horizon Year 2050 Intersection Analysis
Table 3.8-10 summarizes the Year 2050 Without and With Project peak hour intersection analysis. As shown in Table 3.8–10, without the project, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of the following intersections:
• Mission Road/Woodward Street (San Marcos Boulevard) – LOS F (AM and PM Peak Hour) • San Marcos Boulevard/Twin Oaks Valley Road - LOS E (AM and PM Peak Hour) With the addition of project traffic all of the study area intersections would continue to operate at LOS D or better with the exception of Mission Road/Woodward Street (San Marcos Boulevard) which would continue to operate at LOS F in the AM and PM Peak hour and San Marcos Boulevard/Twin Oaks Valley Road, which would continue to operate at LOS E in the AM and PM Peak Hour. As shown in Table 3.8- 10, the project’s increase in delay at these intersection would range from 0.1 seconds to 1.1 seconds which is less than the 2 seconds average delay. Therefore, none of the study intersections analyzed in the Horizon Year 2050 scenario would degrade to an unacceptable level with implementation of the proposed project and no improvements would be required.
Table 3.8-10. Horizon Year (2050) Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour
Year 2050
Base
Conditions
Year 2050
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.
Delay
(sec.)(1)
LOS(2)
Avg.
Delay
(sec.)(1)
LOS(2)
1 Woodward
Street/Project
Driveway
TWSC(5) AM -- -- 11.7 B -- Yes
PM -- -- 13.1 B -- Yes
2 Mission Road/Pico
Avenue
Signal AM 49.3 D 49.4 D 0.1 Yes
PM 35.3 D 35.5 D 0.2 Yes
3 Mission
Road/Woodward
Street (San Marcos
Boulevard)
Signal AM 101.3 F 101.5 F 0.2 Yes
PM 96.3 F 96.4 F 0.1 Yes
4 Signal AM 71.4 E 72.5 E 1.1 Yes
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City of San Marcos Page 3.8-20
# Intersection Control
Type
Peak
Hour
Year 2050
Base
Conditions
Year 2050
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.
Delay
(sec.)(1)
LOS(2)
Avg.
Delay
(sec.)(1)
LOS(2)
San Marcos
Boulevard/Twin Oaks
Valley Road
PM 58.2 E 58.5 E 0.6 Yes
5 San Marcos
Boulevard/Rancheros
Drive
Signal AM 36.6 D 37.1 D 0.5 Yes
PM 39.0 D 39.4 D 0.4 Yes
Source: LLG 2023a.
Notes: (1) Average Delay expressed in seconds per vehicle (2) LOS = Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) TWSC = Two-way stop controlled intersection.
Horizon Year 2050 Segment Operations
Table 3.8 -11 summarizes the segment operations throughout the study area for the Year 2050 Without and With Project daily street segment operations. As shown in Table 3.8 -11, all of the study area segments are calculated to operate acceptably at LOS B both with and without the project.
Table 3.8-11. Horizon Year 2050 Roadway Segment Operations Without and With Project Roadway Segment
Capacity
(LOS
E)(1)
Year 2026 Base
Condition
Year 2065
Base + Project
Condition Δ(4)
Consistent
with City
LOS
Standards?
(5)
Daily
Volume V/C(2) LOS(3) Daily
Volume V/C(2) LOS(3)
Mission
Road
Pico
Avenue to
Woodward
Street
40,000 12,310 0.308 A 12,347 0.309 A 0.001 Yes
Woodward
Street to
Mission
Villas
Road
60,000 21,790 0.363 A 21,287 0.346 A 0.000 Yes
San
Marcos
Boulevard
Rancheros
Drive to
Mission
Road
40,000 17,380 0.435 B 17,656 0.441 B 0.006 Yes
Source: LLG 2023a.
Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Volume to Capacity
(3) LOS = Level of Service
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(4) Δ denotes a project-induced increase in the Volume to Capacity (V/C) ratio. (5) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element.
Community Facility District (Congestion Management) Participation As a condition of project approval, the applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD2011-01 (Congestion Management).
Public Facility Fees
As a condition of project approval, the applicant/developer/property owner shall pay Public Facility Fees, a portion of which go towards improvements to circulation streets and State Route 78 interchanges.
Consistency with City of San Marcos Zoning Ordinance
The Zoning on the project site is SPA and is associated with the HOCSP Area. No change in zoning is proposed as part of the project. The project would establish its own development criteria under the proposed Woodward 46 Specific Plan.
Multiple Habitat Conservation Program
The project’s consistency with the MHCP is analyzed in Section 3.3, Biological Resources, of this EIR.
The analysis concludes that while the project is located within the MHCP, it is not located within a Focused Planning Area as defined in the MHCP and Draft San Marcos Subarea Plan. The project would impact Diegan coastal sage scrub and disturbed Diegan coastal sage scrub The project would mitigate these impacts consistent with the mitigation ratios identified in the MHCP and Draft San Marcos Subarea Plan, as detailed in Section 3.3.5 of the EIR. The project does not result in any inconsistencies with the MHCP and Draft San Marcos Subarea Plan.
3.8.5 Cumulative Impact Analysis
As described in Section 3.8.4 of the EIR, while the project seeks approval of a General Plan Amendment, the proposed project would be consistent with the overarching goals and policies of the City’s General Plan (see Table 3.8-1 2). In addition to the City’s General Plan, the proposed project would also be consistent with the City’s Municipal Code, San Diego Association of Governments 2050 Regional Transportation Plan/Sustainable Communities Strategy, and applicable plans and polic es.
Furthermore, as analyzed throughout Chapter 3, implementation of the proposed project would not result in any significant unavoidable impacts that could further impact land use.
All cumulative projects would be subject to similar criteria as the proposed project, which would ensure compliance with existing applicable land use plans with jurisdiction over the project area. Any cumulative projects that propose amendments to the Gene ral Plan or Zoning Ordinance would be required to show that proposed uses would not result in significant environmental impacts due to a conflict with applicable policies in a similar way as the proposed project. Since all current and future projects would be analyzed for compatibility and compliance with land use regulations prior to approval, cumulative impacts related to land use and planning are determined to be less than significant.
3.8 Land Use and Planning
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City of San Marcos Page 3.8-22
Regarding the LOS analysis for compliance with the City’s Mobility Element, the preceding analysis of the proposed project in Section 3.8.4 is based on methodologies that incorporate the cumulative effects of traffic from general growth and anticipated dev elopment in the area. This reflects background traffic and traffic from area-wide growth already approved by the City of San Marcos plus the development of the proposed project. As discussed in Section 3.8.4, the project would not result
in any required ro adway or intersection improvements due to degraded LOS in the Near Term 2026 nor Horizon Year 2050 time frames. Therefore, the project would not result in any inconsistencies with the goals and policies of the Mobility Element relating to LOS. Cumulative impacts would be less than
significant.
3.8.6 Mitigation Measures
No land use impacts were identified; therefore, no mitigation measures are required.
3.8.7 Conclusion
The project site has a General Plan and zoning designation of SPA and is associated with the HOCSP.
In the HOCSP, certain properties along the Mission Road corridor, such as the project site, have a sub- plan designation of Richmar Specific Plan. 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. As detailed in Table 3.8-12, the proposed project would be consistent with the app licable goals and policies of the City’s General Plan. The project would also be consistent with the MHCP. Based upon the analysis presented in Sections 3.8.3 and 3.8.4, including Table 3.8-12, implementation of the proposed project would not conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect. The analysis also included a detailed analysis to determine the proposed project’s consistency with the Mobility Element policies that add ress LOS. The proposed project would not result in any decreases in LOS to the studies roadways or intersection in the Near Term 2026 and Horizon year 2050 timeframe. Impacts would be less than significant.
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-23
Figure 3.8-1. Existing Roadway Conditions
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City of San Marcos Page 3.8-24
Figure 3.8-2. Existing Traffic Volumes
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Table 3.8-12. Project Consistency with Applicable San Marcos General Plan Goals and Policies General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Land Use and Community Design Element
Goal LU-1 Achieve a balanced distribution and compatible mix of land uses to meet the present and
future needs of all residents and the business
community.
The project would construct 46 duplex residential units. These units would add to the housing stock within the city and the greater North County area of San Diego and would meet the demand for future housing in the city, as contemplated by the City’s General Plan. The project is consistent with this goal.
Goal LU-1,
Policy LU-1.1/
Goal EJ-1,
Policy EJ-1.1
Ensure that adjacent land uses complement
one another by considering compatibility of
activities, development patterns and
architectural character elements, and access
to various mobility choices.
The project area is developed with a mix of residential uses with commercial and civic uses in the greater project vicinity. The project site is near North County Transit District (NCTD) bus stops on E. Mission Road and the San Marcos Civic Center SPRINTER station. The Specific Plan identifies design concepts to minimize the bulk and scale of the project. This includes: using building-form elements such as place breaks, roof forms, and changes in materials to define individual units; articulating the front and rear elevations both vertically and horizontally; and avoiding long unbroken surfaces on front and rear elevations by providing a change in plane at least every 25 feet. The proposed architectural style takes inspiration from contemporary/modern style architecture. Elements and materials traditionally used for this style include angular pitched roofs using concrete roof tiles, simple forms with stucco or stone veneer walls, metal railings, and awnings. The project is consistent with this policy.
Goal LU-1,
Policy LU-1.4
Maintain the natural integrity of open space
preserves by ensuring development projects
are sensitively integrated along the edges of
preserved or protected areas.
The project site is an undeveloped lot in a developed portion of the City. The project has been designed to suit the topography of the site. Development is focused within a portion of the project site that is away from the existing open space area to the north and allows for the retention of larger areas of habitat. The project is consistent with this policy.
Goal LU-2 Promote development standards and land use
patterns that encourage long-term
environmental sustainability.
The project site is in a developed portion of the City and has been designed in a sustainable manner. The site has been identified for commercial, office and multi- family residential development in applicable planning documents and the project would construct multi-family residential uses. The project site is near NCTD bus stops and a SPRINTER station. The project incorporates green features and has been designed to meet current California Building Code requirements as related to green building practices. Based upon the analysis in this EIR, the project would reduce all significant impacts to below a level of significance through the incorporation of mitigation measures. The project is consistent with this goal.
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City of San Marcos Page 3.8-26
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-2,
Policy LU-2.1/
Goal EJ-1,
Policy EJ-1.3
Promote compact development patterns that
reduce air pollution and automobile
dependence and facilitate walking, bicycling,
and transit use.
The project would connect to existing pedestrian and bicycle infrastructure on Woodward Street. The project site is near NCTD bus stops on E. Mission Road and the San Marcos Civic Center SPRINTER station. The project is consistent with this policy.
Goal LU-2,
Policy LU-2.2
Encourage new development to be sited to
respond to climatic conditions, such as solar
orientation, wind, and shading patterns.
The project would comply with the latest applicable Title 24 standards. The buildings have been sited to accommodate solar and the installation of rooftop solar is part of the project design. The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. The project is consistent with this policy.
Goal LU-2,
Policy LU 2.3
Require the incorporation of green building
practices, technologies, and strategies into
development projects per code standards.
The project incorporates green features and has been designed to meet current California Building Code requirements as related to green building practices. The 2022 Energy Code encourages efficient electric heat pumps, establishes electric- ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Examples of the project’s green features includes: installation of rooftop solar, compliance with the City’s Water Efficiency Landscaping Ordinance (WELO,) use of low-water/native species in the landscape plan, garages will be wired for EV chargers, and providing pedestrian connections to Woodward Street, The project is consistent with this policy.
Goal LU-2,
Policy LU-2.5
Promote landscaping (e.g., native, drought-
tolerant plants) that minimizes demands on
water supply.
The proposed landscape plan focuses on native, drought tolerant species including a mix of trees, shrubs, and groundcover and the plant selection emphasizes low and moderate water use species. Proposed tree species include: evergreen elm, Marina strawberry tree, Chitalpa pink dawn, Australian willow, Tuscarora crape myrtle, Chinese pistache, African suman, eastern redbud, bronze loquat, sweetshade, shrubby yew podocarpus, Torrey pine, coast live oak, southern live oak, Brisbane box, and little gem magnolia. The proposed project would also comply with the City’s WELO and Title 20 of the Municipal Code which minimizes the use of water for irrigation. The landscape concept plan is included as Figure 2-4 and the complete landscape plan and planting palette is included in Appendix A.4.
Goal LU-2,
Policy LU-2.7/
Goal EJ-1,
Policy EJ-1.5
Promote the installation of trees to reduce the
urban heat island effect and green
infrastructure to reduce storm water runoff.
The proposed landscape plan includes a mix of trees, shrubs, and groundcover and the plant selection emphasizes low and moderate water use species. Proposed tree species include: evergreen elm, Marina strawberry tree, Chitalpa pink dawn, Australian willow, Tuscarora crape myrtle, Chinese pistache, African suman, eastern
3.8 Land Use and Planning
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City of San Marcos Page 3.8-27
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy redbud, bronze loquat, sweetshade, shrubby yew podocarpus, Torrey pine, coast live oak, southern live oak, Brisbane box, and little gem magnolia. The proposed project would also comply with the City’s WELO and Municipal Code, Title 20. The landscape concept plan is included as Figure 2-4. As discussed in greater detail in Section 3.7 (Hydrology/Water Quality) the project incorporates biofiltration features and source control and site design best management practices (BMPs) to reduce storm water runoff. The project is consistent with this policy.
Goal LU-3 Develop land use patterns that are compatible with and support a variety of mobility
opportunities and choices.
The project’s internal pedestrian circulation network would connect to the existing sidewalk and bicycle lanes along the project frontage on Woodward Street which would provide connection to the existing NCTD bus stop on E. Mission Road near the project site and the San Marcos Civic Cener SPINTER stop 0.1 miles from the project.
The project is consistent with this goal.
Goal LU-3,
Policy LU-3.1
Require that new development and
redevelopment incorporate connections and
reduce barriers between neighborhoods,
transit corridors, and activity centers within the
City.
The project’s internal pedestrian circulation network would connect to the existing sidewalk along the project frontage on Woodward Street which would provide connection to the existing NCTD bus stop on E. Mission Road near the project site and the San Marcos Civic Cener SPINTER stop 0.1 miles from the project. The project is consistent with this policy.
Goal LU-3,
Policy LU-3.4/
Goal EJ-5,
Policy EJ-5.1
Provide non-motorized (pedestrian and bicycle)
access/circulation within, and to, mixed-use
centers to reduce reliance on the automobile.
The project includes internal walkways that would connect to the sidewalk on Woodward Street. The project is consistent with the policy.
Goal LU-3,
Policy LU-3.5/
Goal EJ-5,
Policy EJ-5.2
Provide an interconnected open space system
that is accessible to the public, including
pedestrian and equestrian links, bicycle paths,
multi-use trails, recreation areas, and drainage-
ways.
The project incorporates 6.01 acres of common open space. The project incorporates pedestrian walkways which would connect to the City’s larger pedestrian and bicycle network. The sidewalk along the project frontage on Woodward Street is identified as an Urban Trail in the City’s Trails Master Plan. The project is consistent with this policy.
Goal LU-5 Promote community design that produces a
distinctive, high-quality built environment with
forms and character that create memorable
places and enrich community life.
The project has been designed to incorporate architectural treatments, including varied rooflines to enhance the appearance of the project. The Specific Plan identifies design concepts to minimize the bulk and scale of the project. This includes: using building-form elements such as place breaks, roof forms, and changes in materials to define individual units; articulating the front and rear elevations both vertically and horizontally; and avoiding long unbroken surfaces on front and rear elevations by providing a change in plane at least every 25 feet. The
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy conceptual landscape plan provides for a mix of trees, shrubs, and groundcover to further enhance the look and feel of the project. The project is consistent with this goal.
Goal LU-5,
Policy LU-5.4
Require building and site design that respects
the natural topography and iconic ridgelines
that serve as the visual backdrop for San
Marcos.
The project site is sloped and the project has been designed to minimize the amount of grading that would be required. No primary or secondary ridgelines are located within or adjacent to the project site. The nearest primary ridgeline is within the North City Area #1 map and includes Owens Peak and “P” Mountain. This primary ridgeline is located approximately 1.25 miles northwest of the project site. The project is consistent with this policy.
Goal LU-5,
Policy LU-5.7
Architecture shall be enhanced with high-end
building materials, varied roof lines, and
decorative details.
The project has been designed to incorporate architectural treatments, including varied rooflines to enhance the appearance of the project. The Specific Plan identifies design concepts to minimize the bulk and scale of the project. This includes: using building-form elements such as place breaks, roof forms, and changes in materials to define individual units; articulating the front and rear elevations both vertically and horizontally; and avoiding long unbroken surfaces on front and rear elevations by providing a change in plane at least every 25 feet. The conceptual landscape plan provides for a mix of trees, shrubs, and groundcover to further enhance the look and feel of the project. The project is consistent with this goal.
Goal LU-7 Direct and sustain growth and expansion in
areas of San Marcos that can support a
concentration of a variety of uses and are
particularly suitable for multimodal
transportation and infrastructure expansion
and improvements.
The project site is within the City of San Marcos, surrounded by existing residential development to the north, east and south. Existing services and utilities are present in proximity to the project. The project is in proximity to transit and would provide sidewalks to encourage non-motorized transportation. The project is consistent with this goal.
Goal LU-7,
Policy LU-7-2/
Goal EJ-5,
Policy EJ-5.3
Coordinate pedestrian, transit and
infrastructure upgrades with infill and
redevelopment opportunities.
The project is in proximity to transit and would connect to the existing sidewalk along the project frontage with Woodward Street. The project is consistent with this goal.
Goal LU-8 Ensure that existing and future development is adequately serviced by infrastructure and
public services.
As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for fire and police protection services would be offset with payment of appropriate development fees, including payment of Public Facility Fees (PFF) and annexation
3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-29
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy into and participation in applicable Community Facilities Districts (CFD). Impacts to parks would be offset through provision of on-site recreational facilities and payment of PFF. Additionally, as analyzed in Section 3.13 (Utilities and Service Systems) water and sewer services are available to serve the project. The project would connect to the existing water line in Woodward Street and would also extend the existing sewer line in Woodward Street to the project entrance. The project would also pay applicable Water and Wastewater Capital Facility Fees to Vallecitos Water District (VWD) per Ordinances Nos. 175 and 176 or a combination of upgrades and fees at an equitable level. The project is consistent with this goal.
Goal LU-8,
Policy LU-8.1
New development shall pay its fair share of
required improvements to public facilities and
services.
As described further in Section 3.10 (Public Services), the project’s demand for fire and police protection services would be offset with payment of appropriate CFD and PFF fees. The project is also required to pay appropriate statutory fees for schools, which would ensure impacts to schools are less than significant. Impacts to parks would also be offset through payment of the City's PFF. Additionally, as analyzed in Section 3.13 (Utilities and Service Systems) water and sewer services are available to serve the project. The project would connect to the existing water line in Woodward Street and would also extend the existing sewer line in Woodward Street to the project entrance. The project would also pay applicable Water and Wastewater Capital Facility Fees to VWD per Ordinances Nos. 175 and 176 or a combination of upgrades and fees at an equitable level. The project is consistent with this policy.
Goal LU-8,
Policy LU-8.2
Promote development timing that is guided by
the adequacy of existing and/or expandable
infrastructure, services, and facilities.
As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for fire and police protection services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. Impacts to parks would be offset through provision of on-site recreational facilities and payment of PFF. Additionally, as analyzed in Section 3.13 (Utilities and Service Systems) water and sewer services are available to serve the project. The project would connect to the existing water line in Woodward Street and would also extend the existing sewer line in Woodward Street to the project entrance.
The project would also pay applicable Water and Wastewater Capital Facility Fees to VWD per Ordinances Nos. 175 and 176 or a combination of upgrades and fees at an equitable level. The project is consistent with this policy.
3.8 Land Use and Planning
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City of San Marcos Page 3.8-30
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-10 Fire protection, emergency services, and law enforcement: Provide effective, high-quality,
and responsive services.
As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for fire services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. The project is consistent with this goal.
Goal LU-10,
Policy LU-10.1
Provide demand-based firefighting and
emergency medical services infrastructure,
equipment, and personnel to provide a high
level of fire, emergency medical, and law
enforcement service in San Marcos to meet
existing and future demands.
As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for fire services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. The project is consistent with this policy.
Goal LU-10,
Policy LU-10.2
Work closely with the County of San Diego
Sherriff’s Department to determine and meet
the community needs for adequate personnel,
equipment, and state-of-the-art technology to
effectively combat crime, and meet existing
and projected service demands.
As described further in Section 3.10 (Public Services), the project impacts related to public services were determined to be less than significant. The project’s demand for police protection services would be offset with payment of appropriate development fees, including payment of PFF and annexation into and participation in applicable CFDs. The project is consistent with this policy.
Goal LU-10,
Policy LU-10.3
Continue to conduct Public Outreach and
education regarding fire safety and crime
prevention within San Marcos.
The San Marcos Fire Department public education program provides comprehensive fire education via presentations, informational demonstrations, health fairs, and station tours, among others. The San Diego County Sheriff's Department provides safety presentations to youth groups and community groups through their Communit y Oriented Policing and Problem Solving deputies. Deputies also attend Neighborhood Watch meetings. In addition, the Crime Prevention Unit focuses on community outreach regarding crime prevention techniques, current trends, and prevention education. The project's annexation into and contribution to the applicable CFD would aid in the continued provision of these services. The project is consistent with this policy.
Goal LU-11 Schools: Ensure all residents have access to high-quality education.
Students generated by the project would attend Richland Elementary School, Woodland Park Middle School, and Mission Hills High School. The project applicant would be required to pay all applicable development fees including payment of school mitigation fees, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal Code Section 17.52.050, The project is consistent with this goal.
3.8 Land Use and Planning
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City of San Marcos Page 3.8-31
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy
Goal LU-11,
Policy LU-11.1
Collaborate with the local public school district
(SMUSD), private schools, and institutions of
higher learning to ensure a range of traditional
and distance-learning educational
opportunities are provided in superior,
accessible facilities that complement the
surrounding land uses.
The project would generate 35 students for SMUSD. The project developer would pay school mitigation fees to offset impacts to schools. The project is consistent with this policy.
Goal LU-11,
Policy LU-11.2
Work with San Marcos Unified School District
and developers to ensure adequate school
facilities are funded as required by State law
and through developer mitigation agreements
between the school district and the developer.
The City shall require a “will serve” letter
substantiating that the developer has paid fees
to the satisfaction of the school district prior to
issuance of building permits.
The project would generate 35 students for SMUSD. The project developer would pay school mitigation fees to offset impacts to schools. The project is consistent with this policy.
Goal LU-12 Libraries: Provide library resources and
services that meet the needs of the
community.
While development of the proposed project would increase demand for library services and resources, the project does not include construction of any library facilities. However, additional library services are available in the County through the Serra Cooperative Library System as well as through California State University San Marcos (CSUSM) and Palomar Community College. Therefore, a less than significant impact was identified for this issue (see Section 3.10, Public Services). The project is consistent with this goal.
Goal LU-12,
Policy LU-12.1
Provide adequate library facilities and
technological access that enhance San
Marcos’s quality of life and create a civic
environment with vast opportunities for self-
learning and academic enrichment.
While development of the proposed project would increase demand for library services and resources, the project does not include construction of any library facilities. However, additional library services are available in the County through the Serra Cooperative Library System as well as through CSUSM and Palomar Community College. Therefore, a less than significant impact was identified for this issue (see Section 3.10, Public Services). The project is consistent with this goal.
Goal LU-13 Water Service and Supply: Manage and
conserve domestic water resources by reducing
water usage and waste on a per capita basis,
The landscape plan for the project focuses on low-water use, native species. The Landscape Plan is presented in Figure 2-4. The proposed landscaping plan conforms to strict water conservation measures, including the City’s WELO. Additionally, the
3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-32
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy to ensure an adequate water supply for existing
and future residents.
project is required to pay Water Capital Facility Fees to VWD. The project is consistent with this goal.
Goal LU-13,
Policy LU-13.1
Work closely with local and regional water
providers to ensure high quality water supplies
are available for the community.
VWD treats water to meet stringent state and federal standards. Ensuring quality at the source is cheaper than treatment. As described in Section 3.7 (Hydrology/Water Quality), the project would not contribute significant polluted runoff due to the incorporation of bioretention and water quality BMPs. Therefore, the project would not impact any local or regional water supplies. The project is consistent with this policy.
Goal LU-13,
Policy LU-13.2
Actively promote water conservation programs
aimed at reducing demand.
VWD promotes conservation and has issued drought alerts under drought conditions.
While not currently in effect, future residential users within this district would be required to comply with any drought alerts and required conservation measures that would reduce demand. The project also incorporates low-water landscaping and would be required to comply with the City’s WELO. The project is consistent with this policy.
Goal LU-13,
Policy LU-13.3
Encourage exploration and use of deep
underground wells to reduce reliance on
treatable water.
The project would irrigate proposed landscaping with potable water. Groundwater use is not proposed by the project. The project’s landscape plan focuses on low-water and drought-tolerant species and meets the requirements of the City’s WELO. The project is consistent with this policy.
Goal LU-14 Wastewater: Ensure an adequate wastewater
system for existing and future development.
Based on the analysis in Section 3.13 (Utilities and Service Systems), there is currently adequate wastewater treatment capacity to serve the project. the project would extend the existing gravity sewer main located north of the project site in Woodward Street for approximately 490 feet. The project applicant would also pay VWD Wastewater Capital Facility Fees for portions of the improvements. The project is consistent with this goal.
Goal LU-14,
Policy LU-14.1
Work closely with local service providers to
ensure an adequate wastewater system for
existing and future development is in place.
Based on the analysis in Section 3.13 (Utilities and Service Systems), there is currently adequate wastewater treatment capacity to serve the project. The project would extend the existing gravity sewer main located north of the project site in Woodward Street for approximately 490 feet. The project applicant would also pay VWD Wastewater Capital Facility Fees for portions of the improvements. The project is consistent with this policy.
Goal LU-14,
Policy LU-14.2
Ensure development approval is directly tied to
commitments for the construction or
Based on the analysis in Section 3.13 (Utilities and Service Systems), there is currently adequate water and wastewater treatment capacity to serve the project.
Expansion of existing wastewater facilities would be necessary to accommodate
3.8 Land Use and Planning
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy improvement of primary water, wastewater,
and circulation systems.
buildout of the VWD services area per the 2018 Master Plan. The project would construct sewer improvements as detailed in Section 3.13.4 of the EIR. The project may also pay Water Capital Facility Fees to VWD and Wastewater Capital Facility Fees to VWD. Additionally, as discussed in Section 3.8.4, above and in Section 3.11 (Transportation), the project will not impact any circulation systems. The project is consistent with this policy.
Goal LU-15 Flood control and storm water drainage
facilities: ensure adequate flood control and
storm water drainage is provided by the
community.
As identified in Section 3.7 (Hydrology/Water Quality), off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. Therefore, implementation of the project would not impact flood control or storm water drainage facilities. The project is consistent with this goal.
Goal LU-15,
Policy LU-15.1
Implement activities, practices, procedures, or
facilities that avoid, prevent, or reduce
pollution of the San Marcos Storm Water
Conveyance System and receiving waters.
As identified in Section 3.7 (Hydrology/Water Quality), implementation of the project’s comprehensive water quality management plan, which incorporates biofiltration and BMPs, would ensure the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Implementation of the project would reduce pollutants entering the San Marcos Storm Water Conveyance System and receiving waters. The project is consistent with this policy.
Goal LU-15,
Policy LU-15.2
Improve inadequate or undersized
drainage/flood control facilities to solve both
small neighborhood and large regional
drainage and flood control problems.
As identified in Section 3.7 (Hydrology/Water Quality), off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. No inadequate or undersized drainage/ flood control facilities were identified that serve the project area.
Therefore, implementation of the project would not impact flood control or storm water drainage facilities. The project is consistent with this policy.
Goal LU-15,
Policy LU-15.3
Avoid, to the extent possible, development in
floodplain and flood prone areas.
The project does not propose development within a floodplain or flood prone area.
The project is consistent with this policy.
Goal LU-15,
Policy LU-15.4
Retain drainage courses in their natural
condition, to the extent possible. Consider
smaller-scale drainage improvements to
protect the environment and avoid disturbing
natural drainage courses; consider detention
areas and raised building pads.
The project is adequately designed such that it would not substantially alter the existing drainage pattern of the site or area. The project would detain and retain runoff through the site with combined water quality and hydromodification bioretention and BMPs. The project is consistent with this policy.
Goal LU-16 Solid waste: reduce the amount of waste
material entering regional landfills with an
As discussed in Section 3.13 (Utilities and Service Systems), the City of San Marcos has a disposal rate target of 8.9 lbs/person/day. If the City meets this target, the City
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy efficient and innovative waste management
program.
is considered in compliance with the 50% diversion requirement of AB 939. The most recent data (2022) from CalRecycle identifies the annual per capital disposal rate for the City of San Marcos is 5.3 lbs/person/day. Thus, the City is exceeding their curren t targets for diversion. In accordance with AB 341, the project would be required to achieve a 75 % waste diversion rate. All green waste would be diverted from landfills and recycled as mulch. The Sycamore Sanitary Landfill has sufficient permitted capacity to accommodate the project's solid waste disposal needs. The project is consistent with this goal.
Goal LU-16,
Policy LU-16.1
Work closely with local service providers to
ensure adequate solid waste disposal,
collection, and recycling services.
Non-recyclable waste, including general trash and green materials, would be collected and transported for disposal by EDCO, a licensed hauler. According to Section 3.13 (Utilities and Service Systems), the Sycamore Sanitary Landfill has sufficient permitted capacity to accommodate the project's solid waste disposal needs. In accordance with AB 341, the project would be required to achieve a 75% waste diversion rate. All green waste would be diverted from landfills and recycled as mulch. The project is consistent with this policy.
Goal LU-16,
Policy LU-16.2
Increase recycling, composting, source
reduction, and education efforts throughout
the city to reduce the amount of solid waste
requiring disposal at landfills.
The City of San Marcos is in compliance with AB 939, which requires 50% waste diversion through recycling. The project is consistent with this policy.
Policy LU-17.2 Require all new development and
redevelopment to provide the technology to
support multiple telecommunications facilities
and providers such as multi-media products,
wireless technologies, and satellite
communications.
As discussed in Section 3.13 (Utilities and Service Systems) communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. However, no specific systems upgrades are proposed with this project, and the location and extent of future facilities is not known at this time. The design for the dry utilities’ connection is still under preparation, however the project proposes to connect to existing infrastructure within Woodward Street. This work would take place within the existing right-of-way and would not disturb any vegetation. The project is consistent with this policy.
Policy LU-17.3 The City shall prohibit above ground utility equipment within any of the pedestrian
pathway and street frontage areas. All above
ground utilities shall be placed either within;
“wet closets” within the buildings, underground
As discussed in Section 3.13 (Utilities and Service Systems) communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. However, no specific systems upgrades are proposed with this project, and the location and extent of future facilities is not known at this time. The project
3.8 Land Use and Planning
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City of San Marcos Page 3.8-35
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy vaults, or behind buildings where they are not
visible. The developer shall be responsible to
contact the applicable utility agencies in
advance to coordinate utilities prior to approval
of the final street improvement plans for both
public and private street frontages and prior to
submittal of building permits.
would be served by SDG&E for electricity and gas service. The design for the dry utilities’ connection is still under preparation, however the project proposes to connect to existing infrastructure within Woodward Street.. This work would take place within the existing right-of-way and would not disturb any vegetation. The project is consistent with this policy.
Mobility Element
Goal M-1 Provide a comprehensive multimodal
circulation system that serves the City land
uses and provides for the safe and effective
movement of people and goods.
The project would connect to the existing sidewalk and bicycle lane along the project frontage on Woodward Street. The project is consistent with this goal.
Goal M-1,
Policy M-1.1
Safely and efficiently accommodate traffic
generated by development and redevelopment
associated with implementation of the General
Plan Land Use Policy Map.
Based upon the traffic analyses prepared for the project by LLG (2023), the project does not result in any transportation impacts, nor does it result in any safety concerns. The project is consistent with this policy.
Goal M-1,
Policy M-1.2
Require new development to finance and
construct internal adjacent roadway circulation
and City-wide improvements as necessary to
mitigate project impacts, including roadway,
transit, pedestrian, and bicycle facilities.
The project has been designed to include an access driveway and internal drive aisle with cul-de-sacs. No private streets are proposed. The project does not result in any significant transportation related impacts and no improvements beyond what is already proposed as part of the project design are required (construct an access point that provides adequate driveway sight distance and 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).
The project is consistent with this policy.
Goal M-1,
Policy M-1.4
Utilize multi-modal LOS techniques to evaluate
transportation facilities. For identified
prioritized modes (based on facility typology),
provide the following minimum LOS as shown
in Table 3-4 of the Mobility Element: LOS D or
better for Vehicles as a prioritized mode or the
City shall allow for flexible LOS where
warranted (e.g., accepting a lower LOS than
identified above).
The local transportation analysis prepared for the project (Appendix J) relied on this LOS technique to determine project-related impacts to the circulation network. As summarized in Section 3.8.4 (Land Use and Planning), study area intersections and roadway segments would continue to operate at an acceptable LOS with implementation of the project. The project would be consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal M-1,
Policy M-1.6/
Goal EJ-2,
Policy EJ-2.10
Work to improve connectivity within the City by
closing gaps in the existing bicycle, pedestrian,
trail, transit, and roadway network. Work with
new development to provide connectivity and
redundancy in the mobility network.
The project includes pedestrian pathways that would connect to the existing pedestrian and bicycle network on Woodward Street. The project is consistent with this policy.
Goal M-1,
Policy M-1.7/
Goal EJ-2,
Policy EJ-2.11
Strive to ensure that streets within San Marcos
shall be complete streets where feasible;
thereby providing accessibility, safety,
connectivity, and comfort for all modes and
users of the system. Appropriate new local
streets and Main Streets will prioritize
pedestrian and bicycle users through the
corridor.
Complete streets balance the needs of all users, both motorized and non-motorized, in design and construction. The project includes pedestrian pathways that would connect to the existing pedestrian and bicycle network on Woodward Street. The project is consistent with this policy.
Goal M-2 Protect neighborhoods by improving safety for
all modes of travel and calming traffic where
appropriate.
Travel modes within and surrounding the project area include vehicular, pedestrian, and bicycle. The project includes pedestrian pathways that would connect to the existing pedestrian and bicycle network on Woodward Street. The project is consistent with this goal.
Goal M-2,
Policy M-2.1
Work with new development to design
roadways that minimize traffic volumes and/or
speed, as appropriate within residential
neighborhoods; while maintaining the City’s
desire to provide connectivity on the roadway
network.
The project includes pedestrian pathways that would connect to the existing pedestrian and bicycle network on Woodward Street. The project is consistent with this policy.
Goal M-3 Promote and encourage use of alternative
transportation modes, including transit,
bicycles, neighborhood electric vehicles (NEVs),
and walking, within the City.
There are NCTD bus stops near the project on E. Mission Road and the project is 0.1 miles from SPRINTER station at the San Marcos Civic Center. As a design feature each residential garage would be wired to accommodate an EV charger. Therefore, the project is consistent with this goal.
Goal M-3,
Policy M-3.1/
Goal EJ-1,
Policy EJ-1.8
Develop an integrated, multimodal circulation
system that accommodates transit, bicycles,
pedestrians, and vehicles; provides
opportunities to reduce air pollution and
greenhouse gas emissions; and reinforces the
The project site is located near public transit and the project’s pedestrian pathways connect to existing sidewalks along Woodward Street. The placement of residential uses near transit options would provide for convenient nearby transit access to future residents of the project. Therefore, the project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy role of the street as a public space that unites
the City.
Goal M-3,
Policy M-3.2
Improve safety conditions, efficiency, and
comfort for bicyclists and pedestrians through
design, maintenance, and law enforcement.
Install wider sidewalks and curb extensions at
pedestrian crossings (bulb outs) where
appropriate.
The project would not impact any existing bicycle or pedestrian infrastructure. The project’s pedestrian pathways would connect to existing pedestrian and bicycle infrastructure on Woodward Street. Therefore, the project is consistent with this policy.
Goal M-3,
Policy M-3.3
Provide a pedestrian and bicycle network in
existing and new neighborhoods that facilitates
convenient and continuous pedestrian and
bicycle travel free of major impediments and
obstacles.
The project includes pedestrian pathways that would connect to the existing pedestrian and bicycle network on Woodward Street. The project is consistent with this policy.
Goal M-3,
Policy M-3.5/
Goal EJ-5,
Policy EJ-5.5
Ensure that streets in areas with high levels of
pedestrian activity (such as employment
centers, residential areas, mixed use areas,
and schools) support safe pedestrian travel by
providing detached sidewalks, bulb-outs,
enhanced pedestrian crossings, pedestrian
bridges, and medians.
There is an existing sidewalk along the project frontage on Woodward Street. For any temporary disruptions to the sidewalk due to project construction, signage would be placed to alert pedestrians. The project would not result in any long-term impacts to the existing pedestrian network in the project vicinity. The project is consistent with this policy.
Goal M-3,
Policy M-3.9/
Goal EJ-5,
Policy EJ-5.6
Create a pleasant walking environment for
roadway typologies where pedestrian travel is
prioritized. This includes providing shade trees,
landscaping, benches, pedestrian-scale
lighting, way finding signage, transit shelters,
and other appropriate amenities.
Pedestrian areas are incorporated into the project design and include landscaping, shade trees and a common open space area with play equipment and seating. The project would connect to the existing sidewalk on Woodward Street. The project is consistent with this policy.
Conservation and Open Space Element
Goal COS-1 Identify, protect, and enhance significant
ecological and biological resources within San
Marcos and its adaptive Sphere of Influence.
A biological technical report (Appendix D.1) , rare plant survey memorandum (Appendix D.2), Coastal California Gnatcatcher protocol survey (Appendix D.3) and Crotch’s bumble bee protocol survey (Appendix D.4) were prepared for the project and summarized in Section 3.3. (Biological Resources). The project would impact sensitive habitat and has the potential to impact sensitive species. Implementation of
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy mitigation measures MM-BIO-1 through MM-BIO-6 would reduce these impacts to below a level of significance. The project is consistent with this goal.
Goal COS-1,
Policy COS-1.1
Support the protection of biological resources
through the establishment, restoration, and
conservation of high-quality habitat areas.
A biological technical report (Appendix D.1) and rare plant survey memorandum (Appendix D.2) were prepared for the project and summarized in Section 3.3 (Biological Resources). The project site supports sensitive habitat and mitigation measures would be implemented to reduce impact to below a level of significance MM-BIO-1 through MM-BIO-6. The project design includes common open space, a portion of which may be placed in a biological conservation easement, which would contribute to the blocks of preserved habitat in the project vicinity. The project is consistent with this policy.
Goal COS-1,
Policy COS-1.2
Ensure that new development, including
Capital Improvement Projects, maintain the
biotic habitat value of riparian areas, oak
woodlands, habitat linkages, and other
sensitive biological habitats.
No oak woodlands, jurisdictional wetlands, or habitat linkages occur on the project site. The project would impact sensitive habitat (Diegan coastal sage scrub and disturbed Diegan coastal sage scrub) and has the potential to impact sensitive species. Implementation of mitigation measures MM-BIO-1 through MM-BIO-6 would reduce these impacts to below a level of significance. The project is consistent with this goal.
Goal COS-2 The City is committed to conserving, protecting, and maintaining open space, agricultural, and
limited resources for future generations. By
working with property owners, local
organizations, and state and federal agencies,
the City can limit the conversion of resource
lands to urban uses.
The project site is an undeveloped parcel in a developed portion of the city and has been identified for development in the City’s General Plan. The project would impact sensitive habitat and has the potential to impact sensitive species. Implementation of mitigation measures MM-BIO-1 through MM-BIO-6 would reduce these impacts to below a level of significance. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.1
Provide and protect open space areas
throughout the City for its recreational,
agricultural, safety, and environmental value.
The project proposes 6.01 acres of common open space. Portions of the common open space area within Lot A may be preserved as biological habitat and subject to an open space easement. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.2
Limit, to the extent feasible, the conversion of
open space to urban uses and place a high
priority on acquiring and preserving open space
lands for recreation, habitat protection and
enhancement, flood hazard management,
water and agricultural resources protection,
and overall community benefit.
The project site is an undeveloped parcel in a developed portion of the city and has been identified for development in the City’s General Plan. The project site supports sensitive habitat including Diegan coastal sage scrub and disturbed Diegan coastal sage scrub. The project has been designed to cluster development to leave larger blocks of habitat intact. Mitigation measures are incorporated to offset impacts to sensitive habitat and potential impacts to sensitive species. There are no flood hazard management issues with the project. Water supply and resources were
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy addressed in Section 3.13 (Utilities and Service Systems) and it was concluded that there is adequate potable water service to serve the project. The project also incorporates low-water landscaping and would be required to comply with the City’s WELO. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.5
Continue to review future development
proposals to ensure that cultural resources
(including prehistoric, historic, paleontological,
and SB 18 Tribal resources) are analyzed and
conserved in compliance with CEQA
requirements.
The proposed project’s potential impacts to cultural resources are detailed in Section
3.4 (Cultural Resources). An archaeological survey report was also prepared for the project (ASM 2024). The City reached out to tribes consistent with the requirements of Senate Bill 18 and Assembly Bill (AB) 52 and met with tribes that requested consultation. Mitigation measures are incorporated into the EIR (MM-CR-1 and MM- CR-2) to reduce impacts to cultural resources to below a level of significance. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.6
Preserve healthy mature trees where feasible;
where removal is necessary, trees shall be
replaced at a ratio of 1:1.
The project site has scattered trees including eucalyptus, queen palm and Mexican fan palm. The proposed landscape plan includes 246 trees which greatly exceeds the requirements of a 1:1 replacement ratio. Proposed tree species include: evergreen elm, Marina strawberry tree, Chitalpa pink dawn, Australian willow, Tuscarora crape myrtle, Chinese pistache, African sumac, eastern redbud, bronze loquat, sweetshade, shrubby yew podocarpus, Torrey pine, coast live oak, southern live oak, Brisbane box, and little gem magnolia. The project is consistent with this policy.
Goal COS-3 Protect natural topography to preserve and
enhance the natural beauty of San Marcos.
The project has been designed to complement the existing topography on the site.
Views of the surrounding hillsides would remain unobstructed from SR-78; however the project would be visible from area roadways, particularly the Twin Oaks Valley Road bridge. The project site is not a protected scenic vista. The project also incorporates extensive design features that ensure that the visual character changes blend with the existing topography and surrounding development including the use of retaining walls to minimize grading, the use of neutral colors on building and retaining walls, and implementation of a comprehensive landscape plan. The project is consistent with this goal.
Goal COS-3,
Policy COS-3.1
Preserve scenic resources, including prominent
landforms such as Double Peak, Owens Peak,
San Marcos Mountains, Merriam Mountains,
Cerro de Las Posas, Franks Peak, and canyon
areas through conservation and management
policies.
None of the prominent landforms as identified in the General Plan are on-site. While implementation of the proposed project would result in changes in the viewshed, development would not alter or impede views of prominent landforms. Views to prominent landforms would remain unobstructed. In addition, the project site is not a protected scenic vista. The project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-3,
Policy COS-3.2
Encourage and maintain high-quality
architectural and landscaping designs that
enhance or complement the hillsides,
ridgelines, canyons, and view corridors that
comprise the visual character in San Marcos.
The proposed architectural design includes elevation treatments, varied rooflines, and a mix of materials and neutral colors. The project has been designed to respect the existing topography on the site and incorporates retaining walls to minimize the amount of grading on the project site. Landscape materials would be used to enhance architectural elements and the provided street trees would enhance the pedestrian experience along the project frontages. The landscape planting palette for manufactured slopes would blend in with the existing natural vegetation. The project is consistent with this policy.
Goal COS-3,
Policy COS-3.3
Continue to work with new development and
redevelopment project applicants in designing
land use plans that respect the topography,
landforms, view corridors, wildlife corridors,
and open space that exists.
The project has been designed to respect the existing topography by clustering the development within a portion of the project site. The project site is not located in a view corridor or wildlife corridor. Development has been focused away from the preserved open space area to the north of the project site. The project is consistent with this policy.
Goal COS-3,
Policy COS-3.4
Evaluate potential impacts to visual and
aesthetic resources, including the potential to
create new light sources, while still maintaining
and being sensitive to rural lighting standards.
Development of the proposed project would create new sources of light at a site that is currently undeveloped. Lighting would be guided by the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards to aid in the preservation of dark sky conditions. Additional lighting specification are included in Section 4.2.6 of the Woodward 46 Specific Plan. Lighting impacts were determined to be less than significant (Section 3.1 Aesthetics). The project is consistent with this policy.
Goal COS-4 Improve regional air quality and reduce
greenhouse gas (GHG) emissions that
contribute to climate change.
The project’s impact to air quality would be less than significant as described in Section 3.2 (Air Quality) of this EIR. The project would not conflict with or obstruct implementation of any air quality plan or violate any air quality standard. Based upon the analysis in Section 5.6 (Greenhouse Gas), the project screens out of a detailed GHG analysis since it proposes fewer than 55 multi-family units. GHG impacts are presumed to be less than significant. The project is consistent with this goal.
Goal COS-4,
Policy COS-
4.1/ Goal EJ-1,
Policy EJ-1.9
Continue to work with the U.S. EPA, CARB,
SANDAG, and the SDAPCD to meet State and
federal ambient air quality standards.
Implementation of the proposed project would not exceed any air quality standard during construction or operation (see Section 3.2, Air Quality). Impacts are less than significant. The project is consistent with this policy.
Goal COS-4,
Policy COS-
Participate in regional efforts to reduce GHG
emissions.
The project is not anticipated to impair implementation of AB 32. Development of the project would not affect regional efforts to reduce GHG emissions. The City’s updated 2020 Climate Action Plan (CAP) quantifies community emissions, identifies emission
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy
4.3/ Goal EJ-1,
Policy EJ-1.11
reduction targets, and specifies climate action measures to reduce GHG emissions.
Based upon the analysis in Section 5.6 (Greenhouse Gas), the proposed project screens out of a detailed GHG analysis since it proposes fewer than 55 multi-family units. GHG impacts are presumed to be less than significant. The project is consistent with this policy.
Goal COS-4,
Policy COS-
4.4/ Goal EJ-1,
Policy EJ-1.12
Quantify community wide and municipal GHG
emissions, set a reduction goal, identify, and
implement measures to reduce GHG emissions
as required by governing legislation.
The City’s updated 2020 CAP quantifies community emissions, identifies emission reduction targets, and specifies climate action measures to reduce GHG emissions.
Based upon the analysis in Section 5.6 (Greenhouse Gas), the proposed project screens out of a detailed GHG analysis since it proposes fewer than 55 multi-family units. GHG impacts are presumed to be less than significant.
The project is consistent with this policy.
Goal COS-4,
Policy COS-
4.5/ Goal EJ-1,
Policy EJ-1.13
Encourage energy conservation and the use of
alternative energy sources within the
community.
As discussed in Section 3.13 (Utilities and Service Systems), the proposed project includes various on-site features and measures to reduce the proposed project’s energy consumption. The project would be built-in compliance with Title 24 requirements applicable at that time. Additionally, as a design feature, each garage would be wired to accommodate an EV charger. The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.
Goal COS-4,
Policy COS-4.6
Goal EJ-1,
Policy EJ-1.14
Promote efficient use of energy and
conservation of available resources in the
design, construction, maintenance and
operation of public and private facilities,
infrastructure, and equipment.
As discussed in Section 3.13 (Utilities and Service Systems), the proposed project includes various on-site features and measures to reduce the proposed project’s energy consumption. The project would be built-in compliance with Title 24 requirements applicable at that time. Additionally, as a design feature, each garage would be wired to accommodate an EV charger. The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.
Goal COS-4,
Policy COS-
4.8/ Goal EJ-1,
Policy EJ-1.15
Encourage and support the generation,
transmission, and use of renewable energy.
Development on the project site would meet the requirements of California’s Building Energy Efficiency Standards, which focus on several key areas to improve the energy efficiency of newly constructed buildings. The project has also been designed to meet current California Building Code requirements as related to green building practices.
The project is consistent with this policy.
Goal COS-5 Reduce water consumption and ensure reliable water supply through water efficiency,
conservation, capture, and reuse.
VWD promotes conservation and has issued drought alerts under drought conditions.
Future residential users within this district would be required to comply with any issued alerts and required conservation measures that would reduce demand. The
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy project proposes a landscape plan that emphasizes low water use species in adherence to the City of San Marcos Water Efficient Landscape Ordinance. The project is consistent with this goal.
Goal COS-6 Protect and restore appropriate surface water and groundwater beneficial uses through
prioritizing the improvement of locally impaired
water bodies within the City of San Marcos
subwatersheds.
The project is located within a watershed with numerous impaired water bodies. The BMP Design Manual requires that pollutants of concern for each impaired water body in the watershed be treated by engineered treatment controls to a medium pollutant removal efficiency or better prior to leaving the project site. The project proposes treatment of storm water runoff via biofiltration facilities prior to discharge, which would result in a medium or high efficiency for removal of the pollutants of concern.
Any groundwater infiltration would likely reach surface flows before reaching groundwater due to the approximate depth to groundwater. Therefore, the project would not have a potentially significant adverse impact on groundwater quality or result in significant impacts to impaired water bodies. The project is consistent with this goal.
Goal COS-6,
Policy COS-6.2
Promote watershed stewardship as the
community norm.
The project includes a comprehensive water quality management approach, which incorporates biofiltration and the use of BMPs, to ensure the project would not contribute any pollutants to area watersheds. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a Stormwater Pollution Prevention Plan (SWPPP), and implement BMPs in compliance with the National Pollution Discharge Elimination System (NPDES) permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would contribute to watershed stewardship. The project is consistent with this policy.
Goal COS-7 Achieve sustainable watershed protection for surface and ground water quality that balances
social, economical, and environmental needs.
The project includes a comprehensive water quality management approach, which incorporates biofiltration and the use of BMPs, to ensure the project would not contribute any pollutants to area watersheds. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would contribute to watershed stewardship. The project is consistent with this policy.
Goal COS-8 Focus watershed protection, surface and
groundwater quality management on sources
Implementation of the project’s comprehensive water quality management plan, which incorporates biofiltration and the use of BMPs, would ensure that the project
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy and practices that the City has the ability to
affect.
would treat runoff containing the pollutants of concern for locally impaired water bodies. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would reduce construction effects on receiving water quality and protect stormwater runoff. The project is consistent with this policy.
Goal COS-8,
Policy COS-8.4
Require new development and redevelopment
to protect the quality of water bodies and
natural drainage systems through site design,
source controls, storm water treatment, runoff
reduction measures, BMPs, LID,
hydromodification strategies consistent with
the Current San Diego RWQCB Municipal
Stormwater NPDES Permit, and all future
municipal stormwater permits.
Implementation of the project’s comprehensive water quality management plan, which incorporates biofiltration and the use of BMPs, would ensure that the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would reduce construction effects on receiving water quality and protect stormwater runoff. The project is consistent with this policy.
Goal COS-10 Establish and maintain an innovative,
sustainable solid waste collection, recycling,
and disposal delivery system for present and
future generations.
As discussed in Section 3.13 (Utilities and Service Systems), according to CalRecycle, the City of San Marcos has a disposal rate target of 8.9 lbs/person/day. If the City meets this target, the City is considered in compliance with the 50% diversion requirement of AB 939. The most recent data (2022) from CalRecycle identifies the annual per capita disposal rate as 5.3 pounds per person per day (CalRecycle 2022).
Thus, the City is exceeding their target for diversion. In accordance with AB 34, the project would be required to achieve a 75% waste diversion rate. All green waste would be diverted from landfills and recycled as mulch. The Sycamore Sanitary Landfill has sufficient permitted capacity to accommodate the project's solid waste disposal needs. The project is consistent with this goal.
Goal COS-10,
Policy COS-
10.1 Promote the curbside recycling program to
divert residential refuse from the landfills.
The City of San Marcos is in compliance with AB 939, which requires 50% waste diversion through recycling. The project would participate in the City’s recycling efforts. The project is consistent with this policy.
Goal COS-11 Continue to identify and evaluate cultural, historic, archaeological, paleontological, and
architectural resources for protection from
demolition and inappropriate actions.
An archaeological survey report was prepared for the project site and summarized in Section 3.4 (Cultural Resources) Mitigation measures are incorporated (MM-CR-1 and MM-CR-2) to reduce potential impacts to archaeological resources to below a level of significance. There are no historical resources on the project site. As discussed in
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Section 3.6 (Geology and Soils), the project site supports plutonic bedrock granite and colluvium and would be very unlikely to contain paleontological resources. . The project is consistent with this goal.
Goal COS-11,
Policy COS-
11.1 Identify and protect historic and cultural
resources including individual properties,
districts, and sites (e.g., archaeological sites) in
compliance with CEQA.
An archaeological survey report was prepared for the project site and summarized in Section 3.4 (Cultural Resources). Mitigation measures (MM-CR-1 and MM-CR-2) are incorporated to reduce potential impacts to archaeological resources to below a level of significance. There are no historical resources on the project site. The project is consistent with this policy.
Goal COS-11,
Policy COS-
11.2 Prohibit the demolition or removal of a historic
structure without evaluation of the condition of
the structure, the cost of rehabilitation, and the
feasibility of alternatives to preservation in
place including but not limited to relocation, or
reconstruction offsite, and/or photo-
preservation.
There are no historical resources on the project site, therefore the project would not have the potential to impact such resources (ASM 2024). The project is consistent with this policy.
Parks, Recreation and Community Health Element
Goal PR-1 Plan for, acquire, develop, and maintain a
system of local parks connected through an
integrated network of trails and high quality
recreational facilities.
Section 5.13 (Environmental Effects Found Not to Be Significant - Recreation) analyzed the project’s impact on recreational facilities. The proposed project would result in an increase in the City of San Marcos population by approximately 143 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City, in addition to what is provided on-site. The project includes common open space areas, including a tot lot, turf play areas and a sensory garden.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this goal.
Goal PR-1,
Policy PR-1.1/
Goal EJ-2,
Policy EJ-2.6/
Goal EJ-5,
Policy EJ-5.7
Develop and maintain a complete system of
public parks and recreational amenities that
provide opportunities for passive and active
recreation at a minimum standard of 5 acres
per 1,000 residents. Parks, trails, and
recreational facilities will enhance community
livability, public health, and safety; should be
Section 5.13 (Environmental Effects Found Not to Be Significant - Recreation) analyzed the project’s impact on recreational facilities. The proposed project would result in an increase in the City of San Marcos population by approximately 143 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City, in addition to what is provided on-site. The project includes common open space areas, including a tot lot, turf play areas and a sensory garden.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy equitably distributed throughout the City; and
be responsive to the needs and interests of
residents, employees, and visitors.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.3/
Goal EJ-
2,Policy EJ-2.7
Ensure that the development of parks, trails,
and recreation facilities and services keeps
pace with development and growth within the
City.
Section 5.13 (Environmental Effects Found Not to Be Significant - Recreation) analyzed the project’s impact on recreational facilities. The proposed project would result in an increase in the City of San Marcos population by approximately 143 residents. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City, in addition to what is provided on-site. The project includes common open space areas, including a tot lot, turf play areas and a sensory garden.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.4/
Goal EJ-5,
Policy EJ-5.8
Promote increased access to parks and open
spaces, pedestrian- and bike-oriented routes to
parks and open space, greening of public
rights-of-way, and a variety of active and
passive uses of parks and open space.
Section 5.13 (Environmental Effects Found Not to Be Significant - Recreation) analyzed the project’s impact on recreational facilities. The proposed project would result in an increase in the City of San Marcos population by approximately 143 residents. The project would connect to Woodward Street which is developed with sidewalks and bicycle lanes which can help future residents access other local parks and recreation spaces. The proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City, in addition to what is provided on-site. The project includes common open space areas, including a tot lot, turf play areas and a sensory garden. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.5/
Goal EJ-5,
Policy EJ-5.8
Require new development to be designed and
constructed in accordance with the approved
Parks Master Plan to meet or exceed the City’s
parkland standard of 5 acres per 1,000
residents.
Section 5.13 (Environmental Effects Found Not to Be Significant - Recreation) analyzed the project’s impact on recreational facilities. The proposed project would result in an increase in the City of San Marcos population by approximately 143 residents which equates to 0.72 acres of parks space applying the 5 acres per 1,000 resident ratio. The project includes 6.01 acres of common open space which includes
0.2 acre of recreation areas. The project will exceed the requirement. Additionally, the proposed project would be required to pay the City’s PFF, which goes toward the acquisition and development of local and community park facilities throughout the City, in addition to what is provided on-site. The project includes common open space
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy areas, including a tot lot, turf play areas and a sensory garden. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.7
Promote park and facility design that
discourages vandalism, deters crime, provides
natural surveillance, and creates a safe and
comfortable environment.
Safety considerations of the proposed project are discussed in Section 3.10 (Public Services). As proposed, the project, including development of common open space areas does not present any unique public safety challenges. The proposed project is consistent with this policy.
Goal PR-2,
Policy PR-2.2/
Goal EJ-5,
Policy EJ-5.10
Implement the trail network per the Master
Trails Plan to increase opportunities for
physical activity (e.g., walking, biking), healthy
lifestyles, and to reduce reliance on cars.
The City’s Master Trail Plan identifies an existing Urban Trail along the project frontage. The project’s driveway would provide access to this pedestrian facility. The project is consistent with this policy.
Safety Element
Goal S-1 Reduce risks to the community from
earthquakes by regulating new development
and redevelopment to prevent the creation of
new geologic and seismic hazards.
The project would implement all recommendations from the geotechnical investigation (Appendix G of the EIR). Additionally, development on the project site would be subject to the requirements of the latest California Building Code (CBC) for resistance to seismic shaking and would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of the State of California Occupational Safety and Health Administration (Cal/OSHA) to minimize risks from earthquakes. The project is consistent with this goal.
Goal S-1, Policy
S-1.1
Reduce the risk of impacts from geologic and
seismic hazards by applying current and proper
land use planning, development engineering,
building construction, and retrofitting
requirements.
The project would implement all recommendations from the geotechnical investigation (Appendix G of the EIR). Additionally, development on the project site would be subject to the requirements of the latest CBC for resistance to seismic shaking, and would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of Cal/OSHA to minimize risks from earthquakes. The project is consistent with this policy.
Goal S-1, Policy
S-1.2
Investigate specific groundwater levels and
geologic conditions underlying all new
development or redevelopment proposals in
areas where potential fault rupture,
There is no known faulting at the project site so the potential for surface fault rupture is low. The project site is not located in a State liquefaction susceptibility zone and is mapped in an area with generally zero to low liquefaction. The project is c onsistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy liquefaction, or other geologic hazards are
suspected.
Goal S-2 Minimize the risk to people, property, and the environment due to flooding hazards.
The project site is not located within a 100-year flood hazard area nor within the City’s Flood Damage Prevention Overlay Zone. Additionally, off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. The project is consistent with this goal.
Goal S-2, Policy
S-2
Require existing private development to take
responsibility for maintenance and repair of
structures to resist flood damage.
The project site is not located within a 100-year flood hazard area nor within the City’s Flood Damage Prevention Overlay Zone. Additionally, off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard has been identified. The project is consistent with this policy.
Goal S-3 Minimize injury, loss of life, and damage to
property results from structure or wildland fire
hazards.
Implementation of the proposed project would result in a developed area with roads, structures, and landscape vegetation. The project site is located in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. The proposed project is consistent with this goal.
Goal S-3, Policy
S-3.1
Require development to be located, designed,
and constructed to provide adequate
defensibility and reduce the risk of structural
loss and life resulting from wildland fires.
Development will consider hazards relative to
terrain, topography, accessibility, and proximity
to vegetation. One such provision for
development to minimize the risk of structural
loss and life shall be the inclusion of overhead
fire sprinklers.
The project site is located in a Local Responsibility Area with a Non-VHFHSZ designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. The proposed project is consistent with this policy.
Goal S-3, Policy
S-3.2
Provide sufficient level of fire protection service
to reduce risk from urban and wildland fire.
Advocate and support regional coordination
According to Section 3.10 (Public Services), the project would have a less than significant impact on fire protection services. Additional staff and resources would be provided via Community Facilities District No. 2001-01, into which the project would
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy among fire protection and emergency service
providers.
annex and pay required mitigation fees. The proposed project is consistent with this policy.
Goal S-3, Policy
S-3.3
Require development to provide additional
access roads when necessary to provide for
safe access of emergency equipment and
civilian evacuation concurrently.
Access to the project site would be via one unsignalized driveway on Woodward Street. The access driveway and internal drive aisle have been designed to allow for access by emergency response equipment including fire trucks. The fire Marshal has reviewed and approved the project plans. The proposed project is consistent with this policy.
Goal S-3, Policy
S-3.4
Coordinate with fire protection and emergency
service providers to assess fire hazards before
and after wildfire events to adjust fire
prevention and suppression needs, as
necessary, commensurate with both short- and
long-term fire prevention needs.
The Fire Marshal has reviewed the project plans. The project site is located in a Local Responsibility Area with a Non-VHFHSZ designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non- VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. The proposed project is consistent with this policy.
Goal S-3, Policy
S-3.6
Protect communities from unreasonable risk of
wildfire within very high fire hazard severity
zones.
a. Assess site constraints when considering
land use designations near wildlands to avoid
or minimize wildfire hazards as part of a
community plan update or amendment.
b. Identify building and site design methods or
other methods to minimize damage if new
structures are located in very high fire hazard
severity zones on undeveloped land and when
rebuilding after fire.
c. Require ongoing brush management to
minimize the risk of structural damage or loss
due to wildfires.
d. Provide and maintain water supply systems
to supplies for structural fire suppression.
e. Provide adequate fire protection.
The Fire Marshal has reviewed the project plans. The project site is located in a Local Responsibility Area with a Non-VHFHSZ designation per CALFIRE’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non- VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding areas are not identified as a Fire Hazard Severity Zone. The proposed project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal S-4 Protect life, structures, and the environment
from the harmful effects of hazardous
materials and waste.
During construction, there is a potential for accidental upset of fuels, lubricants, and other materials; however, there are existing federal and state standards in place for the handling, storage, and transport of these materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. Additionally, the project site and surrounding properties are not considered hazardous materials sites. See Section 5.7 (Environmental Effects Found Not to be Significant - Hazards and Hazardous Materials) for additional information. The proposed project is consistent with this goal.
Goal S-4, Policy
S-4.1
Promote and support the proper disposal,
handling, transport, delivery, treatment,
recovery, recycling, and storage of hazardous
materials in accordance with applicable
federal, State, and local regulations.
During construction, there is a potential for accidental upset of fuels, lubricants, and other materials; however, there are existing federal and state standards in place for the handling, storage, and transport of these materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. Additionally, the project site and surrounding properties are not considered hazardous materials sites. See Section 5.7 (Environmental Effects Found Not to be Significant - Hazards and Hazardous Materials) for additional information. The proposed project is consistent with this policy.
Goal S-4, Policy
S-4.2/ Goal EJ-
1, Policy EJ-
1.21 Require areas of known or suspected
contamination to be assessed prior to reuse or
redevelopment. Plan for reuse of contaminated
areas in a manner that is compatible with the
nature of the contamination and subsequent
remediation efforts.
As discussed in Section 5.7 (Environmental Effects Found Not to be Significant – Hazards and Hazardous Materials), based on a search of the Department of Toxic Substance Control (DTSC) EnviroStor site conducted on May 16, 2023, there are no current or past permitted facilities or cleanup activities on the project site. The project would not develop an area of known or suspected contamination. The proposed project is consistent with this policy.
Goal S-4, Policy
S-4.3/ Goal EJ-
1, Policy EJ-
1.22 Require that land uses using hazardous
materials be located and designed to ensure
sensitive uses, such as schools, hospitals, day
care centers, and residential neighborhoods,
are protected.
The proposed project is not anticipated to generate, release, or use large amounts of hazardous materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. The proposed project is not anticipated to impact any sensitive uses in the project vicinity. The proposed project is consistent with this policy.
3.8 Land Use and Planning
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal S-4, Policy
S-4.4/ Goal EJ-
1, Policy EJ-
1.23 Avoid locating sensitive uses near established
hazardous materials users or industrial areas
where incompatibilities would result, except in
cases where appropriate safeguards have been
developed and implemented.
As discussed in Section 5.7 (Environmental Effects Found Not to be Significant – Hazards and Hazardous Materials), based on a search of the DTSC EnviroStor site conducted on May 16, 2023, there are no current or past permitted facilities or cleanup activities on or adjacent to the project site. The closest listed sites per EnviroStor are: 1) 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; and 2) 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. The proposed project is consistent with this policy.
Goal S-5 Establish and maintain an effective emergency
response program to respond to disasters and
maintain continuity-of-life support functions
during an emergency.
The Safety Element of the General Plan does not identify Woodward Street as an evacuation corridor. The site plan has been reviewed by the Fire Marshal. According to Section 5.7 (Environmental Effects Found Not to be Significant – Hazards and Hazardous Materials), the project would not impact any roadway or staging areas identified in any emergency planning documents. The project is consistent with this goal.
Goal S-5, Policy
S-5.3
Develop, implement, and maintain an effective
evacuation program for areas of risk in the
event of a disaster.
The San Marcos Emergency Operations Plan identifies several main thoroughfares as primary evacuation corridors in an emergency. The project provides one access driveway on Woodward Street. According to Section 5.7 (Environmental Effects Found Not to be Significant – Hazards and Hazardous Materials), the project would not impact any roadway or staging areas identified in any emergency planning documents. The project is consistent with this policy.
Goal S-6, Policy
S-6.3/ Goal EJ-
4, Policy EJ-
4.12 Use Crime Prevention through Environmental
Design (CPTED) principles in the design or
redevelopment of projects and buildings.
The San Diego County Sheriff's Department provides CPTED reviews through their crime prevention unit. The project's required contribution to a CFD would aid in the continued provision of this service. The Sheriff's Department has reviewed all project plans. The project is consistent with this policy.
Goal S-7 Comply with the McClellan-Palomar Airport
Land Use Compatibility Plan.
The project site is located within Review Area 2 of the McClellan-Palomar airport influence area and may be subject to annoyances associated with noise, vibration, and overflights. Consistent with the Airport Land Use Compatibility Plan (ALUCP), recordation of overflight notification documents would be required as a condition of
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy project approval. Review Area 2 also limits heights of structures in areas of high terrain. The project site is not characterized as high terrain and proposed development would remain below surrounding prominent topographic features. The project is consistent with this goal.
Goal S-7, Policy
S-7.1
Record an overflight notification document in
association with the approval of any new
residential land use within the AIA overflight
notification area consistent with the ALUCP.
The project site is located within Review Area 2 of the McClellan-Palomar airport influence area and may be subject to annoyances associated with noise, vibration, and overflights. Consistent with the ALUCP, recordation of overflight notification documents would be required as a condition of project approval. Review Area 2 also limits heights of structures in areas of high terrain. The project site is not characterized as high terrain and proposed development would remain below surrounding prominent topographic features. The project is consistent with this goal.
Noise Element
Goal N-1 Promote a pattern of land uses compatible with current and future noise levels.
The noise study prepared for the project (Appendix K) modeled ambient and future noise levels at the project site and compared with exterior and interior noise thresholds contained in the City’s General Plan. The project has the potential to result in short-term construction noise impacts related to proposed rock drilling for blasting operations and rock crushing. Implementation of mitigation measures MM-N-1 and MM-N-2 would reduce these impacts to below a level of significance. The project is not of a type that would generate excessive noise to neighboring uses during daily operation. Noise associated with increased traffic as a result of the project would not increase levels above the significance threshold of 3 dBA CNEL. Therefore, the project is consistent with this goal.
Goal N-1,
Policy N-1.1
Address the potential for excessive noise levels
when making land use planning decisions in
accordance with Table 7-3 Land Use
Compatibility Noise Standards.
The noise study prepared for the project (Appendix K) analyzed noise impacts to and generated from implementation of the proposed project. As summarized in Section
3.9 (Noise), there is a potential for construction related impacts from rock drilling and rock crushing. Implementation of mitigation measures MM-N-1 and MM-N-2 would reduce this impact to below a level of significance. No noise-related operational impacts were identified. The project is consistent with this policy.
Goal N-1,
Policy N-1.2
Ensure that acceptable noise levels are
maintained near noise-sensitive uses.
The noise study prepared for the project (Appendix K) analyzed noise impacts to and generated from implementation of the proposed project. As summarized in Section
3.9 (Noise), there is a potential for construction related impacts from rock drilling and rock crushing. Implementation of mitigation measures MM-N-1 and MM-N-2 would
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy reduce this impact to below a level of significance. No noise-related operational impacts were identified. The project is consistent with this policy.
Goal N-1,
Policy N-1.3/
Goal EJ-4,
Policy EJ-4.11
Incorporate design features into residential
land use projects that can be used to shield
residents from excessive noise. Design
features may include, but are not limited to:
berms, walls, and sound attenuating
architectural design and construction methods.
No noise-related operational impacts were identified for the project. The project is consistent with this policy.
Goal N-1,
Policy N-1.4
Require new development projects to provide
barriers to reduce noise levels, or provide
sufficient spatial buffers to separate excessive
noise generating land uses and noise-sensitive
land uses.
No noise-related operational impacts were identified for the project. The project is consistent with this policy.
Goal N-1,
Policy N-1.5
Require an acoustical study for proposed
developments in areas where the existing and
projected noise level exceeds or would exceed
the Normally Acceptable levels identified in
Table 7-3.
The noise study prepared for the project (Appendix K) analyzed noise impacts to and generated from implementation of the proposed project. As summarized in Section
3.9 (Noise), there is a potential for construction related impacts and implementation of mitigation measures MM-N-1 and MM-N-2 would reduce these impacts to below a level of significance. No noise-related operational impacts were identified. The project would not exceed the Normally Acceptable levels in General Plan Table 7-3. The project is consistent with this policy.
Goal N-2 Control transportation-related noise from
traffic, rail, and aviation sources near noise
sensitive land uses.
A noise study was prepared for the project (Appendix K) and summarized in Section
3.9, (Noise), of the EIR. Noise impacts related to off-site transportation noise, including vehicular traffic and the SPRINTER were determined to be less than significant. The project is consistent with this policy. The project is consistent with this goal.
Goal N-2,
Policy N-2.1
Encourage only noise-compatible land uses
along existing and future roadways, highways,
and freeways.
A noise study was prepared for the project (Appendix K) and summarized in Section
3.9, (Noise), of the EIR. Noise impacts related to off-site transportation noise, including vehicular traffic and the SPRINTER were determined to be less than significant. The project is consistent with this policy.
Goal N-2,
Policy N-2.2
Promote coordinated site planning and traffic
control measures that reduce traffic noise on
noise-sensitive land uses.
A noise study was prepared for the project (Appendix K) and summarized in Section
3.9, (Noise), of the EIR. There is a potential for offsite noise impacts related to rock drilling and rock crushing. Implementation of mitigation measures MM-N-1 and MM- N-2 would reduce this potential impact to below a level of significance. All other
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy construction-related noise impacts were determined to be less than significant.
Operational noise impacts were determined to be less than significant. The analysis considered the influence of adjacent roadway noise and the SPRINTER rail line. The project is consistent with this policy.
Goal N-2,
Policy N-2.3
Advocate the use of alternative transportation
modes such as walking, bicycling, mass transit,
and non-combustible engine vehicles to reduce
traffic noise.
The project’s internal pedestrian circulation network would connect to the existing sidewalk on Woodward Street. The project is near NCTD bus stops on E. Mission Road and is 0.1 miles from the SPRINTER rail station at San Marcos Civic Center. The project is consistent with this policy.
Goal N-3 Control non-transportation-related noise from
commercial, industrial, construction, and other
sources on noise sensitive land uses.
The nearest noise-sensitive land uses are the residences to the south, east and north. As analyzed in Section 3.9, (Noise), there is a potential for significant noise impacts related to rock drilling for blasting activities and rock crushing during project construction. Implementation of mitigation measures MM-N-1 and MM-N-2 would reduce these potential impacts to below a level of significance. The project is consistent with this goal.
Goal N-3,
Policy N-3.1
When adjacent to noise sensitive receptors,
require developers and contractors to employ
noise reduction techniques during construction
and maintenance operations.
The nearest noise-sensitive land uses are the residences to the south, east and north. As analyzed in Section 3.9, (Noise), there is a potential for significant noise impacts related to rock drilling for blasting activities and rock crushing during project construction. Implementation of mitigation measures MM-N-1 and MM-N-2 would reduce these potential impacts to below a level of significance.. No other construction-related noise impacts were identified for the project. The project is consistent with this policy.
Goal N-3,
Policy N-3.2
Limit the hours of construction and
maintenance operations located adjacent to
noise-sensitive land uses.
Construction activities would comply with the City’s Municipal Code requirement and all construction activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. No construction activities would occur on weekends or holidays. No construction-related noise impacts were identified for the project. The project is consistent with this policy.
Housing Element
Goal H-1 Provide a broad range of housing opportunities with emphasis on providing housing which
meets the special needs of the community.
The project would construct 46 residential duplex units. While no affordable units are proposed as part of the project, the project applicant would pay in-lieu fees for affordable housing which would be made available to affordable housing developers for projects in the City. The project is consistent with this goal.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal H-1,
Policy 1.1/
Goal EJ-4,
Policy EJ-4.5
Designate land for a variety of residential
densities sufficient to meet the housing needs
for a variety of household sizes and income
levels, with higher densities being focused in
the vicinity of transit stops and in proximity to
significant concentrations of employment
opportunities.
The project would construct 46 residential duplex units. The project site is within 0.1 miles of the Civic Center SPRINTER station and there are bus stops nearby on Mission Road. The project is consistent with this policy.
Goal H-4,
Policy 4.4
Balance the need to protect and preserve the
natural environment with the need to provide
additional housing and employment
opportunities.
The project has been designed to consolidate development within the project area, this allows for less habitat impact and the ability to preserve portions of the project site within an open space easement. The project site has been identified as an area proposed for development in the MHCP and the San Marcos Subarea Plan.
Additionally, Section 4.0, (Alternatives), provides a range of alternative development scenarios, including a no development alternative, considered for the project site.
The project is consistent with the policy.
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3.9 Noise
Introduction
This section addresses the potential noise effects resulting from the construction of the project and analyzes the noise compatibility of the project site with surrounding land uses. The analysis is based on the following report, which is included as Appendix K of the Environmental Impact Report (EIR):9 • Noise Assessment, Woodward 46 Specific Plan, SP22 -0005, SP22-0006, GPA22-0004, MFSD22-0005, TSM22-0004, City of San Marcos , prepared by LDN Consulting, January 7, 2025 (LDN 2025)
In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to have an adverse impact resulting from excessive noise levels from being located within the vicinity of a private airstrip or within two miles of a public airport.
Therefore, this issue is not discussed further in this section. Section 5.11, Environmental Effects Found Not to Be Significant – Noise of the EIR provides additional information on this topic.
Table 3.9-1 summarizes the project- and cumulative-level noise impacts, by threshold.
Table 3.9-1. Noise Summary of Impacts
Threshold of Significance Project Direct
Impact
Project
Cumulative
Impact
Impact After
Mitigation
#1 – Generation of a substantial
temporary or permanent increase in
ambient noise levels in the vicinity of the
project in excess of standards
established in the location general plan
or noise ordinance, or applicable
standards of other agencies.
Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant
#2 - Generation of excessive
groundborne vibration or groundborne
noise levels.
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
3.9.1 Existing Conditions
This section provides background on noise analysis and a description of the existing noise environment on the project site and surrounding area. This section also details the results of the ambient noise monitoring conducted by LDN Consulting on July 14, 2023 between 12:00 PM and 1:00 PM.
9 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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Background
Noise
Noise is generally defined as “unwanted sound” that interferes with normal activities. Excessive levels of noise can cause hearing loss, although the principal human response to environmental noise is annoyance. Noise is measured on a logarithmic scale of sound pressure level known as decibel (dB).
A-weighted decibels (dBA) approximate the subjective response of the human ear to broad frequency noise sources by discriminating against very low and very high frequencies of the audible spectrum.
They are adjusted to reflect only frequencies audible to the human ear. Equivalent sound level (Leq) is the noise metric used to collect short-term noise level measurement samples. It represents a steady state sound level containing the same total energy as a time varying signal over a given sample period, with Lmax and Lmin as the maximum and minimum, respectively. Community receptors are more sensitive to unwanted noise intrusion during the evening and at night. State law requires that, for some planning purposes, an a rtificial dBA increment be added to quiet time noise levels in a 24- hour A- weighted average noise descriptor called the Community Noise Equivalent Level (CNEL). In general, a change of 10 dBA is perceived as twice as loud (i.e., 65 dBA sounds twice as loud as 55 dBA to a human ear), a 5 dBA change in community noise levels is clearly noticeable, and a 3 dBA change is the smallest increment that is perceivable by most people. Changes of 1 to 2 dBA are not usually detectable by the human ear.
The decibel level of a sound decreases (or attenuates) exponentially as the distance from the source of that sound increases. For a single point source, such as a piece of mechanical equipment, the sound level normally decreases by about 6 dBA for each dou bling of distance from the source. Sound that originates from a linear, or “line” source, such as a heavily traveled traffic corridor, attenuates by approximately 3 dBA per doubling of distance, provided that the surrounding site conditions lack ground effects or obstacles that either scatter or reflect noise.
Surrounding site conditions, meteorological conditions, and the presence of manmade obstacles such as buildings and barriers may also reduce noise at the location of a receiver. For example, vegetation and loose soils may either absorb or scatter the sound from roadways, yielding sound attenuation rates in environments with these major ground effects that are as high as 4.5 dBA for each doubling of distance (compared to 3 dBA without major ground effects). In addition, barriers between a noise source and a receiver can substantially reduce noise levels at the receiver. A barrier that breaks the line of sight between a source and a receiver will typically result in at least 5 dBA of noise reduction.
Taller barriers will provide increased noise reduction.
Vibration
Vibration is an oscillatory motion through a solid medium in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. Human response to vibration is best approximated by the vibration velocity level.
Heavy equipment operation, including stationary equipment that produces substantial oscillation or construction equipment that causes percussive action against the ground surface, may be perceived by building occupants as perceptible vibration known as “st ructureborne/groundborne” vibration.
Vibration in buildings is typically perceived as rattling of windows or items on shelves or the motion of building surfaces. The vibration of building surfaces can also be radiated as sound and heard as a low- frequency rumbling noise, known as groundborne noise. Although the perceived vibration from such equipment operation can be intrusive to building occupants, the vibration is seldom of sufficient
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magnitude to cause even minor cosmetic damage to buildings unless the receptors are in proximity to heavy equipment.
Vibration energy spreads out as it travels through the ground, causing the vibration amplitude to rapidly decrease with distance away from the source. Soil properties also affect the propagation of vibration.
Man-made vibration issues are, therefore, usually confined to short distances from the source (i.e., 50 feet or less).
Vibration amplitudes are usually described in terms of peak levels, as in peak particle velocity (PPV) in inches/second that correlates best with human perception. The particle velocity is the velocity of the soil particles resulting from a disturbance. Ag encies such as the California Department of Transportation (Caltrans) use the PPV descriptor because it correlates well with damage or complaints.
Caltrans estimates that the threshold of perception is approximately 0.006 inches/second PPV and the level at which continuous vibration begins to annoy people is approximately 0.010 inches/second PPV (Caltrans 2020).
Existing Noise Environment
The project site is currently vacant and does not contain any sources of noise or vibration generation.
The project site is located on Woodward Street between E. Mission Road and Vineyard Road. The project vicinity is developed primarily with residential uses. with a mix of commercial, office and residential uses. Sources of noise in the surrounding area are primarily from traffic on Woodward Street, E. Mission Road, and the SPRINTER rail.
Existing ambient noise measurements were collected by LDN Consulting on July 14, 2023, at the southwestern corner of the project site adjacent to Woodward Street. The sound level meter and microphone were mounted on a tripod at approximately five feet above the ground and equipped with a windscreen during all measurements. The sound level meter was calibrated before and after the monitoring using a Larson-Davis calibrator, Model CAL 200. The monitoring location is shown in Figure
3.9-1.
The results of the noise level measurements are presented in Table 3.9-2. The measurements were taken on site to establish a baseline of the vehicle noise from Woodward Street, E. Mission Road and the SPRINTER rail line. The measurements were free of obstruction and had a direct line of sight to the roadways. As shown in Table 3.9-2, the overall sound level was found to be 55.3 dBA Leq.
Table 3.9-2. Measured Ambient Noise Levels
Measurement
Identification Description Date/Time
Noise Levels (dBA Leq)
Leq Lmax Lmin L10 L50 L90
ML 1 Woodward
Street
July 23, 2023
12:00 PM to 1:00 PM
55.3 66.7 48.4 58.9 54.8 50.5
Source: LDN 2025.
3.9.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to noise, including federal, state, and local guidelines.
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Federal
Federal Bodies
Title 49 Chapter 65 of the United States Code of Federal Regulations provides for the regulation of noise to protect the public health, safety, and welfare. The Federal Highway Administration (FHWA); Federal Rail Administration and Federal Transit Administ ration (FTA); and the Federal Aviation Administration, respectively, regulate roadway, rail, and aircraft.
Vibration and Groundborne Noise Impact Regulations
Publications of the FTA and Caltrans are two of the seminal works for the analysis of groundborne noise and vibration relating to transportation and construction-induced vibration. While the project is not subject to FTA or Caltrans regulations, these guidelines serve as a useful tool to evaluate vibration impacts. Caltrans guidelines recommend that a standard of 0.2 in/sec peak particle velocity (PPV) not be exceeded for the protection of normal residential buildings, and that 0.08 in/sec PPV not be exceeded for the protection of old or historically significant structures. With respect to human response within residential uses (i.e., annoyance, sleep disruption), FTA recommends a maximum acceptable vibration standard of 80 vibration velocity (VdB).
State
State noise standards regulate noise levels of motor vehicles, sound transmission through buildings, occupational noise control, and noise insulation. State regulatory guidelines governing noise levels generated by individual motor vehicles and guidelines governing occupational noise control are not applicable to planning efforts nor are these areas typically subject to California Environmental Quality Act (CEQA) analysis.
Office of Planning and Research General Plan Guidelines The State of California General Plan Guidelines, published by the Governor’s Office of Planning and Research, provides guidance for the acceptability of specific land use types within areas of specific noise exposure. The guidelines also present adjustment factors that may be used to arrive at noise acceptability standards that reflect the noise control goals of t he community, the community’s sensitivity to noise, and the community’s assessment of the relative importance of noise pollution.
General Plan gui delines are advisory in nature. Local jurisdictions, including San Marcos, have the responsibility to set specific noise standards based on local conditions.
State of California Code of Regulations Title 24
In 1974, the California Commission on Housing and Community Development adopted noise insulation standards for hotels, motels, dormitories, and multi -family residential buildings (Title 24, Part 2, California Code of Regulations). Title 24 establishes stan dards for interior room noise (attributable to outside noise sources). The regulations also specify that acoustical studies must be prepared whenever a multi-family residential building or structure is proposed to be located near an existing or adopted fre eway route, expressway, parkway, major street, thoroughfare, rail line, rapid transit line, or industrial noise source, and where such noise source or sources create an exterior CNEL (or LDN) of 60 dBA or greater. Such acoustical analysis must demonstrate that the residence has been designed to limit intruding noise to an interior CNEL (or LDN) of at least 45 dBA [California’s Title 24 Noise Standards, Chap. 2-35].
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Local
City of San Marcos General Plan
The following are applicable goals and policies from the City of San Marcos General Plan, Noise Element (GPNE):
• Goal N-1: Promote a pattern of land uses compatible with current and future noise levels. o Policy N -1.1: Address the potential for excessive noise levels when making land use planning decisions in accordance with Table 7-3 Land Use Compatibility Noise Standards. o Policy N-1.2: Ensure that acceptable noise levels are maintained near noise-sensitive uses. o Policy N-1.3: Incorporate design features into residential land use projects that can be used to shield residents from excessive noise. Design features may include, but are not limited to: berms, walls, and sound attenuating architectural design and constr uction methods.
o Policy N-1.4: Require new development projects to provide barriers to reduce noise levels, or provide sufficient spatial buffers to separate excessive noise generating land uses and noise-sensitive land uses.
o Policy N-1.5: Require an acoustical study for proposed developments in areas where the existing and projected noise level exceeds or would exceed the Normally Acceptable levels identified in Table 7-3.
• Goal N-2: Control transportation-related noise from traffic, rail, and aviation sources near noise sensitive land uses.
o Policy N -2.1: Encourage only noise -compatible land uses along existing and future roadways, highways, and freeways.
o Policy N-2.2: Promote coordinated site planning and traffic control measures that reduce traffic noise on noise-sensitive land uses.
o Policy N -2.3: Advocate the use of alternative transportation modes such as walking, bicycling, mass transit, and non-combustible engine vehicles to reduce traffic noise. • Goal N-3: Control non-transportation-related noise from commercial, industrial, construction, and other sources on noise sensitive land uses.
o Policy N -3.1: When adjacent to noise sensitive receptors, require developers and contractors to employ noise reduction techniques during construction and maintenance operations.
o Policy N-3.2: Limit the hours of construction and maintenance operations located adjacent to noise-sensitive land uses.
The following is an applicable goal and policy from the City of San Marcos General Plan, Safety Element:
• Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan. o Policy S-7.1: Record an overflight notification document in association with the approval of any new residential land use within the AIA overflight notification area consistent with the ALUCP.
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The following is an applicable goal and policy from the City of San Marcos General Plan, Environmental Justice Element:
• Goal EJ-4: Foster healthy living conditions for people of all backgrounds and incomes o Policy EJ-4.11: Incorporate design features into residential use projects that can be used to shield residents from excessive noise. Design features may include, but are not limited to: berms, walls and sound attenuating architectural design and construction methods.
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As detailed in Table 3.8-12 in Section 3.8 (Land Use and Planning), the project is consistent with the applicable goals and policies.
City of San Marcos Municipal Code
Chapter 10.24 (Noise)
Chapter 10.24 of the San Marcos Municipal Code prohibits loud, annoying, or unnecessary noises.
However, the Noise Ordinance does not specifically provide quantified property line noise level limits.
Section 10.24.020 provides definitions for and examples of prohibited noise sources. Included in the list of prohibited noise sources is demolition and building construction activities that occur Monday through Friday before 7:00 AM and after 6:00 PM or on Saturdays before 8:00 AM or after 5:00 PM.
No grading, extraction or construction is allowed on Sundays or City holidays. The noise ordinance does not include a quantified noise level limit for construction noise. Section 10.24.030 describes the standards for how sound is assessed. Commonly, the City has utilized Section 36.409 of the County of San Diego’s Noise Ordinance noise limit of 75 dBA Leq (8-hour) for construction activities.
Section 17.32.180 (Grading Operation Restrictions)
City of San Marcos Municipal Code Section 17.32.180 addresses the time limits that apply to grading, extraction, and blasting between 7:00 AM and 4:30 PM Monday through Friday. Grading, extraction, or related earth moving is not allowed in the City on the weekends or holidays. The Municipal Code does not set noise limits on construction activities. Commonly, the City has utilized the County of San Diego’s Noise Ordinance noise limit of 75 dBA for construction activities.
The Noise Element of the County of San Diego General Plan establishes limitations on sound levels to be received by various land uses. New development may cause an existing noise sensitive land use (NSLU) to be affected by noise caused by the new development, or it may create or locate a NSLU in such a place that it is affected by noise. The Noise Element identifies airports and traffic on public roadways as the major sources of noise. The County Noise Element establishes the exterior noise level standards and provides interior standards and definitions. If the exterior noise level would exceed 75 dBA CNEL, new development would not be approved.
Section 17.60.06 (Blasting Operations Procedures)
The City of San Marcos Section 17.60.06 of the City’s Municipal Code states that all blasting operations within the City of San Marcos are prohibited unless a Certificate of Authorization is first obtained from the San Marcos Building Director and an Opera tions Permit issued by the Fire Chief.
Additional relevant sections of the City’s Code for Blasting are provided below:
• The general contractor or property owner/developer shall give reasonable notice in writing at the time of issuance of a building permit, grading permit or encroachment license to all
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residences or businesses within 600 feet of any potential blast location. The notice shall be in a form approved by the Building Director. Any resident or business receiving such notice may request of the Building Director that a notice of impending blasti ng be given by the blaster at the time of the 12-hour advance notice given to the Building Director. The general contractor or property owner/developer shall make all reasonable efforts to contact any and all parties requesting the second notice.
• The blaster shall file a written certification with the Building Director certifying that the general notice required by Section 17.60.060(b) has been given. The certificate shall include addresses and date(s) of notification. A copy shall be retained on file at the Building Division. • Inspections of all structures within 300 feet of the blast site shall be made before blasting operations. The persons inspecting shall obtain the permission of the building owner to conduct an inspection. The inspections shall be done by a registered struc tural engineer employed by the blaster or project contractor. The inspection shall be only for the purpose of determining the existence of any visible or reasonably recognizable pre -existing defects or damage in any structure. Inspection refusal shall be at the discretion of the property owner. • Blasting shall only be permitted between the hours of 9:00 a.m. and 4:00 p.m. during any weekday, Monday through Friday, exclusive of City recognized holidays unless special circumstances warrant another time or day and special approval is granted by the B uilding Director and Fire Chief.
Chapter 20.300 (Zoning Ordinance)
The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.
Section 20.300, Performance Standards, within the Zoning Ordinance identifies noise regulations to prohibit unnecessary, excessive, and annoying noises. Table 20.300-4, included below as Table 3.9-3 identifies allowable noise levels (dBA) by zone type. For multifamily residential , the allowable noise level, as measured at the property line is 65 dBA from 7:00 AM to 10:00 PM. and 55 dBA from 10:00 PM to 7:00 AM. Increases in allowable noise levels listed in Table 3.9 -3 may be permitted in
accordance with the standards outlined in Table 3.9-4.
1 Noise shall be measured with a sound-level meter that meets the standards of the American National Standards Institute (ANSI) (Section S1.4 -1979, Type 1 or Type 2). Noise levels shall be measured in decibels at the property line of the receptor property, and at least five (5) feet above the ground and ten (10) feet from the nearest structure or wall. The unit of measure shall be designated as an A-weighted decibel (dBA) Leq standard. A calibration check shall be made of the instrument at the time any noise measurement is made. 2 No person shall create or allow the creation of exterior noise that causes the noise level to exceed the noise standards established by Table 20.300-4 (shown as Table 3.9-3). Increases in allowable noise levels listed in Table 20.300-4 (shown as Table 3.9-3) may be permitted in accordance with the standards outlined in Table 20.300- 5 (shown as Table 3.9-4). 3 No person shall create nor allow the creation of noise that causes the interior noise level when measured within a dwelling unit to exceed forty-five (45) dBA at any time, except as permitted by Table 20.300-6 (shown as Table 3.9-5).
4 Use of compressors or other equipment, including vents, ducts, and conduits, but excluding window or wall-mounted air conditioners, that are located outside of the exterior walls of any building, shall be enclosed within a permanent, noncombustible, view-obscuring enclosure to ensure that the equipment does not emit noise in excess of the ANSI standards.
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Table 3.9-3. Exterior Noise Standards by Zone
Zone Allowable Noise Level (dBA Leq) Measured from the
Property Line
Single-Family Residential (A, R-1, R-2)1,2
7:00 AM and 10:00 PM (daytime) 60
10:00 PM and 7:00 AM (overnight) 50
Multifamily Residential (R-3) (1)(2)
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 55
Commercial (C, O-P, SR)(3)
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 55
Industrial
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 60
Source: City of San Marcos 2023 (Table 20.300-4)
Notes: (1) For single-family detached dwelling units, the "exterior noise level" is defined as the noise level measured at an outdoor living area which adjoins and is on the same lot as the dwelling, and which contains at least the following minimum net lot area: (i) for lots less than 4,000 square feet in area, the exterior area shall include 400 s quare feet, (ii) for lots between 4,000 square feet to 10 acres in area, the exterior area shall include 10 percent of the lot area; (iii) for lots over 10 acres in area, the exterior area shall include 1 acre. (2) For all other residential land uses, "exterior noise level" is defined as noise measured at exterior areas which are provided for private or group usable open space purposes. "Private Usable Open Space" is defined as usable open space intended for use of occupants of one dwelling unit, normally including yards, decks, and balconies.
When the noise limit for Private Usable Open Space cannot be met, then a Group Usable Open Space that meets the exterior noise level standard shall be provided. "Group Usabl e Open Space" is defined as usable open space intended for common use by occupants of a development, either privately owned and maintained or dedicated to a public agency, normally including swimming pools, recreation courts, patios, open landscaped areas, and greenbelts with pedestrian walkways and equestrian and bicycle trails, but not including off -street parking and loading areas or driveways.
(3) For non-residential noise sensitive land uses, exterior noise level is defined as noise measured at the exterior area provided for public use.
Table 3.9-4. Permitted Increase in Noise Levels
Permitted Increase (dBA) Duration
(cumulative minutes per hour)
5 15
10 5
15 1
20 Less than 1 minute
Source: City of San Marcos 2023 (Table 20.300-5).
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Table 3.9-5. Permitted Increase in Interior Noise Levels Permitted Increase (dBA) Duration
(cumulative minutes per hour)
5 1
10 Less than 1 minute
Source: City of San Marcos 2023 (Table 20.300-6).
3.9.3 Thresholds of Significance
According to Appendix G of the California Environmental Quality Act (CEQA) Guidelines, noise impacts are considered potentially significant if they cause:
• Threshold #1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the location general plan or noise ordinance, or applicable standards of other agencies. • Threshold #2: Generation of excessive groundborne vibration or groundborne noise levels.
The term “substantial increase” is not defined by any responsible agency. Under ambient conditions, people generally do not perceive that noise has clearly changed until there is a 3 dBA difference.
Therefore, a threshold of 3 dBA is commonly used to define “substantial increase,” as it is noticeable to humans under typical ambient conditions.
As identified above, impacts related to being in the vicinity of a private airstrip or airport land use plan are not discussed in this section. Section 5. 11, Environmental Effects Found Not to Be Significant – Noise, provides additional information on this topic.
San Marcos Noise Impact Thresholds
Construction Noise Standards
The City of San Marcos Municipal Code does not set noise limits on construction activities. Commonly, the City utilizes the County of San Diego’s Noise Ordinance Section 36.410 noise limit of 75 dBA at any existing sensitive receptor for construction activities. The Municipal Code Section 17.32.180 does address and limit grading and extraction activities between the hours of 7:00 AM and 4:30 PM, Monday through Friday, and no grading or earth moving activities are allowed on the weekends or holidays.
As mentioned, typically, the threshold for determining whether construction noise is significant is 75 dBA. However, in the past, the City of San Marcos has applied the operational noise standards to rock crushing activities when operating on a longer -term basis. The City’s 60 dBA Leq operational noise - standard at the nearest single-family residences has been applied.
Ground Vibration Standards
The City of San Marcos does not have adopted vibration criteria for construction. The FTA provides criteria for acceptable levels of groundborne vibration for various types of buildings that are sensitive to vibration. For the purpose of identifying potential project -related vibration impacts resulting from
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the proposed project, the FTA criteria was used. Table 3.9-6 shows the FTA groundborne vibration and noise impact criteria for human annoyance.
Table 3.9-6. Groundborne Vibration and Noise Impact Criteria (Human Annoyance)
Groundborne Vibration
Impact Levels
(VdB re 1 microinch/second)
Groundborne Noise Impact Levels
(dB re 20 micropascals)
Frequent
Events1
Occasiona
l Events2
Infrequent
Events3
Frequent
Events1
Occasiona
l Events2
Infrequent
Events3
Category 1: Buildings where low
ambient vibration is essential for
interior operations.
65 VdB4 65 VdB4 65 VdB4 N/A4 N/A4 N/A4
Category 2: Residences and
buildings where people normally
sleep.
72 VdB 75 VdB 80 VdB 35 dBA 38 dBA 43 dBA
Category 3: Institutional land uses
with primarily daytime use.
75 VdB 78 VdB 83 VdB 40 dBA 43 dBA 48 dBA
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.
1. “Frequent Events” are defined as more than 70 vibration events per day. Most rapid transit projects fall into this category.
2. “Occasional Events” are defined as between 30 and 70 vibration events of the same source per day. Most commuter trunk lines have this many operations.
3. “Infrequent Events” are defined as fewer than 30 vibration events of the same kind per day. This category includes most commuter rail branch lines.
4. This criterion limit is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes. Vibration-sensitive manufacturing or research would require detailed evaluation to define the acceptable vibration levels. Ensuring lower vibration levels in a building often requires special design of the HVAC systems and stiffened floors.
5. Vibration-sensitive equipment is not sensitive to groundborne noise.
In addition to the vibration annoyance standards presented in Table 3.9-6, the FTA also applies the following standards for construction vibration damage. As shown in Table 3.9-7, structural damage is possible for typical residential construction when the PPV exceeds 0.2 inch per second (in/sec). This criterion is the threshold at which there is a risk of damage to normal dwellings.
Table 3.9-7. Groundborne Vibration Impact Criteria (Structural Damage) Building Category PPV (in/sec) VdB
I. Reinforced-concrete, steel, or timber (no plaster) 0.5 102 II. Engineered concrete and masonry (no plaster) 0.3 98 III. Non-engineered timber and masonry buildings 0.2 94 IV. Buildings extremely susceptible to vibration damage 0.12 90 Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment, September 2018.
Note: RMS = Root Mean Square (RMS) velocity calculated from vibration level (VdB) using the reference of one microinch/second.
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Transportation Noise Standards
To control transportation -related noise sources such as arterial roads, freeways, airports, and railroads, the City of San Marcos has established guidelines for acceptable community noise levels in the Noise Element of the General Plan (Table 7-3 of the Ge neral Plan Noise Element). For noise sensitive rural and single-family residential uses, schools, libraries, parks, and recreational areas, the City Noise Element requires an exterior noise level of less than 60 dBA CNEL for outdoor usable areas, such as y ard and patio areas. For multi -family developments, the standard is 65 dBA CNEL and a standard of 70 dBA CNEL is typically applied to commercial uses. The City has also established an interior noise limit of 45 dBA CNEL for all residential uses. Noise sensitive indoor spaces are subject to compliance with CCR Title 24 noise insulation standards demonstrating a 45 dBA CNEL interior noise level with all windows of the structure closed.
For this analysis, a direct roadway noise impact would be considered significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and increases noise levels above an unacceptable noise level per the City’s General Plan in the area adjacent to the roadway segment.
Operational Noise Standards
The City noise regulations that apply to the proposed project are found in Chapter 20.300 Site Planning and General Development Standards of the City Municipal Code. These regulations aim to prohibit unnecessary, excessive, and annoying noises from all sources, as certain noise levels are detrimental to the health and welfare of individuals. The standards of this section and of Chapter 10.24 Noise of the Municipal Code apply to all land uses unless otherwise specified. No person shall create or allow the creation of exterior noise that causes the noise level to exceed the noise standards established by Table 20.300-4 of the Municipal Code. See Table 3.9-3 earlier in this section.
The City Ordinance limits noise generation in multi-family zones to 65 dB Leq (one -hour average) between the hours of 7 am and 10 pm and 55 dB Leq between the hours of 10:00 PM and 7:00 AM as measured at the project property line as shown above in Table 3.9-3. Per the GPNE, noise standards for multi-family residential areas are higher than single-family residential areas because they typically reflect a more urban environment (GPNE, pg. 7- 10). The project vicinity includes single -family residential neighborhoods to the north and east, multi -family residential developments to the south, and undeveloped land to the west across Woodward Street. Therefore, the City Ordinance’s 60 dBA hourly noise standard during the daytime hours between 7:00 AM and 10:00 PM and 50 dBA standard during the nighttime hours between 10 p.m. and 7 a.m. would apply at the single family residential neighborhoods to the north and east and the 65 dBA hourly noise standard for daytime hours and 55 dBA hourly noise standard for nighttime hours would apply to the multi-family residential developments to the south.
3.9.4 Project Impact Analysis
Construction and operation of the project would have the potential to result in short term and long term increases in noise on the project site and in the project vicinity. A s part of the project design features, to ensure compliance with CCR Title 24, a final noise assessment is required prior to the issuance of the first building permit . The final noise assessment would identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed -window-condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).
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Threshold #1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the location general plan or noise ordinance, or applicable standards of other agencies.
Construction Noise
This section addresses the construction noise impacts associated with the project to determine if they would result in the exposure of persons to or generation of noise level in excess of applicable noise standards. Construction noise represents a short -term impact on the ambient noise levels, primarily from construction equipment. Grading activities typically represent one of the highest potential sources for noise impacts. The most effective method of controlling construction noise is through local control of construction hours and by limiting the hours of construction to normal weekday working hours. As stated above, the City of San Marcos Municipal Code does not set noise limits on construction activities. Commonly, the City utilizes the County of San Diego’s Noise Ordinance Section
36.410 noise limit of 75 dBA at any existing sensitive receptor for construction activities.
The U.S. Environmental Protection Agency (USEPA) has compiled data regarding the noise generating characteristics of specific types of construction equipment. Noise levels generated by heavy construction equipment can range from 60 dBA to in excess of 100 dBA when measured at 50 feet.
However, these noise levels diminish rapidly with distance from the construction site at a rate of approximately 6 dBA per doubling of distance. For example, a noise level of 75 dBA measured at 50 feet from the noise source to the receptor would be reduced to 69 dBA at 100 feet from the source to the receptor and reduced to 63 dBA at 200 feet from the source.
LDN used a point-source noise prediction model to calculate the expected construction noise impacts.
The essential model input data for these performance equations include the source levels of each type of equipment, relative source to receiver horizontal and vertical separations, the amount of time the equipment is operating in a given day, also referred to as the duty -cycle and any transmission loss from topography or barriers (LDN 2025).
The equipment needed for the most intensive grading activities would consist of a tractor/backhoe, a large bulldozer, loader/grader, excavator, water truck, paver/blade, drill rig and a hoe ram. Based on the USEPA noise emissions, empirical data and the am ount of equipment needed, worst case noise levels from the construction equipment for site preparation would occur during grading operations.
The project vicinity includes single-family residential neighborhoods to the north and east, multi-family residential developments to the south, and undeveloped land to the west across Woodward Street.
Existing ambient noise levels were determined to be 55.3 dBA Leq.
Grading
The grading activities would consist of the preparation of site access, internal roadways, parking, and the finished pads. The equipment would be spread out over the project site from distances near the occupied property lines to distances of 400 feet or more away. Based upon the site plan, the majority of the grading operations, on average, would occur more than 2 80 feet from the property lines. This means that most of the time the average distance from all the equipment to the nearest property line would be 280 feet. It should be noted that construction activities would be on average approximately 140 feet from the residences to the east. However, the homes are elevated over 50- feet above the proposed pads. Therefore, noise levels would be reduced by a minimum of 5 dBA due to the topography blocking line of sight to the existing homes.
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As shown in Table 3.9-8, at an average distance of 2 80 feet from the construction activities to the nearest property line would result in a noise attenuation of 15 dBA without shielding. This results in a property line noise level of 74.7dBA. Given this, the noise levels would comply with the 75 dBA Leq (8- hour) standard at the property lines. Additionally, all equipment would be properly fitted with mufflers and all staging and maintenance would be conducted as far away from the existing residence as possible.
Table 3.9-8. Construction Noise Levels
Equipment Type Quantity Used Source @ 50 Feet
(dBA)
Cumulative Noise
Level @ 50 Feet (dBA)
Tractor/Backhoe 1 72 72.0
Dozer D9 Cat 1 74 74.0
Loader/Grader 1 73 73.0
Excavator 1 72 72.0
Water Truck 1 70 70.0
Paver/Blade 1 75 75.0
Rock Drill Rig 1 85 85.0
Hoe Ram 1 87 87.0
Rock Crusher 1 78 78.0
Cumulative Level 89.7
Distance to Sensitive Uses (feet) 280
Noise Reduction due to Distance -15.0
Property Line Noise Level 74.7
Source: LDN 2025.
Grading Materials Export
Earthwork activities include 41,989 cubic yards (CY) of cut volume. With over-excavation and bulking, the total fill volume would be 50,270 CY, for a difference of 8,281 CY. If suitable, the excess material would be used as wall backfill and the site would balance. If it is not suitable, it would be exported from the site. To be conservative, the environmental analysis assumes the materials would be exported. Assuming 15 cy truck trips, that would equate to 553 trips. These trips would be spread over approximately 23 working days for 24 trips per day associated with export.
Noise level changes greater than 3 dBA are often identified as audible and considered potentially significant, while changes less than 1 dBA would not be discernible to local residents. In the range of 1 to 3 dBA, residents who are very sensitive to noise may perceive a slight change. Community noise exposures are typically over a long time period rather than the immediate comparison made in a laboratory situation. Therefore, the level at which changes in community noise levels become discernible is likely greater than 1 dBA, and 3 dBA appears to be appropriate for most people. For the purposes for this analysis, direct and cumulative roadway noise impacts would be considered
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significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and if the project increases noise levels above an unacceptable noise level per the City’s General Plan in the area adjacent to the roadway segment. Typically, it requires a project to double (or add 100%) to the traffic volumes to result in a 3 dBA CNEL increase, which is considered a potential impact. Based on a current traffic volume of approximately 5,388 average daily traffic (ADT) or more on the roadways along the site and along the anticipated haul route, the additional 24 trucks per day would add less than 0.5 dBA to the overall noise level. This is well below a 3 dBA increase that is considered a potential impact. Negligible noise impacts are anticipated at the residential uses that are located along the roadways due to the low volume of trucks. Impacts would be less than significant.
Rock Drilling and Blasting
Due to bedrock conditions on the project site, rock drilling and b lasting may be required during the project grading and site preparation activities. The project would comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday.
During project grading and site preparation activities, areas of the project site that require deeper cuts and where the native material is not easily rippable (graded) may require blasting and the use of a rock drill. The rock drill would be moved around the site on an as needed basis dependent upon the site characteristics. The use of a rock drill would occur independently of all other proposed equipment.
The drilling and blasting activities would occur in one area and then the grading equipment would relocate or remove the debris. To determine the worst-case noise levels from the drilling operations, it was assumed that the noise level from the rock drill would be 85 dBA at 50 feet. Utilizing a 6 dBA reduction per doubling of distance, the rock drill would need to be located at an average distance of 160 feet from any property line to comply with the 75 dBA standard as shown in Table 3.9-9.
Rock drilling and blasting would occur on an as-needed basis on site. In the event that the rock drill is staged within 160 feet of any occupied noise sensitive land use, a potentially significant impact (N-1) would occur.
• Impact N-1 Due to temporary rock drilling and blasting activities during construction, the proposed project has the potential to create noise levels in excess of the 75 dBA standard if rock drilling equipment is staged closer than 160 feet to the nearest property line.
Table 3.9-9. Construction Noise Levels from Rock Drill
Construction
Equipment Quantity
Source Level
@ 50 Feet
(dBA)
Duty Cycle
(Hours/Day)
Noise Level @ 50 Feet
(dBA)
Rock Drill 1 85 8 85.0
Noise Reduction Needed to Comply -10.0
Distance Required to Reduce Noise Levels 160
Nearest Property Line Noise Level 74.9
Source: LDN 2025.
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Rock Crushing
The project’s requested approvals include a Conditional Use Permit, which would allow for the use of a temporary rock crusher. Rock crushing would occur between the hours of 7:00 AM and 4:00 PM. As shown in Figure 3.9-2, the rock crushing equipment is proposed to be located in the central portion of the site at the proposed building pads, over 300 feet from the nearest residences to the east, over 530 feet from the residences to the south, and over 660 feet from the residences to the north . Based on empirical data collected at the existing Mission 316 residential development to the south from a similar rock crusher, noise levels ranged between 70-72 dBA at 100 feet ( LDN 2021). Therefore, a worst-case noise level of 72 dBA at 100 feet was used to analyze noise levels from rock crushing equipment (LDN 2025). The analysis assumed the project would use a Thunderbird Hazemag #CP300 or equivalent rock crusher. Typically, the threshold for determining whether construction noise is significant is 75 dBA. However, in the case of rock crushing, the City has applied the operational noise standard to rock crushing activities when operating on a longer -term basis. T he exterior noise standards by zone as shown in Table 3.9 -3 have been applied in the analysis. Because the closest sensitive receptor to the rock crusher would be the single -family residences located 300 feet to the east, the daytime threshold of 60 dBA Leq has been applied to determine significance.
It was determined that the noise levels of the rock crusher would be reduced by a minimum of 5 dBA due to the topography blocking line of sight to the existing single-family homes to the east. As can be seen in Table 3.9-10, based on the proposed location of the rock crusher shown in Figure 3.9-2, the anticipated noise levels (57.5 dBA) at the eastern residentia l property line would be below the City’s 75dBA Leq construction noise standard and below the applied 60 dBA Leq operational noise standard for single family residential.
The rock crushing equipment would be located over 530 feet from residences to the south and over 660 feet from the residences to the north. No reductions were taken due to topography. As can be seen in
Table 3.9-11, at 530-feet, the noise levels would be reduced to 57.5 dBA and would be below the City’s 75 dBA Leq construction noise standard and blow the applied 60 dBA Leq operational noise standard for single family residential.
However, if the rock crusher is located within 75 feet of a single -family residential use without shielding, noise levels may exceed the construction noise threshold of 75 dBA Leq. Additionally, in the event that the rock crusher is staged within 400 feet of a residential use without shielding, noise levels may exceed the applied operational threshold of 60 dBA at any existing single family residential use, 65 dBA for any multifamily use or 70 dBA at a commercial use. This represents a potentially significant
impact (Impact N-2) and mitigation is required.
• Impact N-2 Due to temporary rock crushing activities, the proposed project has the potential to create noise levels in excess of the 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.
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Table 3.9-10. Rock Crushing Noise Levels (East)
Equipment Type Quantity
Used
Source @ 100
Feet (dBA)
Duty Cycle
(hrs/day)
Cumulative Noise Level @ 50
Feet (dBA)
Thunderbird Hazemag
#CP300 1 72 8 72.0
Distance to Sensitive Use 300
Noise Reduction due to Distance -9.5
Noise Reduction due to Topography -5.0
Property Line Noise Level 57.5
Source: LDN 2025.
Table 3.9-11. Rock Crushing Noise Levels (South)
Equipment Type Quantity
Used
Source @ 100
Feet (dBA)
Duty Cycle
(hrs/day)
Cumulative Noise Level @ 50
Feet (dBA)
Thunderbird Hazemag
#CP300
1 72 8 72.0
Distance to Sensitive Use 530
Noise Reduction due to Distance -14.5
Property Line Noise Level 57.5
Source: LDN 2025.
Operational Noise
This section addresses the operational noise associated with the project to determine if it would result in the exposure of persons to or generation of noise level in excess of applicable noise standards.
Operational noise associated with the project would include traffic generated by the project that travels on area roadways as well as noise that is generated on the project site. Aside from vehicular trips associated with future residents, residential uses are not typically considered a substantial noise source. Operationally, noise is typically associated with unit-specific heating/cooling equipment or the sounds of human activity. Such equipment and activity is not typically characterized as a substantial noise source. Additionally, the future residences are over 200 feet from the nearest existing residences, with the distance providing additional attenuation.
Future Onsite Roadway and Railway Noise
Onsite Roadway Noise
To determine the future noise environment and impact potential resulting from increased traffic associated with the proposed project, the Sound32 model was utilized. The critical model input parameters, which determine the projected vehicular traffic noise levels, include vehicle travel speeds, the percentages of automobiles, medium trucks, and heavy trucks in the roadway volume, the site
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conditions, and the peak hour traffic volume. The peak hour traffic volumes range between six to 12 percent of the ADT and ten percent is generally acceptable for noise modeling.
Table 3.9-12 presents the roadway parameters used in the analysis including the peak traffic volumes, vehicle speeds, and the hourly traffic flow distribution (vehicle mix). The vehicle mix provides the hourly distribution percentages of automobile, medium trucks, and heavy trucks for input into the FHWA model. The Buildout conditions for E. Mission Road and Woodward Street include the future year 2050 traffic volume forecasts provided by the project traffic study (LLG 2023).
Table 3.9-12. Future Traffic Parameters
Roadway Average Daily
Traffic (ADT)1
Peak Hour
Volumes1
Modeled
Speeds
(MPH)
Vehicle Mix %2
Auto Medium
Trucks
Heavy
Trucks
E. Mission Road 21,827 2,183 45 96 2 2
Woodward Street 5,920 592 40 96 2 2
Source: LDN 2025.
Notes: (1) Peak hour volumes are Year 2050 volumes identified in the Local Transportation Analysis prepared by LLG, 2023.
(2) Typical City vehicle mix.
The required coordinate information necessary for the Sound32 model input was taken from the precise grading plans provided by Excel Engineering.. The grading plans were used to identify the pad elevations, roadway elevations, and the relationship between the noise source(s) and the outdoor receptor areas. To evaluate the potential noise impacts on the proposed development, outdoor observers were located throughout the site and placed five feet above the finished pad elevation. The modeled observer locations for the potential outdoor use areas are shown in Figure 3.9-3. Private
outdoor use areas would be provided by ground floor rear yards, second floor balconies, and rooftop decks which were modeled to determine if shielding/mitigation is required to reduce the noise levels below the City’s 65 dBA CNEL threshold (LDN 2025).
Onsite Rail Line Noise
The proposed project is located a minimum of 400 feet from the San Diego Northern Railroad (SDNR) consisting of SPRINTER service operated by the North County Transit District (NCTD). According to the City of San Marcos General Plan Noise Element, Figure 7 -2, the future 65 dBA CNEL noise contour from the anticipated increased rail activity, with no shielding, is located 130 feet from the centerline of the railroad. No reduction factor was taken for the building facades (LDN 2025).
Combined Future Onsite Noise Levels
Ground floor rear yards, upper floor balconies, and roof decks were modeled to determine if shielding/mitigation is required to reduce future exterior noise levels below the City’s 65 dBA CNEL threshold for multi -family developments. The noise levels determined for the roadway and train activities were combined to determine the overall combined noise levels at the proposed outdoor use areas, balconies, and rooftop decks. The resultant cumulative noise levels from the traffic and train activities are provided below in
Table 3.9-13 for each of the ground floor patios and upper floor areas.
As shown, the outdoor use areas would be in compliance with the City of San Marcos Noise standards of 65 dBA CNEL. Impacts would be less than significant.
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Table 3.9-13. Combined Future Exterior Noise Levels (Roadway and Railway) Receptor Number1
Unmitigated Noise
Levels from
Roadways (dBA
CNEL)
Unmitigated Noise
Levels from Train
(dBA CNEL)
Cumulative Noise
Levels at Ground
Floor (dBA CNEL)
Cumulative Noise
Levels at Upper
Floor (dBA
CNEL)2
1 62 60 64 64
2 62 59 63 63
3 61 58 63 63
4 61 57 62 62
5 60 57 62 62
6 60 56 61 61
7 63 60 65 --
8 62 59 64 --
Source: LDN 2025.
Notes: (1) Modeled Receptor Locations 1- 6 are residences. Modeled Receptor Locations 7 and 8 are outdoor space so do not have upper floor noise levels.
(2) Interior Noise Study required per City Guidelines if building façade is above 60 dBA CNEL.
Additionally, as part of the project design features described in Table 2 -2, to ensure compliance with CCR Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).
Project Related Offsite Transportation Noise
For the purposes for this analysis, direct and cumulative roadway noise impacts would be considered significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and if the project increases noise levels above an unacceptab le noise level per the City’s General Plan in the area adjacent to the roadway segment. To determine if direct or cumulative off -site noise level increases associated with the development of the proposed project would create noise impacts, the noise levels for the existing conditions were compared with the noise level increase of existing plus the proposed project. To be conservative, hard site conditions (concrete, asphalt, and hard pack dirt) were used to develop the noise contours and analyze noise impacts along all roadway segments.
Table 3.9-14 presents the comparison of the existing year with and without project related noise levels.
The overall roadway segment noise levels would not increase with the development of the project. The project would not create a direct noise increase of more than 3 dBA CNEL on any roadway segment.
Therefore, the project’s direct contributions to off -site roadway noise increases would not cause a significant impact to any existing or future noise sensitive land uses. Impacts would be less than
significant.
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Table 3.9-14.Existing vs. Existing Plus Project Noise Levels Roadway Roadway Segment
Existing Noise
Level @ 50-feet
(dBA CNEL)
Existing Plus
Project Noise
Level @ 50-feet
(dBA CNEL)
Project Related
Noise Level
Increase @ 50-
feet (dBA CNEL)
Mission Road Pico Avenue to
Woodward Street
69.9 69.9 0
Woodward Street
to Mission Villas
Road
72.2 72.2 0
San Marcos
Boulevard
Rancheros Drive
to Mission Road
69.8 69.9 0.1
Woodward Street E. Mission Road to
Project
65.3 65.6 0.3
Project to
Vineyard Road
65.3 65.3 0
Source: LDN 2025.
In summary, the proposed project has the potential to result in a substantial temporary increase in ambient noise during construction depending on the final location for the rock drilling and rock crushing equipment that is potentially significant (
Impacts N-1 and N-2). Mitigation is required and is
provided in Section 3.9.6. The project would not result in a permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the general plan or noise ordinance, or applicable standards of other agencies.
Threshold #2: Generation of excessive groundborne vibration or groundborne noise levels.
This section analyzes the potential for the project to expose a person to or generation of excessive vibration or groundborne noise. Proposed residential uses would not be characterized as creating excessive vibration during project operation. The noise modeling is based upon project construction details and schedule provided by the project applicant.
Grading
The nearest vibration-sensitive uses are the existing residences to the east, located 280 feet or more from the center of the proposed construction. Table 3.9-15 lists the average vibration levels that would be experienced at the nearest vibration sensitive land uses from temporary grading and site preparation activities.
The FTA has determined vibration levels that would cause annoyance to a substantial number of people and potential damage to building structures. The FTA criterion for vibration induced structural damage is 0.20 in/sec for the PPV. Project construction activities would result in PPV levels below the FTA’s criteria for vibration induced structural damage. Therefore, project construction activities would not result in vibration induced structural damage to residential buildings near the construction areas during regular construction activities. The FTA criterion for infrequent vibration induced annoyance is
80 VdB for residential uses. Grading activities would generate levels of vibration that would not exceed
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the FTA criteria for nuisance for nearby residential uses during regular construction activities. Short term grading impacts would be less than significant.
Table 3.9-15. Vibration Levels from General Construction Activities at Residential Receptors Equipment
Approximate
Velocity Level at
25 Feet
(VdB)
Approximate
PPV Level
at 25 Feet
(in/sec)
Approximate
Velocity Level at
280 Feet
(VdB)
Approximate
PPV Level at 280
Feet
(in/sec)
Small Bulldozer 58 0.003 26.5 0.0001
Jackhammer 79 0.035 47.5 0.0009
Loaded Trucks 86 0.076 54.5 0.0020
Large Bulldozer 87 0.089 55.5 0.0024
FTA Criteria 801 0.22
Significant Impact? No No
Source: LDN 2025.
1FTA criterion for infrequent vibration induced annoyance. 2 FTA criterion for vibration induced structural damage. 3PPV at Distance D = PPVref x (25/D)1.5
Blasting Vibration
Blasting for construction projects typically results in an RMS vibration velocity of about 100 VdB at 50 feet from the blast, based on FTA findings. This is equivalent to a PPV of about 0.4 inch per second.
Given attenuation of vibration velocities with di stance, if the blasting activity was located 160 feet from the nearest residence, the vibration and peak particle velocities at the nearest existing residence would be about 85 VdB and 0.07 inch per second, respectively. Based on the construction vibration damage criteria published by the FTA (Table 3.9-7), the threshold vibration levels for damage to "non- engineered timber and masonry buildings" are 94 VdB and 0.20 inch per second. Therefore, the effect of the blasting activity on nearby residential structures would be less than significant.
However, the
FTA human annoyance criterion of 80 VdB (for infrequent transit noise) would be exceeded when blasting occurred within about 250 feet of existing residences. If blasting is required within 250 feet of exist ing residences, the potential annoyance may not be completely avoided, but it can be minimized by following the City’s blasting procedures as stated above in Section 3 .9.2, including proper notice to residences. Short term blasting vibration impacts would be less than significant.
Train Vibration
Train vibration depends on the weight of the train, travel speed, the condition of the track and soil characteristics. The proposed project buildings would be more than 400 feet from the centerline of the tracks. The FTA Transit Noise and Vibration Impact Assessment Manual (FTA 2018) predicts that freight train vibration levels are as high as 73 VdB at 175 feet from the track centerline for a locomotive-powered freight train traveling at speeds of 50 miles per hour (MPH)and up to 62 VdB for commuter rail tr ain events at that speed. Therefore, the frequent commuter train activities will be below the 72 VdB frequent event annoyance thresholds as identified in Category 2 (residences and buildings where people normally sleep) of Table 3 .9-6. Additionally, due to the p roximity of the San Marcos Civic Center SPRINTER station, the commuter trains will be traveling at a slower speed of
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approximately 15 MPH as they enter and exit the station, which would reduce the vibration levels by 8 VdB. Therefore, the train activities would have a less than significant impact on the proposed project.
3.9.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to noise, the cumulative analysis is based upon a li st approach to determine the proposed project’s contributing effect on potential cumulative noise impacts.
Cumulative construction noise could occur if there are other projects under construction in the vicinity of the proposed project. Based upon the location of the project and the timing for development and location of the cumulative projects included in Table 2-4, a cumulative noise impact is not anticipated, and impacts would be less than significant.
To determine if cumulative off -site noise level increases associated with the development of the project and cumulative projects in the vicinity would create noise impacts, a cumulative noise analysis was conducted. No noise barriers or topography that may affect noise levels were incorporated in the calculations.
Table 3.9-16 presents the comparison of existing noise levels with existing plus project plus cumulative projects noise levels. As shown, the overall roadway segment noise levels would increase 0.1 to 0.4 dBA CNEL with the development of the project and proposed cumulative projects.
The cumulative noise increase would be less than 3 dBA CNEL on any roadway segment so cumulative roadway noise impacts would be less than significant.
Table 3.9-16. Existing vs. Existing Plus Project Plus Cumulative Noise Levels Roadway Roadway Segment
Existing Noise
Level @ 50-feet
(dBA CNEL)
Existing +Project+
Cumulative Noise
Level @ 50-feet
(dBA CNEL)
Project Related
Noise Level
Increase @ 50-
feet (dBA CNEL)
Mission Road Pico Avenue to
Woodward Street
69.9 70.0 0.1
Woodward Street
to Mission Villas
Road
72.2 72.4 0.2
San Marcos
Boulevard
Rancheros Drive
to Mission Road
69.8 70.2 0.
Woodward Street E. Mission Road to
Project
65.3 65.7 0.4
Project to
Vineyard Road
65.3 65.4 0.1
Source: LDN 2025.
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3.9.6 Mitigation Measures
Noise Levels During Rock Drilling and Blasting (Impact N-1) MM-N-1 Prior to issuance of a blasting permit, the project applicant or contractor shall provide the final location of the construction equipment, topography and construction schedule to the Planning Division. If the rock drill is shown to be located within 160 f eet from a sensitive land use’s property line, an acoustical engineer shall prepare a noise assessment to determine whether noise levels in excess of the 75 dBA standard would occur during construction.
If the rock drilling and blasting noise assessment determines noise levels at the affected property lines would exceed 75 dBA, the acoustical engineer shall develop a mitigation plan to ensure during rock drilling and blasting would be below 75 dBA at the property line. Potential measures to reduce drilling and blasting noise levels could include: 1) construction of a temporary noise barrier of solid non -gaping material ranging from 8 to 12 feet in height along any property line where the impacts could occu r; 2) limits on usage of the equipment (amount of time used and/or the location in respect to the property line) or other measures to ensure the levels would be below 75 dBA. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.
Noise Levels During Rock Crushing (Impact N-2)
MM-N-2 Prior to issuance of a Grading Permit for a rock crusher, the project applicant or contractor shall provide the final location and rock crusher type to the Planning Division. If the rock crusher is shown to be located within 400 feet of a single-family residential use without shielding , an acoustical engineer shall prepare a noise assessment to determine whether noise levels would be above the applied thresholds of 60 dBA at any existing single family residential use and 65 dBA for multi-family.
If the rock crushing noise assessment determines noise levels at the affected property lines would exceed the standards, the acoustical engineer shall develop a mitigation plan to reduce noise levels to 60 dBA at any existing single-family use and 65 dBA at any existing multi-family use. Mitigation may include sound barriers, sound absorbing materials, and/or operational limits on the crusher equipment’s usage. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.
3.9.7 Conclusion
Based on the proposed location of construction equipment relative to surrounding land uses, the noise analysis prepared for the project (LDN 2025) concluded that noise impacts during construction would be below City standards and less than significant. However, the potential exists that construction equipment, specifically the rock drill and rock crusher , could be staged closer to sensitive uses than anticipated potentially resulting in noise levels exceeding the 75 dBA (8-hour) threshold for rock drilling and the applied operational threshold of 60 dBA at any existing single family residential use . during operation of a rock crusher. These potentially significant impacts would be mitigated to below a level of significance through implementation of mitigation measures MM-N-1 through MM-N-2.
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Specifically, implementation of mitigation measures MM-N-1 and MM-N-2 provide for preparation of a noise assessment to be prepared prior to issuance of a blasting permit for the rock drill and conditional use permit for the rock crusher to confirm that noise levels would not exceed applicable City standards.
If noise levels would exceed standards, then noise mitigation plans would be prepared and implemented to ensure noise levels are in compliance.
Operational noise impacts at the project site would not exceed the City’s General Plan Noise Element 65 dBA exterior noise threshold nor increase roadway noise levels by more than 3 dBA. Therefore, impacts related to operational noise would be less than significant.
Construction activities would generate levels of vibration that would not exceed the FTA criteria for nuisance and structural damage for nearby residential uses. If blasting is required within 250 feet of existing residences, the potential annoyance may not be completely avoided but it can be minimized by following the City’s blasting procedures as stated in Section 3. 9.2, including proper notice to residences. Short term vibration impacts would be less than significant.
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Figure 3.9-1. Ambient Monitoring Locations
Source: LDN 2025.
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Figure 3.9-2. Modeled Receptor Locations
Source: LDN 2025.
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Figure 3.9-3. Temporary Rock Crusher Proposed Location
Source: LDN 2025.
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3.10 Public Services
This section analyzes the potential impact of the proposed project on public services including fire protection services, police protection services, schools, parks, and libraries. Please see Section 3.13, Utilities and Service Systems, for an analysis of water, wastewater, energy, telecommunications, stormwater, and solid waste services. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s web site. 10 Service provider letters
are included in Appendix L of this document.
Table 3.10-1 summarizes the project - and cumulative -level public services analysis impact, by threshold of significance.
Table 3.10-1 Public Services Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for:
Fire protection services
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
Police protection services
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
Schools
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
Parks
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
Other public facilities
Less than
Significant
Less than
Significant
Less than
Significant
Without
Mitigation
10 http://www.san-marcos.net/work/economic-development/general-plan
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3.10.1 Existing Conditions
This section details the existing service providers and resources related to fire protection, police protection, schools, parks, and libraries.
Fire Protection
The San Marcos Fire Department (SMFD) would provide fire protection and emergency medical services to the project site. The SMFD has existing automatic mutual aid fire agreements in place with the Cities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District.
The SMFD has an Insurance Service Office Rating 1, on a scale of one to ten wi th one being superior service.
The SMFD currently operates four fire stations, four paramedic assessment engine companies, one paramedic assessment truck company, five paramedic transport ambulances (24 -hour units), one shift battalion chief, and one on-call duty chief. SMFD also cross-staffs three wildland fire engines and a State of California/Office of Emergency Services wildland fire engine (City of San Marcos 2024).
The SMFD Station 1, located at 180 W. Mission Road in San Marcos is the closest station to the project site and would serve the project site should fire response or emergency services be needed (City of San Marcos 2024). SMFD Station 1 is located approximately 0.25 miles west of the project site. SMFD Station 1 houses an engine, truck, brush engine, ambulance, and battalion chief.
There are two easements on the project 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 ass ociated with fire buffer maintenance requirements of adjacent development.
Police Protection
The San Diego County Sheriff’s San Marcos Station provides law enforcement services to the City and unincorporated communities of Harmony Grove, Elfin Forest, Lake San Marcos, Hidden Meadows, Ivy Del, Del Dios, Lake Hodges, and the San Pasqual Valley (SDCSD 2024 ). The San Marcos Station is located at 182 Santar Place in San Marcos, approximately 0.75 mile southeast of the project site.
Law enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services (City of San Marcos 2012a). Services are available 24 hours a day, 7 days a week.
The San Marcos Station serves more than 111,000 residents and staffs more than 100 deputies, volunteers, and professional staff members. Additionally, Community Oriented Police and Problem Solving teams are assigned to investigate community quality -of-life issues. Lastly, the Sheriff’s San Marcos Station has the only ASTREA (Sheriff’s Aviation) helicopter landing pad in the County, which assists ground units and extends the range deputies can patrol (SDCSD 2024).
The County Sheriff’s Department does not set response time goals. The Sheriff’s Department does, however, prioritize different types of calls to better facilitate deputy dispatches. The Sheriff Department’s priority categories are as follows: priority level 1 (lifesaving response calls), priority level 2 (expeditious response calls within confines of vehicle codes), priority level 3 (calls responded to as soon as possible), and priority level 4 (calls responded to when clear, still being alerted to violatio ns that require immediate law enforcement action) (City of San Marcos 2012a).
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Schools
The project site is located within the San Marcos Unified School District (SMUSD). SMUSD is 49 square miles in size and encompasses most of the City of San Marcos and portions of the cities of Vista, Escondido, and Carlsbad, as well as unincorporated areas of the County of San Diego between these cities. As of 2023, there are ten elementary schools, two K–8 schools, three middle schools, three high schools, and one independent high school program that are a part of the SMUSD. In the 2021 - 22 school year, SMUSD served 19,341 students. (SMUSD 2023a).
Based upon information from SMUSD, Richland Elementary School, Woodland Park Middle School and Mission Hills High School would serve the project site (SMUSD 2023b). Currently, Richland Elementary and Woodland Park have capacity and Mission Hills High School is over capacity (SMUSD 2023b).
Richland Elementary was recently reconstructed and there are plans for expansions at Woodland Park Middle School and Mission Hills High School (SMUSD 2023b).
Parks
The purpose of the City’s Parks, Recreation, and Community Health Element of the General Plan is to provide recreational opportunities, which contribute to the health and well -being of the residents of San Marcos and to provide goals and policies that outl ine the role recreational amenities play in achieving the City’s vision for the future (City of San Marcos 2012a).
There are 24 community parks, 13 neighborhood parks and three recreation centers in the City.
The parks closest to the project site are Richmar Park and Hollandia Park. Richmar Park is located
0.25 mile west of the project site at 110 Richmar Avenue. Richmar Park is developed with adapted play equipment, a performance plaza, permanent restrooms, a picnic shelter, p icnic tables, play equipment and turf play areas. Hollandia Park is located 0.8 miles east of the project site at 12 Mission Hills Court. Hollandia Park is developed with an amphitheater, lighted ballfield, barbeque area, dog park, horseshoe court, lighted multi-purpose fields, park space, permanent restrooms, a picnic shelter, play equipment, skate plaza and turf play areas.
Other Public Facilities (Libraries)
The City is served by the San Diego County Library, San Marcos Branch located at 2 Civic Center Drive, approximately 1.4 miles northwest of the project site. The San Marcos Branch is 15,394 square feet (s.f.) (City of San Marcos 2012b). The library is open seven days a week. The San Diego County Library system has 33 branches, an E -library, two bookmobiles, and five digital kiosks (San Diego County Library 2024a).
3.10.2 Regulatory Setting
Local
San Marcos General Plan
The following are applicable goals and policies from the City of San Marcos General, Land Use and Community Design Element related to public services:
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Land Use and Community Design Element
• Goal LU -8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU -8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities. • Goal LU-10: Fire protection, emergency services, and law enforcement: Provide effective, high- quality, and responsive services.
o Policy LU -10.1: Provide demand -based fire -fighting and emergency medical services infrastructure, equipment, and personnel to provide a high level of fire, emergency medical, and law enforcement service in San Marcos to meet existing and future demands. o Policy LU -10.2: Work closely with the County of San Diego Sherriff’s Department to determine and meet the community needs for adequate personnel, equipment, and state- of-the-art technology to effectively combat crime, and meet existing and projected service demands.
o Policy LU-10.3: Continue to conduct public outreach and education regarding fire safety and crime prevention within San Marcos.
• Goal LU-11: Schools: Ensure all residents have access to high-quality education. o Policy LU-11.1: Collaborate with the local public school district (SMUSD), private schools, and institutions of higher learning to ensure a range of traditional and distance -learning educational opportunities are provided in superior, accessible facilities that complement the surrounding land uses.
o Policy LU-11.2: Work with San Marcos Unified School District and developers to ensure adequate school facilities are funded as required by State law and through developer mitigation agreements between the school district and the developer. The City shall require a “will serve” letter substantiating that the developer has paid fees to the satisfaction of the school district prior to issuance of building permits. • Goal LU -12: Libraries: Provide library resources and services that meet the needs of the community.
o Policy LU-12.1: Provide adequate library facilities and technological access that enhance San Marcos’s quality of life and create a civic environment with vast opportunities for self- learning and academic enrichment.
o Policy LU-12.2: Accommodate technology needs of the community and locate accessible technology in the library.
Safety Element
The following are applicable goals and policies from the City of San Marcos General Plan, Safety Element related to public services:
• Goal S -3: Minimize injury, loss of life, and damage to property resulting from structural or wildland fire hazards.
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o Policy S -3.1: Require development to be located, designed and constructed to provide adequate defensibility and reduce the risk of structural loss and life resulting from wildland fires. Development will consider hazards relative to terrain, topography, ac cessibility and proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead fire sprinklers. o Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire. Advocate and support regional coordination among fire protection and emergency service providers.
o Policy S-3.3: Require development to provide additional access roads when necessary, to provide for safe access of emergency equipment and civilian evacuation concurrently. o Policy S-3.4: Coordinate with fire protection and emergency service providers to assess fire hazards before and after wildfire events to adjust fire prevention and suppression needs, as necessary, commensurate with both short- and long-term fire prevention needs. • Goal S-6: Provide neighborhood safety through effective law enforcement. o Policy S-6.1: Continue to maintain demand-based law enforcement service levels to reduce the risk of criminal activity.
o Policy S -6.2: Continue public education efforts and community outreach programs to promote community involvement in crime and drug prevention. o Policy S-6.3: Use Crime Prevention through Environmental Design (CPTED) principles in the design or redevelopment of projects and buildings.
Parks, Recreation, and Community Health Element
The following are applicable goals and policies from the City of San Marcos General Plan, Parks, Recreation and Community Health Element related to parks:
• Goal PR-1: Plan for, acquire, develop, and maintain a system of local parks connected through an integrated network of trails and high-quality recreational facilities. o Policy PR-1.1: Develop and maintain a complete system of public parks and recreational amenities that provide opportunities for passive and active recreation at a minimum standard of 5 acres per 1,000 residents. Parks, trails, and recreational facilities w ill enhance community livability, public health, and safety; should be equitably distributed throughout the City; and be responsive to the needs and interests of residents, employees, and visitors.
o Policy PR-1.2: Update and maintain a Master Parks Plan and a Master Trails Plan that implement the City’s long-term vision for a complete system of parks, trails, and recreation facilities.
o Policy PR-1.3: Ensure that the development of parks, trails, and recreation facilities and services keeps pace with development and growth within the City. o Policy PR-1.4: Promote increased access to parks and open spaces, pedestrian- and bike- oriented routes to parks and open space, greening of public rights-of-way, and a variety of active and passive uses of parks and open space.
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o Policy PR-1.5: Require new development to be designed and constructed in accordance with the approved Parks Master Plan to meet or exceed the City’s parkland standard of 5 acres per 1,000 residents.
o Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.
o Policy PR-1.7: Promote park and facility design that discourages vandalism, deters crime, provides natural surveillance, and creates a safe and comfortable environment. o Policy PR -2.2: Implement the trail network per the Master Trails Plan to increase opportunities for physical activity (e.g., walking, biking), healthy lifestyles, and to reduce reliance on cars.
Environmental Justice Element
The following are applicable goals and policies from the City of San Marcos General Plan, Environmental Justice Element related to parks:
• Goal EJ-2: Locate public facilities and services equitably throughout the community. o Policy EJ-2.7: Ensure that the development of parks, trails, and recreation facilities and services keeps pace with development and growth within the City (See Policy PR-1.3). o Policy EJ-4.12: Use Crime Prevention through Environmental Design (CPTED) principles in the design or redevelopment of projects and buildings (See Policy S-6.3). o Policy EJ 2.6 and EJ -5.7: Develop and maintain a complete system of public parks and recreational amenities that provide opportunities for passive and active recreation at a minimum standard of 5 acres per 1,000 residents. Parks, trails, and recreational facilities will enhance community livability, public health, and safety; should be equitably distributed throughout the City; and be responsive to the needs and interests of residents, employees, and visitors (See Policy PR-1.1).
o Policy EJ-5.8: Promote increased access to parks and open spaces, pedestrian- and bike- oriented routes to parks and open space, greening of public rights-of-way, and a variety of active and passive uses of parks and open space (See Policy PR-1.4) o Policy EJ -5.10: Implement the trail network per the Master Trails Plan to increase opportunities for physical activity (e.g., walking, biking), healthy lifestyles, and to reduce reliance on cars (See Policy PR-2.2).
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As detailed in Table 3.8-12 in Section 3.8, the project is consistent with all applicable goals and policies.
San Marcos Municipal Code
Section 17.36 – Park and Recreational Development Construction Unit Fee This code requires that builders of residential units pay fees which shall be used for the improvement, development and operation of park or recreational facilities. The fee shall be paid prior to the issuance of building permits for any dwelling units.
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Section 17.44 – Development Services and Public Facilities Exactions, Fees, and/or Costs This code requires that each applicant for a grading, construction, building and/or development permit or entitlement shall, prior to the issuance of such permit or entitlement, pay the fees including Development Services Fees and Public Facilities Fees (PFF). Per Section 17.44.060, one component of the PFF is parks.
3.10.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to public services are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to public services would occur if the project would:
Threshold #1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
• Fire protection.
• Police protection.
• Schools.
• Parks.
• Other public facilities.
3.10.4 Project Impact Analysis
Threshold #1: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire Protection
As discussed in Section 3.10.1, above, the SMFD provides fire protection services to the City and would serve the project site. The proposed project would increase the demand on SMFD resources as a result of the development of residential uses and the associated population increase . The project would introduce approximately 143 residents on -site resulting in the increased demand for fire protection services through routine fire and emergency medical calls.
As part of the project design, the project would implement a zoned brush management plan which would 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. The brush management concept is presented in Figure 2-12 in Chapter 2. The brush management plan and implementation would be the responsibility of the Home Owners Association. The brush management zones include:
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• Zone 1 (Structures) – This zone covers 50 feet around structures and is measured from the structure outward to 50 feet or to the property line. Zone 1 landscaping shall be permanently irrigated and landscaped with fire resistive, low fuel plant material lower than 18 inches high.
At maturity, trees shall be located so crowns are a minimum 10 feet from structures at maturity and spaced with a minimum of 10 feet between crowns at maturity. No combustible fencing shall be allowed. No bark mulch shall be allowed within 5 feet of structure walls. • Zone 1 (Roadway Adjacent) – This zone measures 30 feet outwards from the roadway curb to 30 feet each side of the roadway. Landscaping shall be permanently irrigated and landscaped with fire-resistive, low-fuel plant material.
• Zone 2 – This zone is measured from the outside edge of Zone 1 outward to 100 feet from the structure. This zone has a reduced fuel, non -irrigated area and shall be maintained, thinned, and trimmed. A maximum of 50 percent of native vegetation shall be retained with single specimen shrubs 20 feet off center maximum. Groundcover shall be maintained at 6 inches height. Trees shall be maintained with a minimum 20 feet between canopies. • Zone 3 – This zone measures from the outside of edge of Zone 2 outward to 150 feet from the structure. This zone is a reduced fuel, non-irrigated area and shall be maintained, thinned and trimmed. A maximum of 30 percent of native vegetation shall be retained with single specimen shrubs 20 feet off center maximum. Groundcover shall be maintained at 6 inches height. Trees shall be maintained with a minimum 20 feet between canopies As a condition of project approval, prior to the issuance of a grading permit, the applicant/developer/property owner would submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001-01 (Fire and Paramedic). This would offset the project’s increase in demand for fire protection services. The project would not result in substantial adverse physical impacts associated with the provision of new fire protection facilities and impacts would be less than significant.
Police Protection
As discussed in Section 3.10.1, above, the San Diego County Sheriff’s Department provides law enforcement services to the City. More specifically, the project would be served by the San Marcos Station, located approximately 0.5 miles from the project site. The project would introduce approximately 143 residents on- site, resulting in an increased demand on existing police protection resources. The development and associated population increase on the project site would be expected to increase the frequency o f emergency and non -emergency calls to the Sherriff’s Department.
However, as discussed in Section 3.10.1 above, over 100 deputies, volunteers, and professional staff serve the residents of the City. Law enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services. Unlike fire services, which respond solely to emergencies, law enforcement services consist of pa trolling large areas 24 hours a day, 365 days a year. Police units are continuously mobile, and service calls are responded to by the nearest available mobile unit.
At the San Marcos Station, patrol deputies are assigned to a geographical “beat” area, allo wing deputies to become familiar with citizens and problems within their “beats”. As such, the location of the proposed project relative to the nearest station would not affect police protection. Further, to minimize the increased demand for police protect ion services, the project has been designed to improve the safety for future residents and visiting guests. Safety features proposed for the proposed project include walls , fencing, and lighting as described in Section 2.2.2.3 (Chapter 2, Project Description).
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Additionally, as a condition of project approval, prior to the issuance of a grading permit, the applicant/developer/property owner would submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 98-01 (Police) . Thus, while new development places increased demand on police protection services, it is not anticipated that the proposed project would result in the need for construction or expansion of existing police facilities. Therefore, the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities. Impacts resulting from the proposed project would be less than significant.
Schools
The project site is located within the service boundary of the SMUSD. Per SMUSD the following schools would serve the project:
• Richland Park Elementary School, (grades TK-5), 910 Richland Road, San Marcos • Woodland Park Middle School (grades 6-8), 1270 Rock Spring Road, San Marcos • Mission Hills High School (grades 9-12), 1 Mission Hills Court, San Marcos Table 3.10-2 presents the number of students anticipated to be generated by the 46 residential units.
As shown in Table 3.10-2, the project will generate 3 TK students, 18 elementary school students, 6 middle school students and 8 high school students a total of 35 students.
Table 3.10-2. Student Generation
Grade Generation Rate(1) Number of Units
Proposed Students Generated
TK 0.05498 46 3
K-6 0.38486 46 18
7-8 0.10996 46 6
9-12 0.15865 46 8
Total Students 35
Source: SMUSD 2023b.
Note: (1) The district has rates for single family, multi family and apartments. The multifamily rate was used for the project.
There is currently capacity at Richland Elementary and Woodland Park Middle School (2023b), however, SMUSD is experiencing district-wide capacity issues. The addition of students generated by the project would contribute to the District-wide capacity issues. The project applicant shall pay school mitigation fees pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) in effect at the time of building permit issuance. Current Level II school fees are $4.79/s.f. for residential development (SMUSD 2023c). Further, consistent with General Plan Policy LU-11.2, the applicant shall provide a letter from the school district to the City prior to the issuance of building permits confirming these fees have been paid.
Payment of these fees would assist in funding SMUSD’s long-range plans. State Bill (SB) 50 states that the fees imposed by school districts shall constitute the exclusive method of considering and mitigating impacts on school facilities caused by a development project. Such payment shall provide “full and complete mitigation of the impacts of any legislative or adjudicative act...on the provision of
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adequate school facilities” (Government Code Section 65995(h)). As such, with contribution of required development fees, impacts to schools would be less than significant.
Parks
Buildout of the proposed project is estimated to add an additional 143 residents to the City. Assuming five acres of park space per 1,000 residents, this equates to a demand of approximately 0.72 acres of park space generated by project residents.
The project applicant would be required to pay the City’s PFF, which is required by all projects that increase the demand for park and recreation needs in the City. The PFF money would go towards the acquisition and development of local and community park facilities throughout the City, to offset the demand on public park space generated by the project, as described in Municipal Code Chapter 17.36 and 17.44. Payment of the PFF shall be made prior to City issuance of the first building permit for the proposed project. The PFF payment would ultimately contribute to development of new parks and recreational facilities and would offset the increase in demand of parks and recreational facilities generated by the proposed project, such that existing facilities would not be substantially deteriorated.
In addition, the project proposes 6.01 acres of open space. The proposed open space includes 5.18 acres of common open space with grades of 10% or greater and 0.86 acres of common open space with grades less than 10%. The project also includes private open space, which totals 38,375 s.f. and includes decks and ground -floor patios for all the units. The 7,480 s.f. (0.2 acres) community recreation area would be located in the southcentral portion of the site and would include a tot lot with fall safe surfacing, turf play areas, shaded picnic table, looped trike track, and a sensory play area.
The homeowners association would be responsible for the maintenance of the common open space areas, including the recreation area/park. As such, with payment of the required PFF in combination with provision of on -site common and private open space, the project would mee t and exceed the anticipated demand for neighborhood and regional parks or other recreational facilities. Project residents would have access to adequate on-site recreational facilities, which would offset increased use of existing parks and recreational facilities. Park impacts would be less than significant.
Other Public Facilities (Libraries)
Development of the project would add an additional 143 residents to the City. This would increase the demands on library services and resources. However, additional library services are available in the County through the Serra Cooperative Library System. The Serra Cooperative Library System is a network of public, academic, and special libraries in the southern California counties of Imperial and San Diego. Serra helps member libraries provide expanded resources and services at reduced costs.
Community members can also borrow materials at Palomar Community College with a valid picture ID and proof of current mailing address. Therefore, a
less than significant impact is identified for this
issue area.
3.10.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative
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impact with respect to public services, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to public services (see Table 2-4, Cumulative Projects).
Fire Protection Services
The geographic area for the cumulative analysis of fire protection and emergency services i ncludes those areas that are serviced by the SMFD. The cumulative projects that fall within this geographic area would add to the increase in demand for fire protection and emergency services. The SMFPD provides service to the City of San Marcos and has existing automatic mutual aid fire agreements in place with the Cities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District. As d iscussed in Section 3.10 .4 above, although the proposed project would introduce approximately 143 residents on-site, the project is not expected to cause a decline in SMFD response times. Nonetheless, the cumulative projects listed in Table 2-4 would result in additional demand of fire protection services, and the potential need for additional fire protection resources. However, all cumulative projects would be required to participate in existing Community Facilities Districts as determined necessary. Future projects would be required to offset the increase in demand caused by their respective project. Development fee payments would go towards providing the additional staff and equipment that would be needed by SMFD in the future to provide fire protection s ervices, including potential new fire stations. Similarly, to offset any potential cumulative impacts to fire protection services, the project would pay all required development impact fees. Thus, cumulative impacts to fire protection services would be
less than significant.
Police Protection Services
The geographic area for the cumulative analysis of police protection i ncludes those areas that are serviced by the San Marcos Sheriff’s Department. All cumulative projects listed in Table 2-4 would result in an increase in demand for police protection services from the San Marcos Sheriff’s Department. The project site would be ser ved by the San Marcos Station, located approximately 0.5 miles from the project site. As discussed in Section 3.10.4, the proposed project would not result in substantial adverse p hysical impacts associated with the provision of new or physically altered facilities. However, the cumulative projects listed in Table 2 -4 would result in additional demand of police protection services, and the potential need for additional police protection resources.
Nonetheless, all cumulative projects would be required to offset increased demand to police protection services through the payment of fees. These fees would provide for additional staff and equipment to assist in the provision of law enforcement services. In order to offset any potential cumulative impacts to fire protection services, the proposed project would also be required to contribute toward future police protection resources through the payment of fees. As such, with payment of fees , cumulative impacts to police protection services would be less than significant.
Schools
SMUSD is experiencing district-wide capacity issues. The addition of students generated by the project would contribute to the district-wide capacity issues.
As discussed in Section 3.10.4, the project applicant would be required to contribute development fees to SMUSD, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal Code Section 17.52.050. The applicant shall pay the school mitigation fees that are in effect at the time of building permit issuance.
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Current Level II school fees are $4.79/s.f. for residential development and $0.78/s.f. for commercial development, however, this fee amount could change between the drafting of this EIR and the time of building permit issuance (SMUSD 2023c). Further, consistent with General Plan Policy LU -11.2, the applicant shall provide a letter from the school district to the City prior to the issuance of building permits confirming these fees have been paid. All the cumulative projects included in Table 2-4 that include residential development would result in increased demand for school services and would be required to pay school fees to offset the increase demand, similar to the proposed project. Additionally, non-residential projects are also required to pay school fe es consistent with SMUSD’s developer fee schedule. As such, with contribution of required development fees by the proposed project and related projects, cumulative impacts to schools would be
less than significant.
Parks
The proposed project as well as the cumulative projects that are in the City of San Marcos (as identified in Table 2 -4) would add to the cumulative demand for park and recreation facilities in the City. All residential projects that increase the demand for park and recreation needs in the City are required to provide park space and/or pay park in lieu-fees. The environmental documentation prepared for each project would analyze impacts associated with the construction of any parks within each overall development footprint. As discussed in Section 3.10.4, the proposed project would be required to pay the City’s PFF, which is required for all projects that increase the demand for park and recreation needs in the City. The PFF would be used for developing neigh borhood and regional parks. It is expected that all cumulative projects that increase demand for parks and recreation needs would also be required to pay these fees. As such, cumulative impacts on recreational facilities in the City would be
less than significant.
Other Public Facilities (Libraries)
Cumulative projects within the service area of the San Marcos Branch Library would result in an increase in demand for library services. Aside from the San Marcos Branch, community members can get borrowing privileges at the CSUSM campus and the Palomar Co mmunity College (CSUSM 2024).
These additional library resources are in the San Marcos community and provide over 200,000 square feet of additional library space. Cumulative impacts to library services would be less than significant.
3.10.6 Mitigation Measures
No significant impacts to public services were identified; thus, no mitigation measures are required.
3.10.7 Conclusion
Development of the proposed project would result in an increase in demand for fire protection, emergency medical services, police protection, school services, parks, and library facilities. However, the project applicant would be required to pay all applicable development fees including payment of school mitigation fees, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal Code Section 17.52.050, and payment of the City’s PFF, required by all projects that increase the demand for park and recreation needs in the City, in order to avoid direct and cumulative impacts to schools and parks.
Although the project, on its own, is not expected to result in impacts to fire and police protection services, with the additional demand on fire and police services to be added by the cumulative projects listed in Table 2 -4, potential need for additional fire and police protection resources could occur. As
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such, the project applicant would be required to pay all required development fees to fire and police services to offset any potential cumulative impacts. The project applicant would also annex into CFD 2001-01 (Fire and Paramedic) and CFD 98-01, Improvement Area 1 (Police), which would offset and minimize potential impacts. As such, with payment of fees towards schools, parks, fire, and police, impacts to public services would be less than significant.
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3.11 Transportation
This section provides a transportation impact analysis for the proposed project related to transit, roadway, bicycle and pedestrian facilities, vehicle miles traveled, design feature hazards and emergency access. The section is based on the following reports, which are included as Appendices J
and M of the Environmental Impact Report(EIR):
• Local Transportation Analysis, Woodward 46 Apartment Project Prepared by Linscott Law & Greenspan (LLG). March 27, 2024 (LLG 2023a)
• Vehicle Miles Traveled (VMT) Study. Woodward 46 Apartment Project Prepared by Linscott Law & Greenspan (LLG). March 27, 2024 (LLG 2023b)
Section 3.8 (Land Use and Planning) includes a description of existing traffic conditions, methodology, baseline conditions and trip generation for the local transportation analysis/level of service (LOS) analysis. Table 3.8-12 in Section 3.8 analyzes the project’s consistency with the Mobility Element of the General Plan.
Table 3.11-1 summarizes the project- and cumulative-level traffic impact analysis, by threshold.
Table 3.11-1. Transportation/Traffic Summary of Impacts Thresholds of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1: Conflict with a program plan,
ordinance or policy addressing the
circulation system, including
transit, roadway, bicycle, and
pedestrian facilities
No Impact Less than
Significant
Less than
Significant Without
Mitigation
#2: Would the project conflict or
be inconsistent with CEQA
Guidelines Section 15064.3,
subdivision (b)?
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#3 - Substantially increase
hazards due to a design feature
(e.g., sharp curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment).
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
#4: Result in inadequate
emergency access
Less than
Significant
Less than
Significant
Less than
Significant Without
Mitigation
3.11.1 Existing Conditions
The City strives to create a robust, city -wide system of roadways, bicycle and pedestrian paths and routes, as well as public transit options, which provide residents with alternative modes of travel as well as recreational opportunities.
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Existing Roadways
The following is a description of the existing street network in the study area (LLG 2023a):
• Woodward Street is currently constructed as a 4 -lane undivided roadway between Vineyard Road and Mission Road. The posted speed limit is 40 mph. On- street parking is prohibited.
Sidewalks are provided on both sides of the roadway. Class II bike lanes are provided. • Mission Road is currently constructed as a 4 -lane undivided roadway with a two-way left-turn lane west of Firebird Lane. Between Firebird Lane and San Marcos Boulevard, Mission Road is built as a 4-lane divided roadway. East of San Marcos Boulevard, it is built as a 6-lane divided roadway. The posted speed limit is 45 mph. On -street parking is prohibited. Sidewalks are provided on both sides of the roadway. Class II bike lanes are provided east of Pico Avenue. • Pico Avenue is currently constructed as a 4-lane undivided roadway south of Mission Road and as a 2-lane undivided roadway north of Mission Road. The posted speed limit is 25 mph. On- street parking is prohibited. Sidewalks are provided on both sides of the roadway. There are no existing bicycle facilities along Pico Avenue.
• San Marcos Boulevard is currently constructed as a 4-lane divided roadway. The posted speed limit is 40 mph. On -street parking is prohibited. Sidewalks are provided on both sides of the roadway. Class II bike lanes are provided.
• Twin Oaks Valley Road is currently constructed as a 4 -lane divided roadway, north of San Marcos Boulevard. South of San Marcos Boulevard, Twin Oaks Valley Road is built as a 6-lane divided roadway. The posted speed limit is 45 mph. On-street parking is prohibited. Sidewalks are provided on both sides of the roadway. Class II bike lanes are provided. • Rancheros Drive is currently constructed as a 4 -lane divided roadway between San Marcos Boulevard and Civic Center Drive. South of Civic Center Drive, Rancheros Drive is built as a 2- lane divided roadway. The posted speed limit is 35 mph. On-street parking is prohibited.
Sidewalks are provided on both sides of the roadway except for the west side portion of the roadway, approximately 550 -feet south from the Rancheros Drive and Civic Center Drive intersection. Class II bike lanes are provided, south of Civic Center Drive.
Existing Transit Service
Transit service is provided to the area via North County Transit District (NCTD). The nearest bus stop is located 1,000 feet south of the p roject site, just west of the Mission Road / Woodward Street intersection. The San Marcos Civic Center Station, which serves the SPRINTER, is located approximately 0.25 miles south of the project site on the southwest corner of the Mission Road / Woodward Street intersection.
• Bus Route 305 provides bus service to the area via Mission Road and South Santa Fe Avenue, connecting Escondido to Vista. During weekdays, headways are 30 minutes for the duration of the day. During weekends, headways are 30 minutes for the duration of the day. Route 305 has one bus stop near the project site located at the intersection of Mission Road and Woodward Street.
• The SPRINTER runs between Escondido and Oceanside. There are fifteen (15) stops along this route. SPRINTER service provides thirty-four (34) daily trips on the weekdays with an additional six (6) trips on Friday nights. It also provides twenty -five (25) daily weekend t rips with an
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additional three (3) trips on Saturday nights (LLG 2023a). The closest SPRINTER Station is 0.2 miles southwest of the project site at the San Marcos Civic Center.
Existing Bicycle Conditions
Currently, the City of San Marcos provides Class II Bike Lanes on Mission Road, Twin Oaks Valley Road, Woodward Street and San Marcos Boulevard. Per the City of San Marcos Bicycle and Pedestrian Master Plan, there are no plans to add or alter bicycle facilities within the project vicinity (LLG 2023a).
Existing Pedestrian Connections
Sidewalk connection is provided between the project site and the San Marcos Civic Center Station and bus stops. Sidewalks are provided on both sides of the roadways except for the west side of Rancheros Drive, approximately 550-feet south from the Rancheros Drive and Civic Center Drive intersection. Per the City of San Marcos Bicycle and Pedestrian Master Plan, there are no plans to add or alter sidewalks within the project vicinity (LLG 2023a).
3.11.2 Regulatory Setting
The following provides a general description of the applicable regulatory requirements and guidelines for the project area.
State Regulations
California Department of Transportation
The California Department of Transportation (Caltrans) is the primary state agency responsible for transportation issues. One of its duties is the construction and maintenance of the state highway system. Caltrans has established standards for roadway traffic flow and has developed procedures to determine if intersections require improvements. For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. For projects that would not physically affect facilities but may influence traffic flow and levels of services at such facilities, Caltrans may recommend measures to mitigate the traffic impacts of such projects.
AB 1358 – California Complete Streets Act of 2008
The California Complete Streets Act of 2008 (Assembly Bill [AB] 1358) requires circulation elements as of January 1, 2011, to consider the transportation system from a multi-modal perspective, including public transit, walking, and biking, which have traditionally been marginalized in comparison to autos in contemporary American urban planning.
SB 743, CEQA Guidelines Update
In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package, which included the California Natural Resources Agency Guidelines for the Implementation of CEQA. As a result, the California Governor’s Off ice of Planning and Research (OPR) updated and released the Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory) in December 2018. According to the updated guidelines, lead agencies had until July 1, 2020, to comply with the updated CEQA revision. The City of San Marcos has adopted Vehicle Miles Traveled (VMT) thresholds as part of their Transportation Impact Analysis Guidelines (City of San Marcos 2020).
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While VMT is the preferred quantitative metric for assessing potentially significant transportation impacts under CEQA, it should be noted that SB 743 does not prevent a city or county from using metrics such as LOS as part of the application of local gene ral plan policies, municipal and zoning codes, conditions of approval, or any other planning requirements through a city’s planning approval process; cities can still ensure adequate operation of the transportation system in terms of transportation congestion measures related to vehicular delay and roadway capacity. As such, the City can continue to require congestion -related transportation analysis and mitigation projects through planning approval processes outside CEQA. Section 3. 8, Land Use and Planning , includes results of the LOS analysis prepared for the project.
Local Plans and Policies
SANDAG San Diego Forward: The 2021 Regional Plan
The Regional Plan, adopted in 2021 by the San Diego Association of Governments (SANDAG), provides a long-term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal access to jobs, education, healthcare, a nd other community resources. The plan is the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative transportation demand and management strategies.
The Regional Plan combines the Regional Comprehensive Plan and the Regional Transportation Plan/ Sustainable Communities Strategy (RTP/SCS). By integrating land use and transportation plans, the Regional Plan is intended to achieve greenhouse gas emission reduction targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act.
The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the city and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants. The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications.
Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Di ego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.
The Regional Plan also supports other regional transportation planning and programming efforts, including overseeing which projects are funded under the Regional Transportation Improvement Program and the TransNet program. SANDAG is applying data -driven strategies, innovative technologies, and stakeholder input to create a future system that is faster, fairer, and cleaner. Part of this data-driven approach includes the implementation of five key transportation strategies referred to as the 5 Big Moves. Thes e strategies provide the framework for the Regional Plan and consider policies and programs, changes in land use and infrastructure, the existing transportation highway and transit networks, and trends in technology to optimize use of the transportation sy stem. Together, these initiatives will create a fully integrated, world -class transportation system that offers efficient and equitable transportation choices, meets state climate targets, and supports local jurisdictions’ achievements of Climate Action Plan goals.
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In September 2022, the SANDAG Board directed staff to prepare an amendment to the 2021 Regional Plan without the regional road usage charge. In developing the amendment, SANDAG will refine the financial strategies used in the 2021 Regional Plan to achieve the region's greenhouse gas emissions target set by CARB, without the road usage charge. SANDAG will also assess the region's continued ability to meet air quality standards. An Amendment to the 2021 Regional Plan removing the regional road user charge was adopted by SANDAG in October 2023. The 2025 Regional Plan is currently in development and also will not include a regional road user charge.
SANDAG Smart Growth Opportunity Area
The project site is partially located within the SM -3 Mixed Use Transit Corridor as identified in the SANDAG Smart Growth Concept Map for North County. The Smart Growth Concept Map identifies locations in the region that can support smart growth, transit, walking, and biking. The map serves as the foundation for prioritizing transportation investments and determining eligibility for local smart growth incentive funds.
Congestion Management Program
The 2008 Congestion Management Program (CMP) for San Diego County was developed to meet the requirements of Section 65089 of the California Government Code. Since that time, the local agencies within San Diego County approved to opt out of the CMP requirem ents, as allowed within the Government Code. As such, there are no CMP -specific requirements associated with this project.
However, to ensure the region’s continued compliance with the federal congestion management process, SANDAG has prepared San Diego Fo rward: The 2021 Regional Plan in compliance with 23 Code of Federal Regulations 450.320. The Regional Plan incorporates performance monitoring and measurement of the regional transportation system, multimodal alternatives to single -occupancy vehicles, land use impact analysis, congestion management tools, and integration with the Regional Transportation Improvement Program process.
City of San Marcos Transportation Impact Analysis Guidelines The City of San Marcos approved Transportation Impact Analysis Guidelines (TIAG) on November 16, 2020 (City of San Marcos 2020). TIAG provide screening criteria for determining whether a land development project should conduct a VMT analysis. These thresholds are based on the project’s consistency with the General Plan, estimat ed daily trips, project location, and other project characteristics. A VMT analysis applies to all land development projects except for those that meet at least one of the screening criteria provided.
City of San Marcos Active Transportation Plan
The City of San Marcos adopted an Active Transportation Plan (ATP) in July 2024 that replaces the previous City of San Marcos Bikeway Master Plan and Pedestrian Master Plan; this plan supplements the General Plan Update by recommending specific pedestrian and bicycle-related projects, programs, and policies for the City. The ATP evaluates the current state of walking and biking opportunities; analyzes user demographics, safety data and more; engages community members; and provides recommendations to support mobility in the city. The ATP also incorporates a Safe Routes to School (SRTS) Study to identify challenges associated with the schools located within the San Marcos Unified School District. The ATP will be used to create active transportation -oriented projects for the City’s Capital Improvement Program (CIP) and for construction as required by the city for private development projects.
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In the City’s ATP, recommendations for future bicycle classifications for each roadway were broken down into interim and ultimate conditions. The interim bicycle network is composed of recommendations that can be accomplished in the near term without requiring redevelopment, right- of-way, or easements, or major environmental documentation/ permitting. The ultimate network contains long-term recommendations that can be completed over time as the City redevelops and right-of-way is acquired. In some cases, and ultimate improvement may be constructed first, rendering the interim improvement unnecessary.