Developers will be required to implement the ultimate bicycle network recommendations when considering setbacks, frontage improvements, and design, and may be required to construct the ultimate facilities based upon roadway characteristics, adjacent facilities, and the ability to design and construct safe transitions into the ultimate improvements. For two -way bicycle facilities —such as a Class I multi-use path or a Class IV two-way bikeway—the City may require a developer to construct or provide setbacks for these types of facilities that may be identified on the side of the roadway opposite the project’s frontage. Locations of desired facilities may, in some cases, be placed on either side of the roadway, at the discretion of the City. Parallel facilities may be required by the City as opportunities arise to create similar connectivity on other routes. The City may require other connectors between the high-level infrastructure shown in this plan in order to ensure a seamless network. The proposed project is consistent with the ATP.
San Marcos Transportation Demand Management (TDM) Ordinance and Policy To implement the City’s Climate Action Plan measures and to reduce traffic impacts from development projects, the City of San Marcos adopted a TDM Ordinance and Policy in December 2023. The TDM Ordinance and Policy will be applicable to any development project that is not exempt from CEQA requirements and would result in emission of more than 500 metric tons of carbon dioxide (MT of CO 2)
per year. Projects that are subject to this Ordinance shall submit a project specific TDM Plan for the City’s review and approval with the entitlement application to show compliance with the TDM Policy and Ordinance.
Its intent is to encourage a shift away from single-occupancy vehicles to alternative travel options such as walking, biking, carpooling, or taking transit. Reducing reliance on roadways will likewise result in reduced congestion, vehicle miles traveled, and greenhouse gases. The TDM policy lists six mandatory strategies that are required for all projects to implement and 29 optional strategies, each assigned a specific point value. Applicable projects would have to establish a project specific TDM Plan that should include all mandatory and a selection of optional strategies to achieve a minimum of a ten-point score.
San Marcos General Plan
The Land Use and Community Design Element of the General Plan identifies specific policies related to congestion management. Those that are applicable to the proposed project are identified below. • Goal LU -1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community. o Policy LU-1:1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices.
• Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
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o Policy LU-3.4: Provide non-motorized (pedestrian and bicycle) access/circulation within, and to, mixed-use centers to reduce reliance on the automobile. o Policy LU -3.5: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways.
o Policy LU -3.7: Require new development to prepare traffic demand management programs.
o Policy LU -3.8: Require new development and discretionary actions to annex into a Congestion Management Community Facilities District.
The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to the transportation analysis for the propos ed project are identified below. Policy M -1.4, which addresses LOS is analyzed in Section 3.8-4, Land Use and Planning. • Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods. o Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map. o Policy M -1.2: Require new development to finance and construct internal adjacent roadway circulation and City-wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian, and bicycle facilities. o Policy M -1.3: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the city.
o Policy M-1.4: Utilize multi-modal LOS techniques to evaluate transportation facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
LOS D or better for Vehicles as a prioritized mode
⸋ Generally, provides facilities that have minimum vehicle congestion during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).
o Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network. o Policy M-1.7: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor. • Goal M-2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.
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o Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate , within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network. o Policy M-2.3: Consider roundabouts, as appropriate, as an intersection control device with demonstrated air quality, traffic efficiency, and safety benefits. • Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City.
o Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance, and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate. o Policy M-3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.
o Policy M-3.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians.
o Policy M -3.9: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian-scale lighting, way finding signage, transit shelters, and other approp riate amenities.
The Environmental Justice Element of the General Plan identifies specific goals and policies related to access to and facilitation of walking, bicycling, and transit use. Those that are applicable to the proposed project are identified below.
• Goal EJ -1: Reduce greenhouse gas emissions, enhance air quality, and reduce impacts associated with climate change.
o Policy EJ -1:1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices (See Policy LU-1.1). o Policy EJ -1.3: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use (See Policy LU -
2.1).
o Policy EJ -1.6: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the city (See Policy M-1.3). o Policy EJ-1.8: Develop an integrated multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution
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and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City (See Policy M-3.1).
• Goal EJ-2: Locate public facilities and services equitably throughout the community. o Policy: EJ-2.10: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network (See Policy M-1.6). o Policy: EJ-2.11: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Stre ets will prioritize pedestrian and bicycle users through the corridor (See Policy M-1.7). • Goal EJ-5: Encourage physical activity and improved physical fitness. o Policy: EJ-5.1: Provide non-motorized (pedestrian and bicycle) access/ circulation within, and to, mixed-use centers to reduce reliance on the automobile (See Policy LU-3.4). o Policy EJ - 5.2: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways (See Policy LU-3.5).
o Policy EJ-5.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians (See Policy M-3.5). o Policy EJ -5.6: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian-scale lighting, way finding signage, transit shelters, and other appro priate amenities (See Policy M-3.9).
The proposed project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As presented in Table 3.8 -12 in Section 3.8 , the project is consistent with the applicable transportation-related goals and policies.
3.11.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts. A project may be deemed to have a significant impact on transportation if it would:
• Threshold #1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; or • Threshold #2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b); or • Threshold #3: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or • Threshold #4: Result in inadequate emergency access.
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3.11.4 Project Impact Analysis
Threshold #1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
Site access is proposed via one full-access driveway to Woodward Street. The project site is currently fronting a four -lane undivided roadway that primarily serves residents. Per the Local Transportation Analysis, the project driveway is calculated to operate at LOS B during the AM and PM peak hours. The following design features are included in the project design per LLG’s recommendation:
• Access point shall provide adequate driveway sight distance. • A 50-foot southbound left-turn pocket shall be provided on Woodward Street to allow for left - turn access to the project site outside of the southbound through lane.
The project would not result in any conflicts related to plans or policies addressing transit, bicycle, and pedestrian facilities. The project is located within 1,000 feet of NCTD transit lines, including bus routes and 0.2 mile from closest SPRINTER station at the San Marcos Civic Center. Construction of the project may result in a temporary disruption of the bicycle lane and sidewalk along the project frontage with Woodward Street. This specifically relates to the extension of the water and sewer lines to serve the project. The contractor would install signage in advance of the work to notify cyclists and pedestrians.
Sidewalk connection currently exists 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 Ran cheros 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). The project proposes sidewalks throughout the Specific Plan area to accommodate safe pedestrian travel through each area.
Additionally, based upon the analysis presented in Section 3.8.4, the project would not result in an inconsistency with the Mobility Element of the City’s General Plan. The Local Transportation Analysis determined that the project would result in 368 total average daily trips (ADT). All study intersections and street segments are calculated to operate acceptably at LOS D or better with the addition of project and cumulative project traffic under Near Term (Interim Year) 2026 and Long -Term (Horizon Year) 2050 conditions with the exception of two intersections:
• Mission Road/ Woodward Street (San Marcos Boulevard) - LOS F during the AM and PM peak hours
• San Marcos Boulevard/ Twin Oaks Valley Road – LOS E during the AM and PM peak hours.
The Local Transportation Analysis concluded that the trips associated with the proposed project would not be enough to increase average vehicle delay by two seconds, which is the threshold for intersections operating at LOS E or F , as identified in the Mobility Element of the General Plan (LLG 2023a).
Therefore, no impact related to a conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities is identified for the project.
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Threshold #2: Conflict or be Inconsistent with CEQA Guidelines Section 15064.3(b).
The City’s Transportation Impact Analysis (TIA) Guidelines (San Marcos 2020) provide several screening approaches to identify when a project should be expected to cause a less -than-significant impact related to VMT. The City of San Marcos TIA Guidelines suggest that a detailed transportation VMT analysis applies to all land development projects, except those that meet at least one of the screening criteria. Relevant screening criteria for the proposed project is described below:
• Adjacency to High Quality Transit. high -quality transit area is defined as the one -half mile walkshed around either of the following:
o An existing major transit stop, defined as a site containing an existing rail transit station or the intersection of two or more bus routes with a combined frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. In addition, a rail transit station must be within 0.25 miles of bus stops serving at least one bus route with individual service intervals no longer than 30 minutes during peak commute periods per route in order to qualify as a high-quality transit area. o An existing stop along a high-quality transit corridor, defined as a corridor with fixed route bus service with combined service intervals (gaps between buses serving the corridor) no longer than 15 minutes during peak commute hours.
However, this presumption does not apply if the project:
1 Has a floor area ratio (FAR) of less than 0.75;
2 Includes more parking for use by residents, customers, or employees of the project than required by the City;
3 Is inconsistent with the City’s current General Plan, as determined by the City; or, replaces affordable residential units with a smaller number of moderate - or high-income residential units.
VMT Analysis
Based upon the criteria provided above, the proposed project would be screened out from conducting a detailed VMT Analysis because the project is located within a high-quality transit area. Appendix A of the VMT analysis (Appendix M of the EIR) contains the TIA Guidelines’ High-Quality Transit Areas map.
The following is a discussion of the three items that are potential caveats (LLG 2023b).
Floor Area Ratio
The Specific Plan’s development standards require a minimum 0.75 FAR.
Parking
The project proposes a total of 46 condominium units. Per the City of San Marcos Municipal Code, Chapter 20.340, 108 parking spaces would be required. A summary of the parking code requirements and calculations are shown in
Table 3.11-2. The project proposes to provide 108 parking spaces.
Therefore, the project would meet the parking requirements but would not exceed them.
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Table 3.11-2. City of San Marcos Municipal Code Parking Requirements and Calculations Parking Code Land Use Required Off-Street
Parking Rate (1)
Project Quantity
(dwelling units)
Required Number
of Parking Spaces
Residential Uses
Duplex 2 spaces/ du 46 3-bedroom units 92
Guest 1 space/ du 46 3-bedroom units 16
Total Spaces 108
Source: LLG 2023b.
Notes: (1) Rates from the City of San Marcos Municipal Code, Chapter 20.340 du= dwelling unit
General Plan Consistency
The project site has a General Plan Designation of SPA (Specific Plan Area) 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 subject property from Richmar Specific Plan to Woodward 46 Specific Plan.
Table 3.8-12 in Section 3.8 Land Use summarizes the applicable San Marcos General Plan goals and policies relating to land use. As shown in Table 3.8 -12, the project is consistent with the applicable goals and policies. Therefore, the proposed project is considered to be screened out of a detailed VMT analysis and may be presumed to cause a less-than-significant VMT impact.
Threshold #3: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) The project area would have one internal circulation system. The conceptual circulation plan is included as Figure 2-11. The proposed access driveway would provide a minimum of 24 feet of paved driving surface measured curb to curb. Where provided, a minimum 4- foot concrete sidewalk would accommodate safe pedestrian travel through each area. Units requiring American Disability Act (ADA)
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accessibility would be located on the western side of the driveway where a 4.5 -foot sidewalk would run the length of the development and would connect units to the common recreation area. A 6 -inch curb and gutter w ould be constructed to either side of the driveway and each travel lane shall be a minimum of 12 feet from the center line.
The internal circulation network proposed for the project site does not include any hazardous design features and the project does not propose any incompatible uses. The project’s internal roadways are designed to provide safe movement of bicycle, pedestrian, and vehicle traffic , including passenger vehicles and heavy vehicles, through the project site (LLG 2023a). The project has been designed to provide a safe, separated walkway from pedestrians from the project site to Woodward Street.
As described above in Threshold #1, site access is proposed via one full-access driveway to Woodward Street. The project site is currently fronting a four -lane undivided roadway that primarily serves residents. Per the Local Transportation Analysis, the project driveway is calculated to operate at LOS B during the AM and PM peak hours. The following design features are included in the project design per LLG’s recommendation:
• Access point shall provide adequate driveway sight distance. • A southbound left -turn pocket shall be provided on Woodward Street to allow for left -turn access to the project site outside of the southbound through lane.
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.
Driveway Sight Distance Analysis
LLG performed a field survey to determine whether or not the minimum required intersection sight distances can be achieved for drivers turning left from Woodward Street. Per the AASHTO Geometric Design of Highways and Street Manual, the point of observation for the review is offset 14.5 feet from the edge of the traveled way. The driver’s eyes are measured at 3.5 feet from the ground surface, and the object to be observed is also 3.5 feet from the ground. The location of the object to be observed is located in the middle of the travel lane.
Based on the proposed traffic control at the project driveway, the appropriate sight distance formula would reflect the left -turn from the minor road with stop control and represent the appropriate constraint on drivers leaving the project site. The formula used to calculate sight distance has variables which are dependent on the design speed of the major road and expected maneuver time pertaining to each specific turning movement. Per the guidelines, the intersection distance for both left and right approaches of the minor leg needs to be determined for vehicles turning left out of the project driveway. According to the sight distance analysis, looking left from the driveway towards the northbound approach, the minimum required intersection sight distance is 383 feet, and looking right from the driveway towards the southbound approach the sight distance is 441 feet. Based on LLG field observations, sight distance requirements would be met for both northbound (383 feet) and southbound (441 feet) approaches (LLG 2023a).
In summary, the project does not include any hazardous design features or any incompatible uses, provides adequate sight distance, and has been designed to provide safe movement throughout and around the project site. Impacts would be
less than significant.
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Threshold #4: Result in inadequate emergency access.
Access to the project site would be via one unsignalized driveway on Woodward Street. The entrance driveway would be ungated and would be 24 -feet wide. Internal vehicular movement would be via a 24-foot-wide drive aisle. The Specific Plan Area would accommodate the Pierce Pumper truck, which is the emergency vehicle in operation with the City of San Marcos Fire Department. A 24-foot minimum curb to curb driveway would be constructed to maintain a minimum road width and any portion of the driveway with grades 12% and steeper would require concrete pavement surface with a broom finish suitable for emergency vehicles per City of San Marcos Fire Department requirements. The project design would include a 30-foot-wide emergency vehicle turnaround area at the northeast corner of the proposed development. The cul -de-sac at the southern end of the site would also serve as an emergency vehicle turnaround area. Both turnaround areas would accommodate the Pierce Pumper truck.
The project would not include any hazardous design features or any incompatible uses, provides adequate sight distance, and has been designed to provide safe movement throughout and around the project site. The project design has also been reviewed by the Fire Marshal and no issues related to inadequate emergency access were identified. Impacts would be less than significant.
3.11.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to transportation, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to hazards. All of the cumulative projects identified in Table 2 -4 are considered in this cumulative analysis.
Cumulative Policy Impact
The related projects and other cumulative development in San Marcos would be subject to the same circulation-related programs, plans, ordinances, and policies as the proposed project. Cumulative projects would be required to demonstrate consistency with th e SANDAG Regional Plan, San Marcos General Plan, San Marcos Bikeway Master Plan, and San Marcos TIA Guidelines, which guide development of transportation systems and circulation in the city. The cumulative projects primarily propose medium- to high-density residential and mixed -use development in areas with good transit connectivity and active transportation options, reducing dependence on automobiles and encouraging more active travel modes. As a result, cumulative impacts related to a conflict with a prog ram plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities would be
less than significant.
Cumulative VMT Analysis
According to the City’s TIA Guidelines (San Marcos 2020) if a land use project (or a component of a mixed-use project) is screened out of requiring a detailed existing VMT analysis or if it falls below the
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existing VMT thresholds outlined in Table 2 of the TIA Guidelines, it will also result in a less than significant cumulative impact. Therefore, the proposed project’s cumulative VMT impact would be less than significant.
Hazards Due to Design and Emergency Access
Site design hazards and emergency access are analyzed and addressed on a project-by-project basis.
Each of the projects in Table 2 -4 would be reviewed to ensure that the site design does not include any traffic-related hazards and that there would be adequate emergency access or required mitigation measures to reduce impacts. Therefore, impacts related to hazardous design and emergency access would be less than significant.
3.11.6 Mitigation Measures
Based upon the analysis presented in Sections 3.11.4 and 3.11.5, impacts were determined to be less than significant. No mitigation measures are required.
3.11.7 Conclusion
Based upon the analysis presented in Section 3.11.4, the project would not have an impact related to a conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
The project would also have a less than significant impact related to VMT based on the City’s screening criteria.
Project impacts related to hazards due to a design feature, incompatible use or inadequate emergency access were determined to be less than significant.
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3.12 Tribal Cultural Resources
Introduction
This section analyzes the potential impacts of the proposed project on tribal cultural resources. As defined by Public Resources Code Section 21074, a tribal cultural resource is a site, feature, place, and or cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is 1) either on or eligible for the California Register of Histor ic Resources (CRHR) or a local historic register, or 2) determined by the City, at its discretion to treat the resources as a tribal cultural resource (Public Resources Code Section 5024.1).
Cultural resources (historical resources, archaeological resources and human remains) are analyzed separately in Section 3.4, Cultural Resources, of the Environmental Impact Report (EIR).
The analysis in this section is based upon the following information:
• Government-to-government tribal consultation between the City and California Native American Tribes pursuant to the procedures in Assembly Bill 52 and Senate Bill 18. • Archaeological Survey and Evaluation Report for the Woodward 46 Project, City of 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.
11 Table 3.12-1 summarizes the tribal cultural resources project - and cumulative - level impacts, by threshold.
3.12.1 Existing Conditions
A detailed description of the project site’s natural setting, archeological context, ethnographic context, records search information, and ASM’s informal tribal coordination and information gathering is presented in Section 3.4 (Cultural Resources). The following section provides information about tribal cultural resources and a summary of government -to-government tribal consultation efforts pursuant to AB 52 and SB 18. Although SB 18 is not a CEQA issue, the tribal consultation was simultaneous under both laws.
11 http://www.san-marcos.net/work/economic-development/general-plan
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Table 3.12-1. Tribal Cultural Resources Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 – Cause a substantial adverse
change in the significance of a tribal
cultural resource, defined in Public
Resources Code Section 21074 as
either a site, feature, place, cultural
landscape that is geographically defined
in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native
American tribe, and that is listed or
eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code
Section 5020.1(k).
Potentially
Significant
Less Than
Significant
Mitigated to Less
Than Significant
#2 – Cause a substantial adverse
change in the significance of a tribal
cultural resource, defined in Public
Resources Code Section 21074 as
either a site, feature, place, cultural
landscape that is geographically defined
in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native
American tribe, and that is a resource
determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to
criteria set forth in subdivision (c) of
Public Resources Code Section 5024.1.
In applying the criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall
consider the significance of the resource
to a California Native American tribe.
Potentially
Significant
Less Than
Significant
Mitigated to Less
Than Significant
Records Search
A detailed records search including previous cultural resources reports, previously recorded cultural resources and archival research was conducted for the project. Please see Section 3.4, Cultural Resources, for a summary.
Tribal Consultation
In addition to ASM reaching out to Tribes as part of the archeological report preparation (see Section
3.4), the City provided notice to Tribes pursuant to AB 52 and SB 18 and consulted with Tribes.
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Under AB 52, the City sent project notification letters on May 23, 2023 to the following California Native American tribes, which had previously submitted general notification requests in writing pursuant to 21080.3.1(d) of the Public Resources Code. Each recipient was provided a brief description of the project and its location, the lead agency contact information, and a notification that the tribe has 30 days to request consultation, pursuant to PRC Section 21080.3.1(d). The 30-day response period concluded on June 22, 2023.
• Mesa Grande Band of Mission Indians
• Pechanga Band of Indians
• Rincon Band of Luiseño Indians
• San Luis Rey Band of Mission Indians
Under SB 18, on December 13, 202 2, the City sent project notification letters to the following California Native American tribes named on the NAHC list. Each recipient was provided a brief description of the project and its location, the lead agency contact information, and a notification that the tribe has 90 days to request consultation, pursuant to Government Code Section 65352.3(a)(2).
The 90-day response period concluded on March 13, 2023. • Barona Group of the Capitan Grande
• Campo Band of Diegueno Mission Indians
• Ewiiaapaayp Band of Kumeyaay Indians
• Iipay Nation of Santa Ysabel
• Inaja-Cosmit Band of Indians
• Jamul Indian Village
• Juaneno Band of Mission Indians Acjachemen Nation 84A • Kwaaymii Laguna Band of Mission Indians
• La Jolla Band of Luiseño Indians
• La Posta Band of Diegueño Mission Indians
• Manzanita Band of Kumeyaay Nation
• Mesa Grande Band of Mission Indians
• Pala Band of Mission Indians
• Pauma Band of Luiseño Indians
• Pechanga Band of Indians
• Rincon Band of Luiseño Indians
• San Luis Rey Band of Mission Indians
• San Pasqual Band of Diegueño Mission Indians
• Soboba Band of Luiseño Indians
• Sycuan Band of the Kumeyaay Nation
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• Viejas Band of Kumeyaay Indians
As a result of the initial notification letters, the City received the following responses, and engaged in consultation with these tribes as summarized below.
San Luis Rey Band of Mission Indians
The tribe responded on March 16, 2023 to request consultation. The City initiated consultation and began discussing the project with the tribe during monthly consultation meetings. The City transmitted the cultural resources technical report to the tribe on April 18, 2023. Subsequent consultation focused on the request to place the features in open space or within landscaping. The City and project proponent carried out an alternatives analysis and held a site visit with Tribal representative Cami Mojado. On October 17, 2024, the City transmitted suggested revised mitigation measures to the tribe and on the same date, the Tribe responded with a letter stating that the mitigation measures are acceptable to the tribe and requested to conclude consultation. These mitigation measures have been incorporated into this EIR. As a result, the City considers consultation with the San Luis Rey Band of Mission Indians concluded with agreement in accordance with Sections 21080.3.2(b)(1) and 21082.3(d)(1) of the Public Resources Code.
Rincon Band of Luiseño Indians
The tribe responded on June 20, 2023 to request consultation under AB 52, and responded on January 26, 2023 to request consultation under SB 18 . The City initiated consultation immediately by discussing the project with tribal representatives during monthly consultation meetings. The City transmitted the cultural resources report to the tribe as requested on April 18, 2023. During the July 14, 2023 meeting, tribal representative Cheryl Madrigal discussed concerns related to coordination with the archaeologi cal consultant. The tribe sent a confidential comment letter to the City dated November 9, 2023, which outlined the tribe’s comments and concerns. The City transmitted the confidential report appendix for the project to the tribe on November 27, 2023, and sent the archaeological site records and GIS data to the tribe on January 10, 2024. Tribal and City representatives conducted a field visit on March 22, 2024, which led to the need for an alternatives analysis to contemplate feasibility for complete avoidance. The alternatives analysis was sent to the tribe on April 22, 2024, and the tribe responded on June 21, 2024. Subsequent monthly meetings with the tribe focused on appropriate mitigation measures, which led to multiple revisions. The final mitigation measures were provided to the tribe on August 30, 2024.
Throughout 2024, the City continued to seek agreement with Rincon over the impacts and mitigation measures required to reduce the impact to less than significant. Ultimately, although Rincon did not provide written concurrence with the mitigation measures, the City determined that, after a good faith and reasonable effort, further consultation on the project would not be fruitful and that meaningful consultation on the project has been exhausted. As a result, the City considers consultation with the Rincon Band of Luiseño Indians complete without agreement in accordance with Section 21080.3.2(b)(2) of the Public Resources Code. The City has exercised its agency discretion and will require mitigation measures developed in consultation with tribes. The information provided to the City to date, including confidential information that cannot be disseminated publicly, was taken into account in the project impact analysis further below.
Pechanga Band of Indians
The tribe responded on January 5, 2023 to request consultation under SB 18 and on June 23, 2023 under AB 52 . The City began discussing this project with tribal representatives during periodic
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coordination meetings. During the May 14, 2024 meeting, the City and tribal representatives discussed options for avoidance and preservation in place, and discussed the general sensitivity of the ar ea. The city sent the alternatives analysis and proposed mitigation measures to the tribe immediately following the meeting. The City received no response.
The City provided all information requested by the tribe and although no written comments were provided, enough consultation occurred that the City considers consultation with the Pechanga Band of Indians complete and in substantial agreement in accordance with Sections 21080.3.2(b)(1) and 21082.3(d)(1) of the Public Resources Code. The information provided to the City to date, including confidential information that cannot be disseminated publicly, was taken into account in the project impact analysis further below.
San Pasqual Band of Mission Indians
The tribe responded on May 1, 2023 to request consultation under SB 18 and forwarded an unsent consultation request letter dated January 10, 2023 . The City initiated consultation immediately by scheduling a consultation meeting that was held on May 11, 2023. The City shared information about the project and answered questions from the Tribe. No further consultation was deemed necessary, and the City considers consultation with the San Pasqual Band of Mission Indians concluded.
Other Tribes
The balance of the tribes did not request consultation under either AB 52 or SB 18.
Because the City initiated consultation with all tribes that requested it, the threshold for release of the CEQA document for public review in PRC Section 21080.3.1(b) has been met. The City considers consultation with all consulting tribes concluded in good faith, as required by PRC Section 21082.3(d).
Tribal Cultural Resources
As detailed in Section 3.4, Cultural Resources, of the EIR, ASM identified one prehistoric Native American archaeological site, which is also considered a tribal cultural resource under CEQA. Site P- 37-040572/CA-SDI-23456 is comprised of two bedrock milling outcrops on granitic outcrops . No associated artifacts or cultural materials were identified at the site (ASM 2024).
3.12.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to tribal cultural resources. The analysis of tribal cultural resources is a State requirement under CEQA, as required by AB 52, described below. The City also has goals and policies in the General Plan Conservation and Open Space Element related to cultural resources, as described below.
State
Senate Bill 18
SB 18, approved in 2004, amends the California Civil Code and the California Government Code, requiring cities and counties to contact and consult with California Native American tribes prior to adopting or amending any general plan or specific plan, or designating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within the city’s or county’s jurisdiction. SB 18 also requires cities and counties to hold in strict confidence any information about the specific identity, location, character, or use of these resources.
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In 2005, the Office of Planning and Research published Tribal Consultation Guidelines to guide cities and counties on the process of engaging in consultation in accordance with SB 18. The Native American Heritage Commission maintains a list of California Native American Tribes with whom cities and counties must consult pursuant to SB 18.
Assembly Bill 52
AB 52 was approved in 2014 and adds new requirements regarding consultation with California Native American Tribes and consideration of tribal cultural resources. The law went into effect on July 1, 2015, and after that date, if requested by a California Native American Tribe, lead agencies must consult prior to the release of a Negative Declaration, Mitigated Negative Declaration or Draft EIR.
Health and Safety Code 8010-8011
This code is intended to provide consistent state policy to ensure that all California Native American human remains and cultural material are treated with dignity and respect. The code extends policy coverage to non-federally recognized tribes and federally recognized groups.
Assembly Bill 2461
The section provides procedures for private land owners to follow upon discovering Native American human remains. Land owners are encouraged to consider culturally appropriate measures if they discover Native American human remains as set forth in California PRC 5097.98.
Local
San Marcos General Plan Conservation and Open Space Element The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of archaeological and historic resources. The following goals and policies apply to the project:
• Policy COS -2.5: Continue to review future development proposals to ensure that cultural resources (including prehistoric, historic, paleontological, and SB 18 Tribal resources) are analyzed and conserved in compliance with CEQA requirements. • Goal COS -11: Continue to identify and evaluate cultural, historic, archaeological, paleontological, and architectural resources for protection from demolition and inappropriate actions.
• Policy COS -11.1: Identify and protect historic and cultural resources including individual properties, districts, and sites (e.g., archaeological sites) in compliance with CEQA.
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, 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 2024 . The guidelines are generally meant to aid third party consultants who prepare archaeological or architectural history inventories, surveys, evaluations, and other technical documents. These guidelines include information pertaining to the minimum qualifi cations, records
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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 202 4). ASM prepared the archaeological resources inventory report in accordance with these guidelines.
3.12.3 Thresholds of Significance
The determination of significance for tribal cultural resources is based on CEQA Guidelines Appendix G. Impacts to tribal cultural resources would be significant if the proposed project would:
• Threshold #1: Cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Publi c Resources Code Section 5020.1(k); or
• Threshold #2: Cause a substantial adverse change in the significance of a tribal cultural resource that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth i n subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
3.12.4 Project Impact Analysis
Tribal consultation under AB 52 and SB 18 identified P-37-040572/CA-SDI-23456 as a tribal cultural resource. As discussed in Section 3.4, Cultural Resources, P-37-040572/CA-SDI-23456 was identified during the project survey and represents a small prehistoric site with two cultural features (the western cultural feature and the eastern cultural feature). Additional information about this resource is restricted from public distribution and is only generally summarized herein; however, the specific information that led to the impact assessment in this EIR was taken into account by the City.
Grading for the proposed project would impact P-37-040572/CA-SDI-23456. It is anticipated that the western cultural feature can be avoided; however the eastern cultural feature will be impacted by the project grading.
Threshold #1: Cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).
The project will impact a portion of P-37-040572/CA-SDI-23456, specifically the eastern cultural feature. Based upon the cultural resources study prepared for the project (ASM 20 24) P-37- 040572/CA-SDI-23456 is not eligible for listing in the CRHR, and therefore it does not qualify as a tribal cultural resource under CEQA.
Threshold #2: Cause a substantial adverse change in the significance of a tribal cultural resource that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth i n subdivision (c) of Public Resources Code Section
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5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
The City received written comments from one tribe regarding the significance of P-37-040572/CA-SDI- 23456 as a tribal cultural resource. The nature of the comments and the specific information provided is confidential and cannot be disseminated to the public; however, this information was reviewed in detail by the City. Ultimately, the City determined that im plementation of the proposed project would result in a significant impact on a tribal cultural resource based on the substantial evidence threshold.
The project civil engineer examined the feasibility of an alternative project design, however, the design requirements for the access road, the steep topography and limited buildable area made it infeasible to create an alternative design which would avoid the eastern cultural feature. Only partial preservation in place was deemed feasible, and this has been incorporated into the mitigation measures.
As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource. This represents a significant impact (Impact TCR-1) and mitigation is required. • Impact TCR-1 As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource that is determined, by the City, based on substantial evidence, to be a tribal cultural resource.
3.12.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to tribal cultural resources, the cumulative analysi s is based upon a regional approach to determine the proposed project’s contributing effect on potential cumulative impacts on tribal cultural resources.
The proposed project will have a significant impact on a tribal cultural resource. Other development projects in the City that are subject to CEQA would require consultation with local tribes. Tribal consultation may provide information on whether tribal c ultural resources are present on a given project site. Depending on the information provided, these sites may be determined to be a tribal cultural resource and how a given project may impact them. If projects are determined to have a significant impact on tribal cultural resources, mitigation would be required to reduce potential impact.
The date, all projects in t he City have reduced potential tribal cultural resources impacts to below a level a significance.
Information provided by one consulting tribe included statements about the cumulative effect on tribal cultural resources in the City as well as the cumulative effect on the tribal cultural resource caused by past mitigation efforts. The City considered this information in light of the substantial evidence and significant nexus thresholds, the development of property in other parts of t he City, and the existing laws that require tribal consultation as described above. The City has determined that the projec t
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would result in a less than significant cumulative impact on tribal cultural resources. No mitigation is required.
3.12.6 Mitigation Measures
Mitigation measures MM-TCR-1 through MM-TCR-12 would reduce potential tribal cultural resources impacts to below a level of significance.
MM-TCR-1 Project-Specific Ethnographic Synthesis. The Applicant shall fund the preparation of a project-specific ethnographic synthesis, not to exceed what is described in the confidential proposal provided by the Rincon Band of Luiseño Indians dated August 27, 2024. No later than 30 days after the final Project approval, the Applicant shall extend a written offer to the Rincon Band of Luiseño Indians to enter into an agreement with their ethnographer to conduct and prepare the ethnographic synthesis in acc ordance with the aforementioned proposal. In the event of a dispute between the parties in entering into the agreement for the ethnographic synthesis, and after a good faith and reasonable effort, the City shall serve as the final arbiter. The City will determine the scope and content of an ethnog raphic synthesis in that event.
The synthesis will draw from oral histories, elder knowledge, and other sources of confidential Indigenous knowledge that relate to the tribal cultural resource affected by the proposed project. The ethnographer shall be afforded up to 90 days following funding of the ethnography to carry out any field visits with appropriate tribal representatives. After 90 days, or sooner if the ethnographer completed the field studies, the Applicant shall be permitted to proceed with ground disturbing activities and cons truction of the project while non -field-based data gathering, such as ethnographic interviews of informants and review of tribal documents, is being carried out. Upon completion, a public (redacted) version of the ethnographic synthesis shall be submitted to the California Historical Resources Information System and the City. The final non-redacted study shall belong to the Rincon Band of Luiseño Indians.
MM-TCR-2 Monitoring Agreement. Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall enter into a Monitoring Agreement with a Traditionally and Culturally Affiliated Native American Tribe (TCA Tribe), identified in consultation with the City. The purpose of the Monitoring Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the TCA Tribe for the monitoring for Native American human remains, funerary objects, cultural and/or religious landscapes, ceremonial items, traditional gathering areas, and other tribal cultural resources. Such resources may be located within and/or discovered during ground disturbing and/or construction activities for the proposed project, including any additional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities.
Any project -specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the TCA Tribe requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation.
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The landowner shall relinquish ownership of all non -burial related tribal cultural resources collected during construction monitoring and from any previous archaeological studies or excavations on the project site to the TCA Tribe for proper treatment and disposition per the Monitoring Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction. The requirement and timing of such release of ownership, and the recipient thereof, shall be reflected in the Monitoring Agre ement. If the TCA Tribe does not accept the return of the cultural resources, then the cultural resources will be subject to curation.
MM- TCR-3 Construction Monitoring. Prior to the issuance of a Grading Permit or ground disturbing activities, the Applicant/Owner or Grading Contractor shall provide written documentation (either as signed letters, contracts, or emails) to the City’s Planning Division stating that the Rincon Band and San Luis Rey Band have been retained at the Applicant/Owner or Grading Contractor’s expense to implement the construction monitoring program, as described in the Monitoring Agreement.
Native American monitoring shall include one monitor from the Rincon Band of Luiseno Indians and one monitor from the San Luis Rey Band of Luiseno Indians simultaneously. In the event that either tribe chooses not to enter into an agreement or fails to respond to the offer, the Cit y shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.
The monitors shall be provided at least 72 hours’ notice of the initiation of construction and be kept reasonably apprised of changes to the construction schedule. In the event that a monitor is not present at the scheduled time, work can continue without the monitor present, as long as the notice was given and documented.
The TCA Native American monitor shall be invited to attend all applicable pre - construction meetings with the General Contractor and/or associated subcontractors to present the construction monitoring program. The TCA Native American monitor shall be present on site during grubbing, grading, trenching, and/or other ground disturbing activities that occur in areas of native soil or other permeable natural surfaces that have the potential to unearth any evidence of potential archaeological resources or tribal cultural resources. In areas of artificial paving, the TCA Native American monitor shall be present on site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb the original pre -project ground su rface to identify any evidence of potential tribal cultural resources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non-commercial sources that have been determined to be absent of tribal cultural resources by the TCA Nat ive American monitor.
The Qualified Archaeologist (CR-1) and TCA Native American monitor shall maintain ongoing collaborative coordination with one another during all ground disturbing activities. The requirement for the construction monitoring program shall be noted
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on all applicable construction documents, including demolition plans, grading plans, etc. The Applicant/Owner or Grading Contractor shall provide written notice to the Planning Division and the TCA Tribes, preferably through e-mail, of the start and end of all ground disturbing activities.
MM-TCR-4 Exclusionary Fencing of ESA. Prior to the commencement of clearing and grubbing of the project area, the contractor shall install high visibility temporary exclusionary fencing around the western cultural feature under the direction of the Qualified Archaeologist and TCA Native American monitor. The contractor shall be responsible for ensuring that the fence is maintained throughout the duration of ground disturbing activity associated with project construction. The feature shall be designated as an Environmentally Sensitive Area on grading plans.
MM-TCR-5 Monitoring of Activity. When heavy equipment operation or construction -related activity that do not involve ground disturbance reach 100 feet of the eastern cultural feature, a TCA Native American monitor must be present. The purpose of the monitoring of non -ground disturbing activity at this location is to ensure that personnel do not inadvertently impact the resource. Monitoring of non -ground disturbing activity shall not be required beyond 100 feet of the eastern cultural feature.
MM-TCR-6 Capping. Prior to the commencement of ground disturbing activities associated with project construction, the contractor shall, under the direction of the Qualified Archaeologist and TCA Native American monitor, cap the eastern cultural feature.
The cap shall be composed of a layer of geotextile or geogrid on the surface of the feature, followed by at least 10 foot by 10 foot area feet of culturally sterile soil.
MM-TCR-7 Controlled Grading. Grading plans for the project construction shall direct the contractor to use controlled grading methods within 500 feet of the eastern and western cultural features. Controlled grading will involve use of a small piece of equipment or a road grader to peel away native soil using shallow cuts made in approximately five-inch-deep layers. The grading equipment will push the shallow cuts of soil to the outside of the cultural deposit area. This deposited soil may be sampled and screened to ensure adequate detection of any cultural materials that may be present. The Qualified Archaeologist and TCA Native American monitor will direct the controlled grading process, including the pace of the grading and the depth of layers to be removed. If potential tribal cultural resources are encountered, the procedures in Mitigation Measure TCR-8 shall apply. If no cultural deposits are encountered, the road grader will continue to make passes until one of two conditions are met (whichever occurs first): 1) Grading will continue to a depth of 30 centimeters below the depth of any recorded artifacts, suggesting an end to the potential for cultural deposits; or 2) non -cultural formational soils are encountered that predate any human occupation of this location. Once the cultural deposit has been completely removed, the controlled grading process will be terminated and mass grading may proceed.
MM-TCR-8 Unanticipated Discovery Procedures. TCA Native American monitors may temporarily halt or divert ground disturbing activities if previously unknown tribal cultural resources are discovered during construction activities. Ground disturbing activities shall b e temporarily directed away from the area of discovery for a
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reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be not associated with Native American culture, it will be subject to MM CR -2. Native American tribal cultural resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture (subject to MM-CR-2), then the Qualified Archaeologist, TCR Tribes, TCR monitors, and City shall coordinate on appropriate treatment.
All unearthed tribal cultural resources will be collected, temporarily stored in a secure location, and repatriated according to the consulting tribes, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.
If a determination is made that the tribal cultural resources are considered potentially significant by the TCA Tribe and the TCA Native American monitor, then the City and the TCA Tribe shall determine, in consultation with the Applicant/Owner, the culturally appropriate treatment of those resources.
All sacred sites and significant tribal cultural resources encountered within the project area shall be avoided and preserved as the preferred mitigation. If avoidance of the resource is determined to be infeasible by the City as the Lead Agency, then the City shall require additional culturally appropriate mitigation to address the negative impact to the resource. The TCA Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation. Any cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site, and repatriated according to the terms of the Monitoring Agreement, unless ordered to do otherwise by a responsible agency or court of competent jurisdiction. The removal of any artifacts from the project site will be inventoried with oversight by the TCA Native American monitor.
MM-TCR-9 Human Remains. As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to o verlie 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 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
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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 archae ological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public.
According to California Health and Safety Code, six 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 d isagreement 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)).
MM-TCR-10 Reburial. Prior to the approval of grading plans, the Applicant shall designate a reburial location onsite and note the location as excluded from construction - related activity on grading plans. The reburial location shall be used to rebury any cultural mat erials encountered during monitoring, and to rebury existing collections from the previous data recovery effort. Following the completion of all ground disturbing activity and reburial of all materials and before the issuance of a Certificate of Occupancy, the Applicant shall: 1) ensure that native plants and natural barriers are installed (in consultation with TCA tribes) as part of landscaping; 2) file a deed restriction on the parcel that protects the reburial location from future disturbance and provide a copy to the City. The exhibit for the deed restriction and purpose of it shall be kept confidential and out of the public record.
MM-TCR-11 Deed Restriction. Prior to the issuance of a Certificate of Occupancy, the Applicant shall record a deed restriction with the County of San Diego for the western cultural feature that restricts ground disturbing activities at that location. A copy of the recorded deed restriction shall be provided to the City as proof of compliance.
MM-TCR-12 Access Agreement. Prior to the issuance of a Certificate of Occupancy, the Applicant shall extend a written offer to each consulting tribe to enter into an access agreement, which is binding on successors and heirs to the property, that allows for legal access to visit the reburial location after construction is completed.
If more than one tribe elects to enter into an access agreement, each tribe shall have its own agreement. In the event that one or more consulting tribe does not respond to the offer within 30 days of receipt, then the City will deem this mitigation measure satisfied provided that the offer was extended and documented in accordance with this measure.
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3.12.7 Conclusion
The project would demolish a portion of site P-37-040572/CA-SDI-23456. Based upon consultation with local tribes pursuant to SB 18 and AB 52, the project site contains known tribal cultural resources that are listed or eligible for listing in the CRHR or in a local register of historical resources.
The City has determined, in consultation with Tribes, that the proposed project would result in a significant impact to a tribal cultural resource under Threshold #1 . Mitigation measures MM -TCR-1 through MM-TCR-12 shall be required to reduce the level of impact to less than significant.
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3.13 Utilities and Service Systems
Introduction
This section identifies the existing service providers for utilities and service systems, including water, wastewater, stormwater drainage, electric power, natural gas, and telecommunications facilities and analyzes the ability of these providers to serve the proposed project based upon current utility infrastructure. A detailed energy consumption analysis is included in Section 3.5, Energy, of the EIR.
The analysis in this section relies on the following document, which is included as Appendix N of the EIR. of the EIR:12
• Woodward 46 Water and Sewer Study, Final Technical Memorandum , prepared by Vallecitos Water District, April 6, 2023.
The Water and Sewer Study, prepared by the Vallecitos Water District (VWD) considered water demand and sewage generation increases due to the proposed General Plan Amendment and development of the proposed project. The study also analyzed the ability of VWD’s infrastructure to serve the proposed project and made recommendations for the capital improvements for demand generated by the proposed project.
Table 3.13-1 summarizes the utilities and service system analysis, by threshold.
Table 3.13-1. Utilities and Service Systems Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 - Require or result in the relocation
or construction of new or expanded
water, wastewater treatment or
stormwater drainage, electric power,
natural gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effects?
Less than
Significant
Less than
Significant
Less than
Significant
Without Mitigation
#2 - Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry, and
multiple dry years?
Less than
Significant
Less than
Significant
Less than
Significant
Without Mitigation
#3 - Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it
has adequate capacity to serve the
project’s projected demand in
addition to the provider’s existing
commitments?
Less than
Significant
Less than
Significant
Less than
Significant
Without Mitigation
12 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
#4 – Generate solid waste in excess
of State or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair the
attainment of solid waste reduction
goals?
Less than
Significant
Less than
Significant
Less than
Significant
Without Mitigation
#5 – Comply with federal, state, and
local management and reduction
statues and regulations related to
solid waste?
Less than
Significant
Less than
Significant
Less than
Significant
Without Mitigation
3.13.1 Existing Conditions
The following provides background information about the water, wastewater, solid waste, and other utility service providers that would serve the proposed project.
Water Service Area
The project lies within the service area of VWD for both water and sewer services. VWD provides water, wastewater, and reclamation services to a population of more than 108,000 within its 45-square-mile boundary including: San Marcos, the community of Lake San Marcos, parts of Carlsbad, Escondido and Vista and other unincorporated areas in north San Diego County. VWD also wholesales recycled water to the City of Carlsbad and the Olivenhain Municipal Water District.
The project site lies completely within VWD’s 920 Pressure Zone. The project site is currently undeveloped. Potable water is delivered to the project area by an existing 8-inch water main in Woodward Street at the main entry to the project site.
Water Supply
VWD is a member of the San Diego County Water Authority (SDCWA), thus eligible to purchase water transported into San Diego County via the massive aqueducts of SDCWA and its wholesaler, Metropolitan Water District (MWD) of Southern California. To understand water supply availability for the proposed project, it is important to begin with MWD and follow the water supply through these agencies.
MWD was formed in 1928 to develop, store and distribute supplemental water to southern California for domestic and municipal purposes. MWD consists of 26-member agencies and has a service area covering six counties, 5,200 square miles, and 19 million people. MWD obtains water from local sources as well as the Colorado River (via the Colorado River Aqueduct) and the Sacramento -San Joaquin Delta (via the State Water Project). MWD’s Urban Water Management Plan (UWMP) documents the availability of these supplies to meet future demands. With a projected annual water demand of 5,374,000 acre-feet per average year for 20 45, the MWD UWMP concludes that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2045 under normal, single dry, and multiple dry water years (MWD 2021).
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The MWD water demands through normal, single dry year, and multiple dry years are shown below in Table 3.13-2.
Table 3.13-2. Metropolitan Water District Total Water Demands in Acre Feet Per Year Year 2025 2030 2035 2040 2045
Average Year 4,925,000 5,032,000 5,156,000 5,261,000 5,374,000 Single Dry Year 4,929,000 5,037,000 5,156,000 5,265,000 5,374,000 Multiple Dry Years 4,877,000 5,064,000 5,182,000 5,299,000 5,410,000 Source: MWD 2020 Urban Water Management Plan (MWD 2021).
SDCWA is the largest member agency of MWD and supplies 75 to 95 percent of the water needs in San Diego County. The population within the SDCWA’s service area was approximately 3.3 million people in 2020 and is projected to increase to roughly 3.8 million people by 2045. The County of San Diego is expected to develop an additional 130,000 acres between 2020 and 2050, with the majority (125,000 acres) of development dedicated to residential land uses. These regional growth projections are based on the San Diego Association of Government (SANDAG)’s Series 14 Regional Growth Forecast, developed for its 2019 Federal Regional Transportation Plan a dopted by SANDAG’s Board of Directors on October 25, 2019. In fiscal year 2020, total water demand in the SDCWA’s service area was 463,128 acre-feet, of which 92% was for municipal and industrial use and 8% was for agricultural water use. By 2045, the SDCWA’s annual water d emands are projected to reach 630,771 acre -feet.
This projection accounts for planned future water conservation savings (SDCWA 2021).
SDCWA is historically the largest purchaser of MWD water; however, as SDCWA and its member agencies have increased their locally controlled water resources and investments in water use efficiency, SDCWA purchases have declined. In fiscal year 2020, SDCWA purchased 62,852 acre-feet, or about 6% of all the water MWD sold. SDCWA’s UWMP assessed water reliability from 2025 through 2045 and determined that there are sufficient supplies to meet projected demands under Single Dry- Year and Multiple Dry-Year conditions (SDCWA 2021).
According to the VWD Master Plan Report, VWD imports about 75% of its water supply from SDCWA.
The rest of VWD’s water supply is provided by the recently completed Carlsbad seawater desalination plant as well as up to 2,200 acre -feet per year of supply from the Olivenhain MWD. Currently, VWD delivers water through 356 miles of pipeline and operates 10 pump stations and 19 potable water storage reservoirs ranging in size from 350,000 gallons to 40 million gallons (MG). VWD’s total operational storage capacity is 121.6 MG. During Fiscal Year 2013- 2014, VWD provided an average of 14.8 million gallons per day (MGD) to approximately 21,900 meters serving residential, commercial, light industrial, institutional, construction, landscape irrigation and agricultural uses (VWD 2018).
Wastewater Service Area
VWD provides wastewater and reclamation services to a 23 -square mile area serving approximately 93,000 people as well as commercial, light industrial, institutional, construction, landscape irrigation, and agricultural customers. Their service area includes the City of San Marcos, parts of the cities of Carlsbad, Escondido, and Vista, and unincorporated areas within the County of San Diego. In addition, VWD wholesales recycled water to the City of Carlsbad and the Olivenhain MWD. Within its service area, there are some rural areas that still use septic systems for sewage disposal, thus VWD’s current 23-square mile sewer service area is much smaller in size than its water service area, although VWD’s
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sphere of influence is equal in size for both. VWD has over 20,000 sewer service connections with 4 lift stations and approximately 250 miles of pipeline (VWD 2018).
VWD would provide the proposed project’s wastewater service. The project site is completely within VWD sewer shed 17C (VWD 2023). The project site is currently undeveloped. Sewer service is provided to the project area by an existing 8 -inch gravity sewer mainline located north of the project site in Woodward Street.
Wastewater Flows
The VWD 2018 Master Plan includes a wastewater system analysis assessing existing and projected wastewater flows, existing and projected capacity and needed capital improvements.
Table 3.13-3 presents the existing and projected future average wastewater flows for VWD’s service area at 5-year increments from the base year of 2014 to 2035 and ultimate buildout conditions. These interim flow projections were estimated based upon SANDAG’s growth forecasts for the region that were available at the time of the Master Plan’s preparation (VWD 2018). As shown in Table 3.13-3, VWD’s 2014 average daily wastewater flow was 7.5 MGD. The average annual flow projection for the ultimate condition is 14.4 MGD. This total represents the maximum potential flow based on allowable land uses and existing flows. While the ultimate flow is potentially higher, continued conservation and water use efficiency would delay reaching ultimate conditions (VWD 2018).
Table 3.13-3. Projected Wastewater Flows within VWD Service Area Year Average Annual Flows
(MGD)
Peak Dry Weather Flows
(MGD) (1)
Peak Wet Weather
Flows (MGD) (1)
Existing 2014 7.5 11.7 17.5
2020 8.7 13.2 20.0
2025 9.5 14.2 21.6
2030 9.6 14.4 21.9
2035 9.6 14.4 22.0
Ultimate 14.4 20.2 31.7
Ultimate w/ NTA (2) 15.2 21.2 33.4
Source: VWD 2018 Master Plan, page 7-19.
Notes: (1) Peak flows were estimated by applying District Peaking Curves as presented in Chapter 6 of the 2018 Master Plan.
(2) N TA is the Northern Tributary Area, a separate drainage basin located in the northern part of VWD’s service area that drains away from the wastewater collection system. NTA flows were estimated and would need further evaluation if this area is to be connected into VWD/s sewer system.
Wastewater Infrastructure and Capacity
VWD’s sewer service area is divided between two principal drainage basins which are named based on the treatment facility which serves it. The treatment facilities used by VWD are the Meadowlark Water Reclamation Facility (MRF) and the Encina Water Pollution Control Facility (EWPCF). The existing wastewater collection system includes treatment facilities, major conveyance facilities, gravity mains, trunk sewers, lift stations, siphons, and force mains. VWD is able to recycle up to 74% of the wastewater generated in the service area.
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Solids Treatment Capacity
The EWPCF is a regional treatment facility located in the City of Carlsbad with a treatment capacity of up to 40.51 MGD. VWD currently owns 10.47 MGD of solids treatment capacity at EWPCF. MRF does not have solids treatment capacity and therefore all solids are treated at the EWPCF. As shown in Table
3.17-3, VWD’s 2014 average daily wastewater flow was 7.5 MGD. The ultimate average wastewater flow identified in the 2018 VWD Master Plan is 14.4 MGD, resulting in a projected solids treatment capacity deficiency of 3.93 MGD (VWD 2023).
Liquids Treatment Facility
VWD currently has a total of 12.67 MGD liquids treatment capacity between EWPCF and MRF. VWD owns 7.67 MGD of liquids treatment capacity at the EWPCF. MRF has a liquid treatment capacity of
5.0 MGD, with a peak wet weather capacity of 8.0 MGD. As shown in Table 3.17-3, VWD’s 2014 average daily wastewater flow was 7.5 MGD. The ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected liquids treatment capacity deficiency of 1.73 MGD (VWD 2023).
Ocean Disposal Capacity
EWPCF’s ocean outfall consists of approximately 1,000 feet on land and extends approximately 7,900 feet into the Pacific Ocean. The EWPCF employs peak flow management procedures and has constructed facilities to manage peak flows, including storage tanks and pump stations. Per the 2018 Master Plan, the plant has provisions to incrementally increase capacity by adding two more 8 MG basins in the future, for a maximum storage capacity of 24 MG. The member agencies’ ability to manage inflow and infiltration into the sewer system is a major factor in deferring additional peak flow facilities or future outfall upgrades at the EWPCF (VWD 2018).
VWD currently owns 10.47 MGD of ocean disposal capacity at the EWPCF. The ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected liquids treatment capacity deficiency of 3.93 MGD (VWD 2023).
Land Outfall Capacity
A majority of VWD’s wastewater is conveyed to the EWPCF using VWD’s maintained Land Outfall. The Land Outfall is approximately 8 miles long and conveys flow by gravity as well as pressure through siphon sections. VWD maintains the entire pipeline from Lift Station No. 1 to the EWPCF. From Lift Station No. 1 to El Camino Real, VWD is the sole user of this pipeline. Total capacity of the land outfall is 20.85 and the land outfall capacity controlled by VWD is 12.10 MGD (VWD 2023).
As stated above, the MRF has a capacity of 5.0 MGD with a peak wet weather capacity of 8.0 MGD.
Combined with the 12.10 MGD capacity of the land outfall controlled by VWD, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD (12.10 MGD + 8.0 MGD). According to the VWD’s 2018 Master Plan, average daily wastewater flow through the land outfall was approximately 7.5 MGD in 2014. This corresponds to a peak wet weather flow of 17.5 MGD, which falls within VWD’s combined peak wet weather collection capacity. Howev er, the 2018 Master Plan estimated that, under approved land uses, VWD has an ultimate build-out average flow of 14.4 MGD.
This corresponds to a peak wet weather flow of 31.7 MGD, which exceeds VWD’s combined peak wet weather collection capacity. To accommodate additional wastewater flows from planned development, the 2018 Master Plan recommended conveyance of peak flows to the EWPCF through a parallel land outfall (VWD 2023).
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VWD Planned System-wide Wastewater Facility Improvements VWD’s 2018 Master Plan analyzed the existing wastewater system to determine size of pipeline replacements and extensions utilizing a hydraulic model developed by collecting the system’s physical data, estimating existing wastewater flows, and calibrating t he model using actual meter data. The 2018 Master Plan does not include developments that were not approved prior to June 30, 2014. As development projects are proposed, the project proponents will be required to prepare a study that will, at a minimum, de fine the location and size of the sewer facilities required to serve the development, including the necessary regional collection, transfer, and treatment infrastructure (VWD 2018).
VWD’s 2018 Master Plan has identified sewer pipe segments W-8 and W-9 for upsizing from 18-inch to 24-inch diameter pipe as part of Capital Improvement Project (CIP) #SP-34, a phase 4 project. Phase 4 projects are planned for construction in the 2031 to 2035 timeline (VWD 2018). Since there is currently capacity in pipes W-8 and W-9 and the need for additional capacity in these sewer mains is not anticipated until Phase 4, the CIP # SP -34 project would address and accommodate the pipeline deficiencies (VWD 2023).
Solid Waste
Solid waste disposal in the city is provided by a private franchise hauler, EDCO Waste and Recycling (EDCO), a private waste collection and recycling company which handles all residential, commercial, and industrial collections within the city. Waste collected by EDCO is hauled to the Escondido Transfer Station where it is then transported to the Sycamore Sanitary Landfill in Santee. Recyclable materials are processed at the Escondido Resource Recovery Transfer Station. The project site would be serviced by EDCO. The Escondido Transfer Station has a permitted daily tonnage of 3,223 tons per day (CalRecycle 2019a). Solid waste is consolidated here and then trucked to a landfill for disposal.
The County of San Diego prepared a Five -Year Review Report of its Integrated Waste Management Plan (June 2022) to plan for the next 15 years of countywide landfill disposal capacity and to determine the adequacy of the region’s planning documents based on updated demographic trends and regulations. The report used an average of the past 15 years in-county disposal data (2005-2020) to project disposal for the next 15 years (2022-2037). Though in-county disposal may both increase and decrease over the next 15 years, a conservative projection is that disposal will remain near the average. The 15-year disposal average is 3,206,009 in-county tons annually (County of San Diego 2022).
The report included a second disposal projection scenario, which anticipates organic materials being diverted from the landfills at a greater rate to align with the statewide organics legislation and goals (AB 32, AB 1826, AB 1594, and SB 1383). When the 75% organics diversion rate was applied to the County’s baseline disposal, organics waste disposal projections were reduced to 288,541 tons for the year 2025. These reductions were deducted from the overall disposal projection to provide a disposal scenario if organics regulations result in increased diversion. Considering the additional organics diversion scenario, the projected disposal by 2037 would be 2,282,678 tons annually, nearly a million tons (923,330 tons) less than the average disposal projection of 3,206,009 tons (County of San Diego 2022).
The second component of determining disposal capacity is the permitted daily capacities allowed by the Local Enforcement Agencies including any projected maximum disposal limits. The maximum annual allowable permitted capacity for all San Diego County land fills was 6,967,600 tons in 2021 and will be 4,134,600 tons in 2032. Landfill operators project that Otay Landfill will close in 2030 and
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Miramar Landfill will close in 2031. Sycamore Landfill is anticipated to receive additional waste flows at that time. The County’s report projections assumed that Sycamore Landfill will apply for three expansions to their daily permitted capacity. Sycamore Landfill has completed CEQA for these landfill expansions; however, there has been no application to the Local Enforcement Agency to revise the Solid Waste Facility Permit. For the purposes of projection, the County assumed that the first expansion at Sycamore Landfill is estimated to occur in 2025 and daily permitted capacity is projected to increase permitted capacity from its current 5,000 tons per day to 7,000 tons per day. The second expansion is estimated to occur in 2027 and permitted capacity is pr ojected to increase to 9,000 tons per day followed by a third expansion estimated to occur in 2030 to increase permitted capacity to 11,000 tons per day. The County’s report indicated that there would be adequate landfill capacity to serve the County for t he next 15 years. Specifically at Sycamore Landfill, the report estimated that there was 105,064,991 cubic yards (or 86,153,293 tons) remaining based on aerial survey/calculations occurring in February 2021. Estimated closure date is listed as 2042, though the permit is anticipated to be revised and extended to 2054 (County of San Diego 2022).
Electricity and Natural Gas
SDG&E provides energy service to an estimated 3.3 million consumers through 1.3 million electric meters and approximately 800,000 natural gas meters in San Diego County and southern Orange County (City of San Marcos 2012a). Electrical facilities throughout the city include a combination of aboveground and belowground electrical distribution lines and utilities structures. The City’s fiber-optic network is facilitated by a 72-strand fiber-optic line that runs in various streets throughout the city. All major arterials in the city have implemented fiber optics. The design for the dry utilities’ connection is still under preparation, however the project proposes to connect to existing electricity and natural gas infrastructure within Woodward Street. This work would take place within the existing right-of-way and would not disturb any vegetation.
Telecommunications
Telecommunications services to the project site may be provided by various distributors. Existing AT&T, Cox, and other independent cable companies telecommunication lines are available in the project vicinity.
3.13.2 Regulatory Setting
Existing federal, state, and local regulations related to water, wastewater, and solid waste that are applicable to the proposed project are summarized below.
Federal
Clean Water Act
The federal Clean Water Act (CWA) establishes regulatory requirements for potable water supplies including raw and treated water quality criteria. The City of San Marcos is required to monitor water quality and conform to regulatory requirements of the CWA.
Resource Recovery and Conservation Act
The Resource Recovery and Conservation Act Subtitle D focuses on state and local governments as the primary planning, regulating, and implementing entities for the management of non- hazardous solid waste, such as household solid waste and nonhazardous indu strial solid waste. Subtitle D
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provides regulations for the generation, transportation, and treatment, storage, or disposal of hazardous wastes.
State
California Green Building Standards Code (CCR, Title 24, Part 11 – CALGreen) In 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24 of the California Code of Regulations) is commonly referred to as CALGreen and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and inte rior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low-rise residential and state-owned buildings and schools and hospitals.
The CALGreen 2022 building standards code became effective on January 1, 2023. The mandatory standards require the following measures that relate to utilities and service systems (24 CCR Part 11):
• Mandatory reduction in indoor water usage through compliance with specified flow rates for plumbing fixtures and fittings and faucets and fountains. • Mandatory reduction in outdoor water usage through compliance with a local water efficient landscaping ordinance or the California Department of Water Resources’ Model Water Efficient Landscape Ordinance.
• 65% of construction and demolition waste must be diverted from landfills. • Mandatory inspections of energy systems to ensure optimal working efficiency. • Inclusion of electric vehicle charging stations or designated spaces capable of supporting future charging stations.
The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and implemented at the discretion of local agencies and applicants. CALGreen’s Tier 1 standards call for a 15% improvement in energy requirements, stricter water conservation, 65% diversion of construction and demolition waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar -reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30% improvement in energy requirements, stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs.
Urban Water Management Plans
Urban water purveyors are required to prepare and update a n UWMP every 5 years. The UWMPs address water supply, treatment, reclamation, and water conservation, and contain a water shortage contingency plan. Local UWMPs and those of other water districts are supplemental to the regional plans prepared by MWD. The W ater Conservation Bill of 2009 (SBX7- 7) requires each urban retail water supplier to develop an urban water use target and an interim urban water use target. Notably, SBX7-7 authorizes urban retail water suppliers to determine and report progress toward achieving these targets on an individual agency basis or pursuant to a regional alliance as provided in California Water Code (CWC) Section 10608.28(a). In accordance with this regulation, the MWD pr epared and their Board of Directors adopted its 2020 UWMP in 2021. MWD’s UWMP includes estimated future
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water demands until 2045, using updated population projections and a conservative assumption that, in the absence of mandatory water conservation measures, per-capita consumption could rebound to its 2020 target value (MWD 2021). Demands provided in MWD’s UWMP have been coordinated with SDWCA, VWD’s wholesale supplier.
Assembly Bill 939 and 341
In 1989, Assembly Bill (AB) 939, known as the Integrated Waste Management Act (California Public Resources Code, Section 40000 et seq.), was passed because of the increase in waste stream and the decrease in landfill capacity. The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by the year 2000.
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle has conducted multiple workshops and published documents that identify priority strategies that CalRecycle believes would assist the state in reaching the 75% goal by 2020.
Senate Bill 1374
Signed in 2002, the Construction and Demolition Waste Materials Diversion Requirements (SB 1374) were codified in Public Resources Code Section 42919. SB 1374 requires that jurisdictions include in their annual AB 939 report a summary of the progress made in diverting construction and demolition waste. The legislation also required that CalRecycle adopt a model ordinance for diverting 50 to 75 percent of all construction and demolition waste from landfills. The model ordinance was adopted by CalRecycle on March 16, 2004.
Senate Bill 1383
SB 1383 establishes a statewide organic waste diversion rate goal of 75 percent by 2025. Beginning in 2022, SB 1383 required every jurisdiction to provide organic waste collection services to all residents and businesses, including food, green material, landscaping waste, organic textiles, lumber, paper products, manure, biosolids, digestate, and sludges. Jurisdictions are also required to educate residents and businesses about the collection requirements.
Local
San Diego County Integrated Waste Management Plan
Pursuant to the Integrated Waste Management Plan, the Countywide Integrated Waste Management Plan for San Diego County describes the goals, policies, and objectives of the county for coordinating efforts to divert, market, and dispose of solid waste during the planning period through the year 2017 (County of San Diego 2005). A Five -Year Review Report was prepared in June 2022 to plan for 15 years of countywide landfill disposal capacity and to determine the adequacy of the region’s planning documents based on updated demographic trends and regulations. The report identified reduced landfill disposal rates compared to the high in 2005. The plan presumes waste disposal tonnages will not reach the 2005 level again due to increased State and local recycling programs. Another reason
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for reduced landfill disposal rates is increased conservation and recycling activities, expansion of compost and construction and demolition facilities, and implementation of mandatory recycling ordinances by jurisdictions. Average disposal quantities and landfill capacities are discussed above in Section 3.17.1 (County of San Diego 2022).
Countywide policies for reducing waste and implementing the programs identified in the individual jurisdiction Source Reduction and Recycling Elements and Household Hazardous Waste Elements, are intended to reduce costs, streamline administration of programs, and encourage a coordinated and planned approach to integrated waste management.
To avoid duplication of effort, all jurisdictions in the county participate in the San Diego County Integrated Waste Management Local Task Force. The Local Task Force coordinates mandated planning, oversees implementation of new or countywide integrated wa ste management programs, and carries out an active legislative program. Regulatory reform, changes to state diversion requirements, and reduction of the costs of compliance are considered by the Local Task Force, as well as other solid waste issues of regional or countywide concern.
City of San Marcos Municipal Code
Title 8, Health and Sanitation
San Marcos Municipal Code Title 8 contains regulations and provisions on sewers and sewage disposal plants, sewer connections, septic tanks, waste matter, garbage and refuse collection, and other matters concerning sanitation. Chapter 14.15 contains regula tions concerning storm water management and discharge control. Chapter 14.24 contains regulations concerning underground utility facilities. Title 19 regulates subdivision requirements, including the installation of utility facilities and connections and payment or fees for such installations.
Title 20, Chapter 20.330 Water Efficient Landscaping Ordinance The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.
Title 20, Section 20.330, details the City’s Water Efficient Landscape (WELO). In accordance with State law, Chapter 20.330 establishes specific standards for landscape and irrigation design and installation to ensure beneficial, efficient, and responsible use of water resources within the city.
City of San Marcos General Plan
The General Plan Conservation and Open Space Element includes two goals and one policy that are applicable to the proposed project (related to water supply and solid waste):
• Goal COS -5: Reduce water consumption and ensure reliable water supply through water efficiency, conservation, capture, and reuse.
• Goal COS -10: Establish and maintain an innovative, sustainable solid waste collection, recycling, and disposal delivery system for present and future generations. o Policy COS-10.1: Promote the curbside recycling program to divert residential refuse from the landfills.
The General Plan Land Use and Community Design Element identifies the following goals and policies regarding utilities and services systems that are applicable to the proposed project:
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• Goal LU -8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU -8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities. • Goal LU-13: Water Service and Supply: Manage and conserve domestic water resources by reducing water usage and waste on a per capita basis, to ensure an adequate water supply for existing and future residents.
o Policy LU-13.1: Work closely with local and regional water providers to ensure high quality water supplies are available for the community.
o Policy LU-13.2: Actively promote water conservation programs aimed at reducing demand. o Policy LU -13.3: Encourage exploration and use of deep underground wells to reduce reliance on treatable water.
• Goal LU -14: Wastewater: Ensure an adequate wastewater system for existing and future development.
o Policy LU-14.1: Work closely with local service providers to ensure an adequate wastewater system for existing and future development is in place. o Policy LU -14.2: Ensure development approval is directly tied to commitments for the construction or improvement of primary water, wastewater, and circulation systems. • Goal LU-16: Solid waste: reduce the amount of waste material entering regional landfills with an efficient and innovative waste management program.
o Policy LU-16.1: Work closely with local service providers to ensure adequate solid waste disposal, collection, and recycling services.
o Policy LU-16.2: Increase recycling, composting, source reduction, and education efforts throughout the city to reduce the amount of solid waste requiring disposal at landfills. • Goal LU-17: Utilities and Communications: Encourage provision of power and communication systems that provide reliable, effective, and efficient service for San Marcos. o Policy LU-17.2: Require all new development and redevelopment to provide the technology to support multiple telecommunications facilities and providers such as multi -media products, wireless technologies, and satellite communications. o Policy LU-17.3: The City shall prohibit above ground utility equipment within any of the pedestrian pathways and street frontage areas. All above ground utilities shall be placed either within; “wet closets” within the buildings, underground vaults, or 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.
o Policy LU-17.4: Require utility location to be shown on all site development plans at the time of development/project application.
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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 of this EIR. As detailed in Table 3.8-12 in Section 3.8, the project is consistent with the applicable utilities-related goals and policies.
3.13.3 Thresholds of Significance
The determination of significance for utilities and service systems is based on Appendix G of the CEQA Guidelines. Utilities and services system impacts would be significant if the proposed project meets any of the following thresholds:
• Threshold #1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
• Threshold #2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? • Threshold #3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
• Threshold #4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
• Threshold #5: Comply with federal, state, and local management and reduction statues and regulations related to solid waste?
3.13.4 Project Impact Analysis
The project proposes to connect to the existing 8 -inch water main in Woodward Street at the main entry to the project site. Water connections to the dwelling units would be provided via 4-inch lines. An 8-inch fire main would parallel the potable water line for fire service to the site. For sewer service, the project w ould extend the existing 8 -inch gravity sewer main located north of the project site in Woodward Street for approximately 490 feet. The proposed sewer line extension would be within the existing roadway on Woodward Street. Dwelling units would connect to sewer via an 8-inch sewer main that will run the length of the main driveway.
VWD Construction and Board acceptance of all onsite and offsite water and sewer facilities would be required prior to service, including installation of the expansion of the 8-inch Sewer main (Pipes W-1 and W-2 in VWD 2018 Master Plan). Additionally, the project applicant would pay all of the applicable Water and Wastewater Capital Facility Fees in effect at the time service is committed in accordance with VWD rules and regulations. Proof of payment would be provided to the City’s Planning Manager.
The design for the dry utility 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.
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Threshold #1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Water
The project site lies within VWD’s water service area and would be served by VWD for potable water and water for fire protection. VWD has confirmed their ability to serve the project and has prepared a Technical Memorandum which includes a Water System Analysis. The memorandum analyzes water demand, water distribution, water storage capacity and water pump station capacity (VWD 2023, Appendix N).
Water Demand
The project site has a General Plan designation of SPA (Specific Plan Area) and is associated with the Heart of the City Specific Plan (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. 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.
VWD’s 2018 Master Plan based its ultimate water demand planning on the Residential 2-4 du/ac land use. The project is proposing 46 multi-family residential units on 8.6 acres. Table 3.13-4 provides the average water demand generated both under the density planned for the VWD 2018 Master Plan and for the proposed project. As shown, the proposed project would increase the projected average water demand from the 2018 Master Plan land use by 6,020 gallons per day (GPD) (VWD 2023).
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Table 3.13-4 Estimated Water Demands for Proposed Project Land Use Type Area
(Acres) Residential Units Duty Factor
(GPD/Acre)
Water Demand
(GPD)
2018 Master Plan Land Use Demand
Residential
(2-4 du/ac)
8.6 1,800 15,480
Proposed Project Demand
Residential
(4-8 du/ac)
8.6 46 2,500 21,500
Water Demand
Increase
6,020
Source: VWD 2023.
Notes: GPD= Gallons per Day
du/ac- dwelling units per acre
Water Distribution System Analysis
VWD prepared a water distribution system analysis to identify potential system impacts that may be created by the proposed water demand, and to recommend any improvements required to provide service to the project. Modeling focused on the infrastructure in the direct vicinity of the project site.
Per the 2018 Master Plan, maximum day demands for the proposed project are 300% those of average day demands, and peak hour demands are 620% those of average day demands (VWD 2023).
VWD modeling focused on the infrastructure in the direct vicinity of the project site. The model found that the proposed project would not create any distribution system deficiencies under an average day demand or maximum day plus fire flow demand conditions (VWD 2023). Therefore, the proposed project would not result in deficient water distribution system, and would not require new or expanded water distribution system that could result in significant environmental impacts.
Water Storage Analysis
The 2018 Master Plan outlines VWD’s potable water storage reservoirs for each pressure zone. The project is located entirely within the VWD 920 pressure zone. Water storage for this zone is located within the 920 zone and 1028 Twin Oaks pressure zones.
Table 3.13-5 shows the required storage in
the 855, 920, and 1028 Twin Oaks pressure zones for existing and ultimate build -out conditions relative to the existing storage provided within each zone. As shown in Table 3.13-5, there is sufficient existing storage available to meet existing demand. The proposed project would increase the projected average water demand by approximately 6,020 GPD. The amount of additional reservoir storage required is 500% of the project’s average day demand, which is 30,100 gallons (6,020 g allons X 500%). VWD’s analysis found that water storage capacity is currently available to serve the project’s increased storage requirements. The proposed project increases the ultimate water demand planned in the 2018 Master Plan and would further contribute to the deficiency. However, per VWD, future project identified in the 2018 Master Plan would address and accommodate the ultimate build -out storage deficiency. As a project design feature (Table 2- 2), the project applicant would pay Water Capital Facility Fees which would be used for the increase in storage necessitated by the project’s demand (VWD 2023).
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Water Pump Station Analysis
Since the proposed project is located in a pressure zone that is not served by pumping, there would be no impacts to existing or proposed pump stations (VWD 2023).
Table 3.13-5 Existing Reservoir Storage Capacity and Requirements Pressure Zone
Existing
Average Day
Demand
(MGD)
Existing
Storage
Requirement
(MG)
Ultimate
Average Day
Demand
(MGD)
Ultimate
Storage
Requirement
(MG)
Existing
Storage
Available
(MG)
855 3.74 50.05 6.79
101.25
0 920 5.61 10.40 18
1028
Twin Oaks
0.66 3.06 73
Totals 10.01 50.05 20.25 101.25 91
Source: VWD 2023.
Notes: MGD= Million Gallons per Day
MG= Million Gallons
Summary
The project proposes to connect to the existing 8 -inch water main in Woodward Street at the main entry to the project site and provide water connections to the dwelling units via 4 -inch lines. These water lines would be constructed within the existing right -of-way on Woodward Street and within the project’s footprint of disturbance. These improvements would occur within the project site or within existing paved roads and have been accounted for in this EIR.
While the project would increase water demand by 6,020 GPD above what the 2018 Water Master Plan identified, VWD’s analysis determined that with payment of the required Water Capital Facility Fees, the project would have less than significant impacts relat ed to VWD’s water distribution, water storage, and water pumping facilities (VWD 2023).The project would not require the location or construction of new or expanded water facilities, the construction of which could cause significant environmental effects. Therefore, impacts related to the relocation or construction of new or expanded water collection facilities would be less than significant.
Wastewater
The proposed project lies completely within VWD sewer shed 17C. The analysis of wastewater infrastructure is based upon the Water and Sewer Study, prepared by VWD (VWD 2023). The Water and Sewer Study is included in Appendix N of this EIR.
As discussed above, for the project site, the land use options for the Richmar Specific Plan designation allow for multi-family residential development. 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.
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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VWD’s 2018 Master Plan based its ultimate wastewater generation planning on the Residential 2- 4 du/ac land use. The project is proposing 46 multi -family residential units on 8.6 acres. Table 3.13-6 provides the average wastewater flows generated both under the density planned for the VWD 2018 Master Plan and for the proposed project. As shown, the proposed project would increase the projected average wastewater flows from the 2018 Master Plan land use by 4,730 GPD (VWD 2023).
Table 3.13-6 Estimated Wastewater Flows for Proposed Project Land Use Type Area
(Acres) Residential Units Duty Factor
(GPD/Acre)
Wastewater Flow
(GPD)
2018 Master Plan Land Use Demand
Residential
(2-4 du/ac)
8.6 750 6,450
Proposed Project Demand
Residential
(4-8 du/ac)
8.6 46 1,300 11,180
Sewer Generation
Increase
4,730
Source: VWD 2023.
Notes: GPD= Gallons per Day
du/ac- dwelling units per acre
Wastewater Collection System Analysis Model Results
VWD modeled several wastewater scenarios to identify system impacts that may be created by the proposed sewer generation, and to recommend any improvements required to provide service to the project. Modeling focused not only on the sewer collection infrastructure in the direct vicinity of the project site, but also on all downstream infrastructure from the development to Lift Station No. 1 on San Marcos Boulevard that would be receiving project flows.
VWD modeling results showed that there are deficiencies in pipe segment W -8 under the currently approved density under peak wet weather flows during ultimate build-out conditions. The wastewater flows from the proposed project would increase those deficiencies (VWD 2023). VWD concluded that approximately 232 feet of existing 18-inch sewer main within a VWD easement along San Marcos Creek must be replaced with a 24-inch main (W -8 and W-9). However, the upsizing of these pipes is included in VWD’s 2018 Master Plan as part of CIP #SP-34, a phase 4 project planned for construction in the 2031 to 2035 timeline. Since there is currently capacity in pipes W-8 and W-9 and the need for additional capacity in these sewer mains is not anticipated until Phase 4, the CIP #SP-34 project would address and accommodate the pipeline deficiencies. Wastewater Capital Facility Fees paid by the project would be used toward the construction of these pipelines (VWD 2023).
Wastewater Lift Station Analysis
Since the project is not located in a sewer shed that is served by a lift station, no lift station upgrades would be required, and no impacts would occur (VWD 2023).
Parallel Land Outfall Analysis.
VWD’s existing land outfall is approximately 8 miles in length and consists of four gravity pipeline sections and three siphon sections varying in diameter from 20 inches to 54 inches. Total landfall
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capacity is 20.85 MGD, and VWD controls 12.10 MGD. The MRF has a capacity of 5.0 MGD with a peak wet weather capacity of 8.0 MGD. Therefore, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD (12.10 MGD + 8.0MGD). VWD’s 2014 average daily wastewater flow through the land outfall was 7.5 MGD. This corresponds to a peak wet weather flow of 17.5 MGD, which falls within VWD’s combined peak wet weather collection capacity (VWD 2023).
The 2018 Master Plan estimated that, under approved land uses, VWD has an ultimate build- out average dry weather flow of 14.4 MGD. This corresponds to a peak wet weather flow of 31.7 MGD, which exceeds VWD’s combined peak wet weather collection capacity. T o accommodate additional wastewater flows from planned development, the 2018 Water Plan recommended conveyance of peak flows to the EWPCF through a parallel land outfall (VWD 2023).
The project proposes to generate 4,730 GPD of additional average wastewater flow that was not accounted for in the Land Outfall’s capacity studied in the 2018 Master Plan. However, per the Water and Sewer Study prepared for the proposed project, VWD determined that outfall capacity is currently available to serve the project’s proposed wastewater generation. Wastewater Capital Facility Fees paid by the project would be used toward design and construction of a par allel land outfall to be sized to accommodate ultimate build-out wastewater flows (VWD 2023).
Wastewater Treatment Facility Analysis
Because VWD utilizes both MRF and EWPCF for wastewater treatment, wastewater generated by the proposed project would be treated at either facility. MRF has liquids treatment capacity of up to 5 MGD with a peak wet weather capacity of 8 MGD. MRF does not ha ve solids treatment capacity, and therefore all solids are treated at the EWPCF. The EWPCF is a regional facility with treatment capacity of up to 40.51 MGD (VWD 2023).
Solids Treatment Capacity
VWD currently owns 10.47 MGD of solids treatment capacity at EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concluded that adequate solids treatment capacity exists at this time to serve the proposed project. However, the ultim ate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected solids treatment capacity deficiency of 3.93 MGD. Wastewater flows from the proposed project would contribute to that deficiency. Wastewater Capital Facility Fees paid by the project would be used towards the deficiency to accommodate the solid treatment capacity wastewater flows (VWD 2023).
Liquid Treatment Capacity
VWD currently owns 7.67 MGD of liquids treatment capacity at the EWPCF in addition to the liquids treatment capacity of 5.0 MGD at MRF, for a total of 12.67 MGD of liquids treatment capacity. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concluded that adequate liquids treatment capacity exists at this time to serve the project. However, the ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected liquids treatment capacity deficiency o f 1.73 MGD. Wastewater flows from the proposed project would contribute to that deficiency. Wastewater Capital Facility Fees paid by the project would be used towards the deficiency to accommodate the ultimate average wastewater flow (VWD 2023).
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Ocean Disposal Capacity
VWD currently owns 10.47 MGD of ocean disposal capacity at the EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concluded that adequate ocean disposal capacity exists at this time to serve the project. However, the ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD resulting in an ocean disposal deficiency of 3.93 MGD. Wastewater flows from the proposed project would contribute to that deficiency. Wastewater Capital Facility Fees paid by the project wo uld be used towards the deficiency to accommodate the ocean disposal wastewater flow (VWD 2023).
Wastewater Summary
The project proposes to extend the existing 8-inch gravity sewer main located north of the project site in Woodward Street for approximately 490 feet. The proposed sewer line extension would be within the existing roadway on Woodward Street. Dwelling units would connect to sewer via an 8-inch sewer main that would run the length of the main driveway. These improvements would occur within the project site or within existing paved roads and have been accounted for in this EIR.
The proposed project would increase wastewater flows by 4,730 GPD above what the 2018 Master Plan identified. However, VWD’s analysis determined that with payment of the required Water Capital Facility Fees, the project would not exceed current capacities of the wastewater treatment system and would not require the relocation or construction of existing wastewater treatment facilities. Payment of the Wastewater Capital Facility Fees is included as project design feature (Table 2 -2). Therefore, impacts related to the relocation or construction of new or expanded sewer facilities, the construction of which could cause significant environmental effects would be less than significant.
Stormwater Drainage
As discussed in Section 3.7.4 (Hydrology and Water Quality), the proposed project would result in an increase of impervious areas on the site. If not carefully planned for, increased runoff from impervious surface can cause alterations to drainage courses. However, the proposed project has been designed to carefully handle runoff and to meet regulatory requirements to ensure that post-development runoff quantities and rates are similar to or less than the pre -development condition. Although the project would include new storm water infrastructure (underground storage pipes, brow ditches and two biofiltration basins) to support project facilities, the proposed infrastructure has been accounted for and analyzed throughout this EIR. The project would not contribute a substantial amount of new stormwater runoff relative to existing c onditions, that would require the relocation o r construction of new or expanded stormwater facilities and impacts are determined to be less than significant. Please
refer to Section 3.7, Hydrology and Water Quality, for additional discussion related to drainage.
Electric Power/ Natural Gas
The project would be served by SDG&E for electricity and gas service. The project design incorporates features which would reduce the amount of electricity that would be required to serve the project. The project would install 246 trees which would provide shade. Each garage would be wired to accommodate EV chargers. Additionally, the project would adhere to the City’s WELO ordinance, which would reduce landscaping water usa ge. The project would also be built under the most current Title 24 standards which are designed to reduce energy.
The design for the dry utilities’ connection is still under preparation; however, the project proposes to connect to existing electricity and gas infrastructure within Woodward Street. Th ese improvements
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would take place within the existing right-of-way, would not disturb any vegetation , and have been accounted for in this EIR. Aside from these improvements, the project would not require the relocation or construction of new or expanded power, or natural gas facilities, the construction or relocation of which could cause significant environmental effects. Impacts would be less than significant.
Telecommunications
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. Existing telecommunications infrastructure in the vicinity of the project site would be available to serve the proposed project. No specific systems upgrades are proposed or would be required to serve the proposed project. Thus, the project would not result in physical impacts associated with the construction or relocation of telecommunications systems. Impacts would be less
than significant.
Threshold #2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As discussed in the response to Threshold #1, the project would be served by VWD. Per the Water and Sewer Study (Appendix N ), the project is anticipated to generate an additional 6,020 GPD over the ultimate demand projected in the 2018 Master Plan. This equates to approximately 6.75 acre-feet per year.
As discussed above and shown in Table 3.13 -2, MWD’s UWMP shows water supplies would be available to meet current and future demands of the region. With a projected annual water demand of 5,374,000 acre-feet per year in 2045, the MWD UWMP demonstrates that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2045 under normal, single dry, and multiple dry water years (MWD 2021). Additionally, SDCWA’s UWMP assessed water reliability from 2025 through 2045 and determined that there are sufficient supplies to meet projected demands under Single Dry-Year and Multiple Dry-Year conditions (SDCWA 2021). The additional 6.75 acre-feet per year generated by the project would present a less than significant increase in water demand relative to the annual water demand projected by the MWD’s UWMP.
Further, the project site would be developed in compliance with CALGreen, which implements water efficiency standards for appliances and fixtures. Compliance with CALGreen would further reduce project water usage in combination with VWD and MWD’s ongoing w ater conservation practices.
Compliance with these regulations and conservation measures would ensure sufficient water supplies are available to service the project. Therefore, impacts to water supply would be less than significant.
Threshold #3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
As discussed under Threshold #1, above, the project site is within VWD’s service area, which would provide service to the project. The project is expected to increase wastewater flows by 4,730 GPD over what was assumed in the 2018 Master Plan. This would l ead to an increase of 4,730 GPD in solids handling, liquids handling and ocean disposal capacity requirements at the EWPCF and in the parallel land outfall’s capacity requirement. VWD has determined that adequate wastewater treatment and disposal capacity exists for the proposed project at this time. As discussed in the Water and Sewer Study (Appendix N), the project applicant would be required to pay all applicable Wastewater Capital
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Facility fees in effect at the time of service in accordance with District rules and regulations. Under these conditions, VWD has determined that adequate wastewater treatment and disposal capacity exists for the proposed project at this time (VWD 2023). Because the project would not exceed current capacities of the wastewater treatment system and would contribute Wastewater Capital Facility fees that would be used towards improvements, impacts to water treatment capacity would be less than significant.
Threshold #4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Construction of the proposed project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, packing materials, and plastics. The City works with EDCO to promote its construction and demolition material waste removal and recycling program. A minimum of 75% of non -hazardous construction and demolition waste would be recycled pursuant to the requirements of CalGreen and AB 939, and construction would not impair the attainment of solid waste reduction goals.
Operation of the proposed project would result in increased generation of solid waste. The anticipated solid waste generation from the proposed project was estimated using CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019b). It is estimated that the project (46 units) would generate approximately 563 pounds of solid waste per day (12.23 pounds per household). This does not consider any waste diversion through recycling. According to CalRecycle, the city has a disposal rate target of 8.9 pounds per person per 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.
Solid waste generated by the proposed project would be collected and transported to the Sycamore Sanitary Landfill by EDCO. According to CalRecycle, the facility currently has a daily permitted capacity of 5,000 tons per day for solid waste but is projected to increase to 7,000 tons per day in 2025 and 9,000 tons per day in 2027. Sycamore landfill’s estimated closure date is listed as 2042, though the permit is anticipated to be revised and extended to 2054 (County of San Diego 2022). Solid waste generated by the proposed project would contribute a minimal amount of solid waste to Sycamore Sanitary Landfill’s daily permitted capacity. As such, the proposed project’s solid waste generation can be accommodated at the landfill. The project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Therefore, impacts would be less than significant.
Threshold #5: Comply with federal, state, and local management and reduction statues and regulations related to solid waste?
The proposed project would comply with all federal, state, and local statues and regulations regarding solid waste. The project would include trash enclosures with clearly marked, source-sorted receptacles for disposing of solid waste, recyclables, and organic waste to facilitate compliance with the requirements of AB 341, AB 939, AB 1826, SB 1383, and CALGreen Code. Additionally, all solid waste facilities, including landfills, require solid waste facility permits to operate. In San Diego County, Public Resources Code (Sections 44001- 44018) and California Code of Regulations Title 27, Division 2, Subdivision 1, Chapter 4 (Section 21440 et seq.) authorizes the County Department of Environmental Health, Local Enforcement Agency to issue solid waste facility permits. Sycamore Sanitary Landfill is a permitted facility and EDCO is a licensed hauler. As such, the project would comply with existing
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regulations related to solid waste disposal and would not violate federal, state, or local management and reduction statutes and regulations related to solid waste. Impacts would be less than significant.
3.13.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future projects producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to utilities and services systems, the cumu lative analysis is based upon a combined list and plan project approach.
Water
All of the cumulative projects included in Table 2 -4 are within VWD’s service area for potable water service and would contribute to the cumulative demand for water supply and water infrastructure.
However, MWD anticipates the demand of future development through their master planning process.
According to MWD’s UWMP, no water shortages are anticipated within MWD’s service area in single or multiple dry years through 2045.
As described in Section 3.13.4, above, the proposed project would result in less than significant impacts to water supply services. As discussed in Section 3.13.1, MWD has determined that with supplies provided by SDCWA and compliance with the Water Conser vation Bill of 2009, no water shortages would occur in a normal year through 2045 (MWD 2021). Other cumulative projects that are consistent with the land use assumptions made in MWD’s UWMP would have already been accounted for in demand projections. Projec ts that are inconsistent with the land use assumptions made in MWD’s UWMP would also be subject to CEQA and required to include water supply assessments to demonstrate adequate supply for development. Further, related projects would be required to show tha t adequate infrastructure exists to serve the related projects and mitigate any potential impacts to water infrastructure caused by the project. All projects would be required to pay applicable Capital Facility Fees to VWD or the applicable water service provider, which are required to go towards infrastructure improvements. Thus, cumulative impacts to water services would be less
than significant.
Wastewater
Cumulative projects that are within the VWD service area for wastewater services would contribute to the cumulative demand for wastewater services. VWD anticipates the demand of future development through their master planning process. Cumulative projects that are consistent with the land use assumptions made in VWD’s Master Plan would have already had their demand accounted for.
As discussed in Section 3.13. 4 above, VWD has sufficient capacity at this time to account for the proposed project’s estimated increase in wastewater generation. However, VWD identified existing system deficiencies in sewer pipe segments W -8 and W-9, as well as in capacity for solids h andling, liquids handling, ocean disposal and parallel land outfall’s capacity for ultimate build-out wastewater flows. The cumulative projects that result in an increase in density or development over what was accounted for in VWD’s Master Plan would further exacerbate these deficiencies. Per VWD, payment
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of Wastewater Capital Facility fees would go toward projects identified in their 2018 Master Plan including upsizing applicable pipelines and design and construction of a parallel land outfall (VWD 2023). The project applicant for the proposed project and for cumulative projects would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations, which would be utilized to fund the identified projects in the 2018 Master Plan. Thus, with payment of all applicable Wastewater Capital Facility fees to VWD, cumulative impacts to wastewater treatment facilities would be less than significant.
Electrical Power and Natural Gas
Potential cumulative impacts related to energy and natural gas infrastructure would result if the project, in combination with past, present, and future projects, would require or result in the relocation or construction of new or expanded electric power or natural gas facilities, the construction or relocation of which could cause significant environmental effects.
As described in Section 3.13.4, above, the proposed project would have a less than significant impact related to energy and natural gas. Each of the cumulative projects identified in Table 2 -4 would be within the service area of SDG&E. Each of the cumulative projects would be required to analyze their potential for impacts related to the provision of electricity and natural gas services, including the need for new or expanded utility infrastruc ture, and would be required to mitigate potential impacts from expanded infrastructure to below a level of significance. Cumulative projects are also required to comply with the state’s energy efficiency standards and local regulations. Additionally, SDG&E regularly undertakes upgrades and expansions, as needed, throughout their service area to continue to provide reliable electricity and natural service. SDG&E conducts their own CEQA review on these projects. In conclusion, cumulative impacts related to the provision of electrical power and natural gas would be
less than significant.
Solid Waste
Future development projects would generate solid waste to be disposed of at the Sycamore Sanitary Landfill. According to CalRecycle, the facility has a daily permitted capacity of 5,000 tons/day for solid waste (expected to increase to 7,000 tons per day i n 2025, and 9,000 tons per day in 2027). As of February 2021, remaining capacity was 105,064,991 cubic yards or approximately 86 million tons with an anticipated closure date of 2042, likely to be revised and extended to 2054 (County of San Diego 2022). Further, there are five other landfills in the County. This includes Borrego Landfill, with a remaining capacity of 88,750 cy and a closure date of 2046; Miramar Landfill, with a remaining capacity of 11,080,871 cy and a closure date of 2031); Otay Landfill, with a remaining capacity of 11,122,997 cy and closure date of 2030, and two US Marine Corps landfills – Las Pulgas and San Onofre, with remaining capacities of 5,657,717 and 1,057,605 cy and 2060 and 2031 closure dates respectively (County of San Diego 2022).
The proposed project and cumulative projects include 3,085 residential units, approximately 211,600 s.f. of commercial, 555,000 s.f. of office and 104,000 s.f. of industrial. When the CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019b) are applied to the proposed project and the cumulative projects, the total solid waste anticipated to be generated is 48,088 pounds per day (lbs/day) or 24.04 tons/day. This is prior to any diversion from mandatory recycling and green waste/organics program. Assuming a 75% diversion rate, as required by AB 341, the net solid waste generation would be approximately 6.01 tons/day. The Sycamore Sanitary Landfill has a daily permitted capacity of 5,000 tons/day, which is expected to increase to 7,000 tons/day in 2025 and
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9,000 tons/day in 2027. The cumulative projects would result in incremental contribution to the landfill capacity; however, the impact would be less than significant.
3.13.6 Mitigation Measures
Impacts would be less than significant, so no mitigation measures are required.
3.13.7 Conclusion
Development of the proposed project would result in an incremental increase in the need for water, wastewater, stormwater, energy, and solid waste services. However, as outlined in the project impact analysis above, it is determined that water, wastewater, stormwater, energy, and solid waste services would be adequate and
project- and cumulative-level impacts would be less than significant.
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4.0 Alternatives
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4.0 Alternatives
4.1 Introduction to Alternatives
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that an Environmental Impact Report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.”
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires an EIR to set forth only those alternatives necessary to permit a reasoned choice. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6(a) of the CEQA Guidelines).
In developing the alternatives to be addressed in the EIR, the potential alternatives were evaluated in terms of their ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the project identified in Section 3.0, Environmental Analysis, of the EIR.
In determining what alternatives should be considered in an EIR, it is important to acknowledge the objectives of the project, the project’s significant effects, and unique project considerations. These factors are important to the development of alternatives that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs must contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether an alternative is feasible or infeasible is made by the lead agency’s decision‐making body, the San Marcos City Council (see Public Resources Code Section 21081[a] [3]).
4.2 Project Objectives
The following project objectives describe the purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in the EIR:
• Provide multi -family housing opportunities close to major transit, education al facilities, shopping opportunities, employment uses, and trails to optimize alternative mode s of transportation, reduce reliance on automobiles, and potentially reduce greenhouse gas emissions.
• To the extent possible given site constraints, maximize the opportunity to provide housing for the City of San Marcos in the 4.1 to 8.0 dwelling unit density range which is comparable to low- density housing developments in the City of San Marcos. • Cluster development to lessen site impacts and minimize landform modification. • Develop high-quality attainable housing which meets the housing needs of the City of San Marcos and the region.
• Create a development that promotes a high -quality-of-life by providing each dwelling unit its own private patio/yard space and by providing a common recreational open space gathering area.
• Establish development standards and design guidelines that ensure distinctive architecture, landscaping and recreational amenities that complements and enhances the existing
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surrounding neighborhood while providing a desirable living environment for residents within the Specific Plan Area.
• Institute a program for the long-term maintenance of the community to ensure all facilities are adequately maintained to City standards.
• Finance or contribute a fair share of funding to all community services and infrastructure needed to support Specific Plan development to promote economic stability.
4.3 Project Alternatives Considered in This EIR
4.3.1 Description of Alternative
The following alternatives are under consideration for this project:
• No Project/No Development Alternative (Section 4.3.3) • No Project/ Existing Plan Alternative (Section 4.3.4) • Reduced Density Alternative (Section 4.3.5)
Alternatives considered and removed from further consideration are summarized in Section 4.4.
4.3.2 Summary of Impacts
Project- and cumulative-level impacts associated with implementation of the proposed project are evaluated in Sections 3.1, Aesthetics, through 3.13, Utilities and Service Systems, of the EIR. As identified in Table 1 -1, in Chapter 1, Executive Summary, co nstruction and/or operation of the proposed project would have the potential to cause the following significant but mitigable environmental impacts:
• Impact BIO-1: The proposed project has the potential to result in direct and indirect impacts to coastal California gnatcatcher.
• Impact BIO-2: Focused surveys found the Diegan Coastal Sage Scrub on site to be occupied by Crotch’s bumble bee. Thus, there is potential for “take” of Crotch’s bumble bee and adverse impacts may occur through the removal of occupied habitat. • Impact BIO -3: The project has the potential to result in direct and indirect impact s to special-status wildlife species including Orange -throated whiptail, coastal whiptail, Southern California rufous -crowned sparrow, Cooper’s hawk, Crotch’s bumble bee, and Bryant’s woodrat.
• Impact BIO-4: The project has the potential to impact nesting birds and raptors that are afforded protection under the California Fish and Game Code and the Migratory Bird Treaty Act.
• Impact BIO -5: The proposed project has the potential to result in indirect impacts to sensitive species due to urban run-off, introduction of meso-predators (e.g., dogs and cats), invasive plant species, and noise and lighting effects. • Impact BIO-6: The proposed project would impact 5.24 acres of Diegan coastal sage scrub and 0.26 acres of disturbed Diegan coastal sage scrub for a total of 5.50 acres of impact.
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• Impact CR-1: Due to grading and ground disturbing activities, the proposed project has the potential to impact unidentified archeological resources on the project site. • Impact CR-2: There is a potential for project construction activities to disturb previously unidentified human remains on the project site.
• Impact N-1: Due to temporary rock drilling and blasting activities during construction, the proposed project has the potential to create noise levels in excess of the 75 dBA standard if rock drilling equipment is staged closer than 160 feet to the nearest property line. • Impact N -2: Due to temporary rock crushing activities, the proposed project has the potential to create noise levels in excess of the exterior daytime standards for single family residential use (60 dBA Leq) and multi -family residential use (65 dBA Leq) if the rock crusher is staged within 400 feet of a single-family residential use. • Impact TCR-1: As a result of tribal consultation, the City has determined that construction of the proposed project has the potential to cause a substantial adverse change to a tribal cultural resource that is determined, by the City, based on substantial evidence, to be a tribal cultural resource.
All project impacts would be mitigated to below a level of significance.
4.3.2.1 No Project/No Development Alternative
Under the No Project/No Development Alternative, the proposed project would not be implemented, and the project site would remain undeveloped and in its current condition. No grading or construction would occur on the project site under this alternative. T he project site is currently undeveloped and supports Diegan coastal sage scrub, disturbed Diegan coastal sage scrub, disturbed habitat, and urban/developed areas (Rincon 2025).
4.3.2.2 Comparison of the Effects of the No Project/No Development Alternative to the Proposed Project
Aesthetics
Under this alternative the project site would remain in its current condition. No grading would occur and no vegetation would be removed. The visual character of the site would not change. The project site is undeveloped and steeply sloped. Elevation ranges from 754 feet above mean sea level in the eastern portion of the project site down to 615 feet in the southwestern portion of the project site. The project site supports Diegan coastal sage scrub, disturbed Diegan coastal sage scrub, disturbed habitat, and urban/developed areas (Rincon 2025). This alternative would not add additional sources of lighting to the project site and vicinity. Compared to the proposed project, this alternative would reduce impacts. No aesthetics impacts would occur under the No Project/No Development Alternative.
Air Quality
Under the No Project/No Development Alternative, air emissions associated with project construction including emissions associated with grading, blasting and rock crushing, site preparation, site finishing and building finishing would not occur. Implementation of this alternative would not introduce any uses that could generate operational air emissions. This alternative would not result in any construction or operational air pollutant emissions. As discussed in Section 3.2.4, impacts to air quality for the
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proposed project would be less than significant and no mitigation would be required. Compared to the proposed project, this alternative would reduce air pollutant emissions. No air quality impacts would occur under the No Project/No Development Alternative.
Biological Resources
The No Project/No Development Alternative would not require any ground -disturbing activities, nor would it include development of the project site. This alternative would avoid potential impacts to coastal California gnatcatcher (Impact BIO-1), Crotch’s bumble bee (Impact BIO-2), other special-status wildlife species and nesting birds (Impact BIO -3 and Impact BIO -4), indirect impact s to sensitive species (Impact BIO -5) and impact to Diegan coastal sage scrub (Impact BIO -6). Since impacts to biological resources would be avoided under the No Project/No Development Alternative, mitigation measures MM -BIO-1 through MM -BIO-6 would not be implemented or required. Compared to the proposed project, this alternative would eliminate the potential biological resources impacts. No biological resources impacts would occur under the No Project/No Development Alternative.
Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.
Therefore, there would be no potential to impact unknown archaeological resources potentially located within the project site (Impact CR -1). Further, there would be no potential to disturb previously unidentified human remains that may be present on the project site (Impact CR-2). As such, mitigation measures MM-CR-1 and MM-CR-2 would not be implemented or required. Compared to the proposed project, the No Project/No Development Alternative would eliminate potential cultural resources impacts. N o impacts to cultural resources would occur under the No Project/No Development Alternative.
Energy
Under the No Project/No Development Alternative, there would be no energy use associated with construction and operation, since no development would occur. While impacts under the proposed project related to energy use were determined to be less than signi ficant, they would be eliminated under this alternative since there would be no energy use. Compared to the proposed project, the No Project/No Development Alternative would eliminate the energy use identified for the project and there would be no energy impacts.
Geology and Soils
Under the No Project/No Development Alternative, the project site would remain in its current state.
Existing topography and on-site soils would not be modified to accommodate proposed development.
While geology and soils impacts were determined to be less than significant for the project, this alternative would eliminate any geology and soils impacts. No geology and soils impacts would occur under this alternative. Compared to the proposed project, the No Project/No Development Alternative would reduce potential impacts related to geology and soils.
Hydrology and Water Quality
Under the No Project/No Development Alternative, no development would occur, and no impervious surfaces would be created. The existing on-site hydrologic conditions, drainage patterns, and drainage volumes would remain unaltered. Water quality would also r emain unchanged. While the proposed project’s hydrology and water quality impacts were determined to be less than significant, this
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alternative would further minimize potential impacts related to hydrology and water quality, and no impact would occur.
Land Use and Planning
Under this alternative, the project site would remain undeveloped and none of the discretionary approvals identified for the project would be required, including the Specific Plan Amendment, adoption of the new Woodward 46 Specific Plan, General Plan Amendment, Site Development Plan, Tentative Subdivision Map and Conditional Use Permit . While the proposed project’s land use and planning impacts were determined to be less than significant, the No Project/ No Development would further minimize potential impacts related to land use and planning, and no impact would occur.
Noise
The project site is currently vacant and does not generate any noise. Under the No Project/No Development Alternative, the project site would remain undeveloped and would not create any new sources of construction or operational noise and vibration . As detailed in Section 3.9, Noise, the project has the potential for construction-related noise impacts due to rock drilling and rock crushing activities. Under this alternative, the potential for noise impacts would be eliminated since no blasting or rock crushing activities would occur. As such, noise impacts under this alternative would be reduced as compared to the proposed project.
Public Services
The No Project/No Development Alternative would not result in an increase in demand for public services, since no residential uses would be developed and there would be no increase in the City’s population. Specifically, the No Project/No Development Alter native would not increase the demand for police and fire protection services, nor would this alternative increase demand for park, school, and library services. As stated in Section 3.10, Public Services, public service impacts for the proposed project would be less than significant. Since this alternative would not result in additional residents on site, impacts on public services would be reduced, compared to the proposed project. No public services impacts would occur under the No Project/No Development Alternative.
Transportation
The No Project/No Development Alternative would not result in the generation of vehicular trips. Under this alternative the minimum 50-foot southbound left-turn pocket on Woodward Street would not be constructed. While the proposed project would have less than significant transportation impacts, this alternative would have no impact related to transportation.
Tribal Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.
Therefore, there would be no potential to impact tribal cultural resources (Impact TCR -1). As such, mitigation measures MM-TCR-1 through MM-TCR-12 would not be implemented or required. No impact would occur, and compared to the proposed project, the No Project/No Development Alternative would result in a reduced level of potential impact to tribal cultural resources.
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Utilities and Service Systems
No development would be constructed under the No Project/No Development Alternative. As such, there would be no increase in demand for water service, wastewater service, stormwater capacity, energy, and solid waste handling services. As discussed in Section 3.13.4, Utilities, project impacts related to utilities and service systems were determined to be less than significant. Because no development would occur under this alternative, the demand for utilities would be eliminated.
Additionally, the sewer line extension within Woodward Street that is required to serve the project would not be needed under this alternative. Thus, impacts to utilities and service systems would be reduced compared to the proposed project. No utilities and service system impacts would occur for the No Project/No Development Alternative.
Conclusion
Since the No Project/No Development Alternative would not develop any residential uses on the project site, overall impacts would be less than those of the proposed project or eliminated entirely.
There are some benefits of the project that would not be re alized under this alternative, including providing additional housing units in the City which helps the City meet its Regional Housing Need Allocation numbers. Under this alternative there would not be any payment of the City’s Public Facilities Fees (PFF), which goes toward supporting a variety of services and improvements in the City, including but not limited to Circulation Streets, State Route 78 Interchanges, National Pollutant Discharge Elimination System, Tech Improvements, Parks, and Habitat Conservation. Payment of these fees provide improvements that benefit all residents of the city. Similarly, this alternative would not contribute any school fees. Finally, this alternative would not meet any of the project objectives ( Table
4-1).
4.3.3 No Project/Existing Plan Alternative
Typically, under a No Project/Existing Plan Alternative, the project site would be developed consistent with the site’s existing land use designation. The project site has a General Plan Designation of SPA (Specific Plan Area) and is associated with the Heart of the City Spe cific Plan (HOCSP). The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Mission Road corridor, including the project site, have a sub -plan designation of Richmar Specific Plan. Prio r to the site’s inclusion under the Richmar sub -plan, the underlying designation for the property was Single-Family Detached 2 to 4 du/ac per the HOCSP.
Development criteria for the Richmar Specific Plan have not been adopted by the City and there is no current City effort to do so. Therefore, properties requesting development within this sub-plan area are required to establish individual specific plans. As such, there is no fixed land use or density currently assigned to the project site. The Richmar Specific Plan identifies commercial, office and multifamily residential as land use options within the Richmar planning area.
Due to its location and the adjacent residential land uses, a multifamily residential development, under a Specific Plan, is the most suitable land use for the subject property. City policy requires that a secondary access be provided if more than 50 units are proposed. Given the topographical constraints of the site and the adjacent residential land uses, multifamily residential land use is assumed as the existing land use for this analysis. The project site would not be suitable for commercial or office development given the site topography and adjacent uses. It is also assumed that a maximum of 50 multifamily residential units could be built on the site given the topographical constraints and the lack
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of availability of a secondary/emergency vehicle access point. Under this scenario the site would have a density of 5.9 du/acre and a Specific Plan would be required.
The overall footprint of development for the 50 units (25 buildings with two units each) is assumed to be the same as the proposed project. The units would still be duplexes; however , the units would be smaller. Building heights would be up to 45 feet. Site access would be similar to the proposed project and would be via a driveway from Woodward Street. Grading, blasting and rock crushing as well as fire fuel modification would be required for this alternative.
4.3.3.1 Comparison of the Effects of the No Project/Existing Plan Alternative to the Proposed Project
Aesthetics
The No Project/Existing Plan Alternative would develop 25 two-unit buildings. The site would be modified through grading and retaining wall construction to allow for the access driveway and building pads. Building heights would be maximum of 45 feet. Similar to the proposed project, a Specific Plan would be prepared to establish the development rules and regulations of the land uses under this alternative. Similar to the proposed project, architectural treatments would be used to break up the bulk and scale of the buildings and add visual interest. Enhanced architectural treatments for highly visible buildings would also be incorporated. A landscape concept plan would also be implemented.
Similar to the proposed project, this alternative would incorporate lighting for safety, security and way finding. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. The No Project/Existing Plan Alternative would have a similar level of aesthetics impact as the proposed project and those impacts would be less than significant.
Air Quality
Under the No Project/Existing Plan Alternative, air pollutant emissions associated with project construction including emissions associated with grading, blasting, rock crushing, site preparation, site finishing and building finishing would still occur. Since 25 buildings would be constructed (versus 23 with the proposed project), there would be more emissions associated with construction and architectural coatings under this alternative. Grading activities would be similar to the proposed project since a similar footprint for development is assumed.
Emissions from vehicles going to and from the project site typically account for the largest portion of air quality emissions. Vehicular trips under the No Project/ Existing Plan Alternative would be slightly higher than the proposed project. This alternative would generate approximately 400 average daily trips (ADT) compared to the 368 ADT anticipated for the project, an approximate 9% increase. As such, because this alternative would result in an increase of ADT on site, operational air pollutant emissions would be slightly increased when compared to the proposed project. Operational and construction air pollutant emissions under this alternative would still be less than significant. Similar to the proposed project, impacts related to odors would be less than significant under this alternative. Overall, the No Project/Existing Plan Alternative would increase air quality emissions during both project construction and operation compared to the proposed project, but impacts would continue to be less than significant.
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Biological Resources
Since it would have a similar footprint of disturbance, the No Project/Existing Plan Alternative would have a similar level of biological resources impacts as the proposed project, including potential impacts to coastal California gnatcatcher (Impact BIO -1), Crotch’s bumble bee (Impact BIO -2), other special-status wildlife species and nesting birds (Impact BIO-3 and Impact BIO-4), indirect impacts to sensitive species (Impact BIO-5) and impacts to Diegan coastal sage scrub (Impact BIO-6). Mitigation measures MM-BIO-1 through MM-BIO-6 would still be required under this alternative. Compared to the proposed project, this alternative would result in a similar level of biological resources impacts.
Cultural Resources
The No Project/Existing Plan Alternative would require a similar level of grading as the development footprint would be similar as the proposed project. Therefore, the potential to impact unknown archaeological resources or unidentified humans remains potentially located within the project site would be similar. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1 and MM-CR-2) and would reduce the impacts to below a level of significance. The No Project/Existing Plan Alternative would have a similar level of cultural resources impacts as the proposed project.
Energy
Construction of the No Project/Existing Plan Alternative would include a similar amount of grading and soil hauling as the proposed project. Therefore, construction -related energy use would be similar to that of the proposed project. Operationally, the pro ject would require slightly more energy use since the number of residential units would be slightly increased (50 units vs 46 units) . Additionally, since this alternative would generate slightly more ADT compared to the proposed project, fuel use would also be slightly increased under this alternative. Similar to the proposed project, this alternative would incorporate energy conservation features consistent with the requirements of Title 24 and would not result in the wasteful or inefficient use of energy or a conflict with a state or local plan for energy efficiency. Compared to the proposed project, energy demand would be slightly greater with the No Project/Existing Plan Alternative, but impacts would continue to be less than significant.
Geology and Soils
Under the No Project/Existing Plan Alternative ground -disturbance would be required for the construction of the residential units. Development under this alternative would be required to implement the recommendations from the preliminary geotechnical inves tigation (GeoTek 2019).
These recommendations include general provisions related to earthwork, and design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, an d post -construction considerations. Compliance with the recommendations of the preliminary geotechnical investigation would ensure that seismic and soils hazards would be addressed through project design and impacts related to geological and soils hazards would be less than significant, similar to the proposed project. The No Project/Existing Plan Alternative would have a similar level of geology and soils impacts as the proposed project.
Hydrology and Water Quality
The No Project/Existing Plan Alternative would introduce impervious surfaces at the site in a similar quantity as the proposed project and the existing on-site hydrologic conditions, drainage patterns, and drainage volumes would be similarly modified. It is expected that this alternative would incorporate all
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required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adversely affect surface and groundwater quality, similar to the proposed project. As compared to the proposed project, this alternative would result in similar impacts and the impacts would be less than significant.
Land Use and Planning
Under the No Project/Existing Plan Alternative, the same list of project approvals would be required, including a Specific Plan Amendment to modify the HOCSP to remove the current Richmar Sub -Plan designation on the project, a new Specific Plan to establis h the development rules for the site, a General Plan Amendment to remove the Richmar Sub -Plan designation from the project site, a Site Development Plan, Tentative Subdivision Map and a Conditional Use Permit for a temporary rock crusher.
Development under this alternative would generate more traffic (400 ADT compared to 368 ADT) than the proposed project. The proposed project did not have any inconsistencies with the City’s Mobility Element goal related to level of service (LOS). While this alternative would generate slightly more ADT, it is not anticipated to have any LOS-related issues. Development under this alternative would still be required to participate in Community Facility District: CFD2011 -01 (Congestion Management). This alternative would have a similar level of impact as the proposed project, which is less than significant.
Noise
Grading-related noise under the No Project/Existing Plan Alternative would be similar to the proposed project, since grading activities would still be required, and similar types of equipment would be used.
Noise related to building construction would be similar to the proposed project but would last for a longer duration since two additional buildings would be constructed. The potential for significant impacts related to rock drilling and rock crushing would still be expected under this alternative and implementation of mitigation measures MM -N-1 and MM -N-2 would still be required. Similar to the proposed project, construction noise impacts would be reduced to below a level of significance with implementation of mitigation.
The No Project/Existing Plan Alternative would generate operational noise from residential activities as well as vehicle trips generated by the project. This alternative would generate slightly more ADT than the project ( 400 ADT compared to 368 ADT). Therefore, offsite noise generated by the project would be slightly increased under this alternative compared to the proposed project. Compared to the proposed project, this alternative would generate more noise during construction and operation; however, similar to the proposed project noise impacts would be reduced to below a level of significance with mitigation.
Public Services
Similar to the proposed project, the No Project/Existing Plan Alternative would result in an increase in demand for public services, due to the construction of residential uses. Specifically, this alternative would increase the demand for police and fire protection services over existing conditions. Residential uses are the primary driver for demand for park, library, and school services. This project would increase the amount of residential development by approximately 9% (50 units instead of 46 units), which results in a proportional in crease in the need for services. Development under this alternative would still be required to pay applicable PFF and school fees and participate in community facility districts for fire and police. Compared to the proposed project, this alternative would result in a slightly
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increased demand for fire and police services and increased demand for park, library and school services. Overall, similar to the proposed project, impacts to public services would be less than significant.
Transportation
Under the No Project/Existing Plan Alternative, impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are still anticipated to be less than significant. Development under this scenario would still be required to construct a minimum 50-foot southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane. This alternative would still be required to construct a sidewalk along the project acce ss driveway to connect the development with existing pedestrian infrastructure on Woodward Street. With regard to Vehicle Miles Traveled (VMT), it is assumed that development under this alternative would be screened out of needing further analysis, similar to the proposed project .
Overall, this alternative would generate slightly more VMT since four more residential units would be constructed. The No Project/Existing Plan Alternative would have a slightly increased level of transportation impacts as the proposed project, and those impacts would be less than significant.
Tribal Cultural Resources
The No Project/Existing Plan Alternative would require a similar level of grading as the development footprint would be similar to the proposed project. Therefore, the potential to impact tribal cultural resources would still occur under this alternative . Tribal c ultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM - TCR-1 through MM -TCR-12) and would reduce the impacts to below a level of significance. The No Project/Existing Plan Alternative would have a similar level of tribal cultural resources impacts as the proposed project.
Utilities and Service Systems
The No Project/Existing Plan Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service over existing conditions through the development of new residential uses. Proposed water use estimates and sewer generation rates for residential are based on the proposed density multiplied by the site acreage. Given that development under this alternative would be of the same land use type as the proposed project (Residential 4 -8 du/acre), the projected water demand and wastewater generation under this alternative would be the same as the proposed project. The sewer line extension in Woodward Street identified for the proposed project in the VWD technical memorandum (2023) would also be required for this alternative.
Storm water infrastructure demands are anticipated to be similar to the proposed project as a similar amount of impervious surface would be created. Solid waste generation would be slightly increased under this alternative but still less than significant. Similar to the proposed project, utilities and service system impacts would be less than significant under the No Project/Existing Plan Alternative . This alternative would have a similar level of impact to utilities and service systems as the proposed project.
Conclusion
The No Project/Existing Plan Alternative would result in a slightly more intensive use on the project site, including an increase in trip generation compared to the proposed project (400 ADT compared to 368 ADT). This results in a corresponding proportional increase in air pollutant s and noise from
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vehicles compared to the proposed project. Construction -related air polluta nts are expected to be slightly increased as construction duration would be longer due to additional building construction but a similar amount of grading, blasting, rock crushing and site preparation would be required.
Construction-related noise impacts due to rock drilling and rock crushing would be similar to the proposed project.
Footprint-specific impacts, such as those related to biological resources, cultural resources, and tribal cultural resources, would be similar to the proposed project, as the same amount of site area would be disturbed.
This alternative would slightly increase the number of students generated for San Marcos Unified School District ( SMUSD) and would increase demand for parks, libraries, and solid waste facilities compared to the proposed project. This alternative would have a similar water demand and wastewater generation as the proposed project. This alternative could meet the majority of the project objectives, as detailed in Table 4-1.
4.3.4 Reduced Density Alternative
Under the Reduced Density Alternative, the project site would be developed with single family residential uses at a reduced density of 2 du/acre, resulting in 16 single family homes. Prior to the last comprehensive update of the City’s General Plan, the project site was designated for Single-Family Detached under the HOCSP with a density of 2 to 4 du/acre assigned to it. The Reduced Density Alternative assumes the lower end of the density range given the steep slope of the property and preparation of a Specific Plan would be required. The maximum building height under this alternative would be 35 feet or two stories. Due to the topographical constraints of the site access would be similar to the proposed project and would be via a driveway on Woodward Street. Grading, blasting and rock crushing as well as fire fuel modification would be required for this alternative.
4.3.4.1 Comparison of the Effects of the Reduced Density Alternative to the Proposed Project Aesthetics
The Reduced Density Alternative would develop 16 single- family residences. The site would be modified through grading and retaining wall construction to allow for the access driveway and building pads. Building heights would be a maximum of 35 feet. Similar to the proposed project, a Specific Plan would be prepared to establish the development rules and regulations of the land uses under this alternative. Architectural treatments would be used to provide visual variety to the buildings, including enhanced treatments for highly -visible buildings. The Specific Plan would identify a planting palette and requirements for landscaping for each residence. Similar to the proposed project, this alternative would incorporate lighting for safety, security and way findi ng. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. Since the Reduced Density Alternative would develop single family residences, it would appear to be more visually consistent with the single - family residential development to the north and east. However, overall, development under this alternative would result in a generally similar level of visual change and would add lighting to an area where it does not currently exist. The Reduced Density Alternative would result in a similar level of impact as the proposed project and those impacts would be less than significant.
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Air Quality
Under the Reduced Density Alternative, air pollutant emissions associated with project construction including emissions associated with grading, blasting, rock crushing, site preparation, site finishing and building finishing would still occur. Grading act ivities would be similar to the proposed project, since a similar footprint for development is assumed . Building finishing and coating would be less under this alternative since fewer buildings would be constructed.
Emissions from vehicles going to and from the project site typically account for the largest portion of air quality emissions. Vehicular trips under the Reduced Density Alternative would be lower than the proposed project. This alternative would generate a pproximately 192 ADT compared to the 368 ADT anticipated for the project, an approximate 48% reduction. As such, because this alternative would result in a reduction of ADT on site, operational air pollutant emissions would be reduced when compared to the proposed project. However, operational and construction air pollutant emissions under this alternative would still be less than significant. Similar to the proposed project, impacts related to odors would be less than significant under this alternative. Overall, this alternative would decrease air quality emissions during both project construction and operation compared to the proposed project, and impacts would continue to be less than significant.
Biological Resources
Since it would have a generally similar footprint of disturbance, the Reduced Density Alternative would have a similar level of biological resources impacts as the proposed project, including potential impacts to coastal California gnatcatcher (Impact BIO -1), Crotch’s bumble bee (Impact BIO -2), other special-status wildlife species and nesting birds (Impact BIO-3 and Impact BIO-4), indirect impacts to sensitive species (Impact BIO-5) and impacts to Diegan coastal sage scrub (Impact BIO-6). Mitigation measures MM-BIO-1 through MM-BIO-6 would still be required under this alternative. Compared to the proposed project, this alternative would result in a similar level of biological resources impacts.
Cultural Resources
The Reduced Density Alternative would require a similar level of grading as the development. The location of the residential development would be generally similar to the proposed project .
Development under this alternative would still have the potential to impact unknown archaeological resources or unidentified human remains potentially located within the project site. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1 and MM-CR-2) and would reduce the impacts to below a level of significance. The Reduced Density Alternative would have a similar level of cultural resources impacts as the proposed project.
Energy
Construction of the Reduced Density Alternative would include a similar amount of grading and soil hauling as the proposed project. Therefore, construction-related energy use would be similar to that of the proposed project. Operationally, the project would require less energy use since the number of residential units would be reduced (46 units to 16). Additionally, since this alternative would generate fewer ADT compared to the proposed project, fuel use would also be reduced under this alternative.
Similar to the proposed project, this alternative would incorporate energy conservation features consistent with the requirements of Title 24 and would not result in the wasteful or inefficient use of energy or a conflict with a state or local plan for energy efficiency. Impacts are expected to be less
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than significant. Compared to the proposed project, energy demand would be decreased with the Reduced Density Alternative and impacts would continue to be less than significant.
Geology and Soils
Under the Reduced Density Alternative ground-disturbance would be required for the construction of the residential units. Development under this alternative would be required to implement the recommendations from the preliminary geotechnical investigation (GeoTek 2019). These recommendations include general provisions related to earthwork, and design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, and post -construction considerations. Compliance with the recommendations of the preliminary geotechnical investigation would ensure that seismic and soils hazards would be addressed through project design and impacts related to geological and soils hazards would be less than significant, simi lar to the proposed project. The Reduced Density Alternative would have a similar level of geology and soils impacts as the proposed project.
Hydrology and Water Quality
The Reduced Density Alternative would introduce impervious surfaces at the site in a similar quantity as the proposed project and the existing on-site hydrologic conditions, drainage patterns, and drainage volumes would be similarly modified. It is expected that this alternative would incorporate all required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adversely affect surface and groundwater quality, simi lar to the proposed project. As compared to the proposed project, this alternative would result in similar impacts and the impacts would be less than significant.
Land Use and Planning
Under the Reduced Density Alternative, the same list of project approvals would be required, including a Specific Plan Amendment to modify the HOCSP to remove the current Richmar Sub-Plan designation on the project, a new Specific Plan to establish the development rules for the site, a General Plan Amendment to remove the Richmar Sub -Plan designation from the project site, a Site De velopment Plan, Tentative Subdivision Map, and a Conditional Use Permit for a temporary rock crusher.
Development under this alternative would generate less traffic (192 ADT compared to 368 ADT) than the proposed project. The proposed project did not have any inconsistencies with the City’s Mobility Element goal related to LOS. Therefore, this alternative, since it would generate even fewer ADT, would not have any LOS -related issues. Development under this alternative would still be required to participate in Community Facility District: CFD2011 -01 (Congestion Management). This alternative would have a similar level of impact as the proposed project, which is less than significant.
Noise
Grading- -related noise under the Reduced Density Alternative would be similar to the proposed project, since grading activities would still be required, and similar types of equipment would be used.
Noise related to building construction would be similar to the proposed project but would last for a shorter duration since 7 fewer buildings would be constructed. The potential for significant impacts related to rock drilling and rock crushing would still be expected under this alternative and implementation of mitigation measures MM -N-1 and MM -N-2 would still be required. Similar to the proposed project, construction noise impacts would be reduced to below a level of significance with implementation of mitigation.
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The Reduced Density Alternative would generate operational noise from residential activities as well as vehicle trips generated by the project. This alternative would generate fewer ADT than the project (192 ADT compared to 368 ADT). Therefore, offsite noise generated by the project would be reduced under this alternative compared to the proposed project. Compared to the proposed project, this alternative would generate less noise during construction and operation; however, similar to the proposed project, noise impacts would be reduced to below a level of significance with mitigation.
Public Services
Similar to the proposed project, the Reduced Density Alternative would result in an increase in demand for public services, due to the construction of residential uses. Specifically, this alternative would increase the demand for police and fire protection services over existing conditions. Residential uses are the primary driver for demand for park, library, and school services. This project would reduce the amount of residential development by approximately 65% (16 units instead of 46 units), which results in a proportional decrease in the need for services. Development under this alternative would still be required to pay applicable PFF and school fees and participate in community facility districts for fire and police. Compared to the proposed project, this altern ative would result in a reduced demand for fire and police services and decreased demand for park, library, and school services. Overall, similar to the proposed project, impacts to public services would be less than significant.
Transportation
Under the Reduced Density Alternative, impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are still anticipated to be less than significant.
Development under this scenario would still be required to construct a minimum 50-foot southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane. This alternative would still be required to construct a sidewalk along the project access driveway to connect the development with the existing pedestrian infrastructure on Woodward Street.
With regard to VMT, it is assumed that development under this alternative would not screen out of a VMT analysis since it would not meet the floor area ratio requirement of 0.75 or greater. Given the lower density of development, the floor area ratio of 0.75 would not be achieved under this alternative.
According to San Diego Association of Government (SANDAG) San Diego Region SB 743 VMT Maps, the project site is within an area where the VMT is 101% of the regional mean for VMT (19.3 VMT/capita compared to the regional mean of 18.9 VMT/capita) (SANDAG 2023). In order to avoid a significant VMT impact, development under this alternative would be required to reduce VMT to 85% of the regional mean, or a total of 16%. There is a limit to the amount of VMT reduction that can be applied to a development project. Within the City, with its suburban land use the maximum feasible total reduction combining all VMT -reducing mitigation measures is 15%. Therefore, the Reduced Density Alternative would end up with a significant and unmitigated transportation impact related to VMT under the purposes of CEQA. This results in a greater level of impact compared to the proposed project.
Tribal Cultural Resources
The Reduced Density Alternative would require a similar level of grading as the proposed development.
The location of the residential development would be generally similar to the proposed project and development under this alternative would still have the potential to impact tribal cultural resources.
Tribal cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (mitigation measures MM -CR-1 and MM-CR-2) and would reduce the impacts to
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below a level of significance. The Reduced Density Alternative would have a similar level of tribal cultural resources impacts as the proposed project.
Utilities and Service Systems
The Reduced Density Alternative would result in an increase in demand for utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service over existing conditions through the development of new residential uses. Based upon the w ater/sewer technical memorandum prepared by VWD (2023) and according to assumptions in their 2018 Master Plan, development under this alternative would have a water demand of 15,480 gallons per day (gpd) and a sewer generation of 6,450 g pd. The proposed project would have a water demand of 21,500 gpd and a sewer demand of 11,180 gpd. Therefore, the demand for sewer and water services would be decreased under this alternative compared to the proposed project. However, the sewer line extension in Woodward Street identified for the proposed project in the VWD technical memorandum (2023) would also be required for this alternative.
Storm water infrastructure demands are anticipated to be similar to the proposed project as a similar amount of impervious surface would be created. Solid waste generation would be decreased under this alternative due to fewer residential units.. Overall, compared to the proposed project, water, sewer, and solid waste demand would be less under the Reduced Density Alternative but similar to the proposed project, utilities and service system impacts would be less than significant.
Conclusion
The Reduced Density Alternative would result in a less intensive use on the project site, including a reduction in trip generation compared to the proposed project (192 ADT compared to 368 ADT). This results in a corresponding proportional decrease in air pollutant s and noise from vehicles compared to the proposed project. Grading-related air pollutants are expected to be similar under this alternative since a similar amount of grading, blasting, rock crushing and site preparation would be required.
Fewer a ir pollutants would be generated from building coating and finishes, since seven fewer buildings would be constructed. Construction -related noise impacts due to rock drilling and rock crushing would be similar as the proposed project.
Footprint-specific impacts, such as those related to biological resources, cultural resources, and tribal cultural resources, would be similar as the proposed project, as the same amount of site area would be disturbed.
This alternative would reduce the number of students generated for SMUSD and would reduce demand for parks, libraries, water, sewer, and solid waste services compared to the proposed project.
The Reduced Density alternative could meet the majority of the project objectives, as detailed in Table 4-1, but would not provide multi-family housing in the 4.1-8.0 dwelling unit range.
4.4 Alternatives Considered But Rejected
CEQA Guidelines Section 15126.6(c) provides guidance in selecting a range of reasonable alternatives for the project. An EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. CEQA Guidelines Section
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15126.6(c) provides the following guidance in selecting a range of reasonable alternatives for the project. There are many factors that may be taken into account when addressing the feasibility of the range of potential alternatives for the project, such as site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by the proponent). The alternatives discussion shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significa nt effects. An EIR should also identify any alternatives that were considered by the lead agency but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency's determination.
The EIR need not discuss every alternative to the project. A range of alternatives that are “reasonable” for analysis have been evaluated and are discussed above in Section 4.3, Project Alternatives Considered in this EIR. The following describes other alternatives considered by the City but dismissed from further evaluation in this EIR, and a brief description of the reasons for their rejection.
4.4.1 Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations to the project. There are sites within the city of an approximately equivalent size to the project site that could be redeveloped with a residential project; however, the project applicant does not control another site within the city of comparable land area that is available for development of the proposed project. One of the factors for feasibility of an alternative is “whether the propone nt can reasonably acquire, control or otherwise have access to the alternative site.” Because the city is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is not considered feasible. It should also be noted that the project site is surrounded by development and located adjacent to tra nsportation facilities, existing, transit and utility infrastructure. Further, the HOCSP identified the site for residential development. As such, an alternative location was ultimately rejected from further analysis in the EIR.
4.5 Environmentally Superior Alternative
Table 4 -2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project. As shown in Tables 4-1 and 4-2, the No Project/No Development Alternative would eliminate all of the potentially significant impacts identified for the project. However, the No Project/No Development Alternative would not meet any of the project objectives. Additionally, there is no certainty that the project site would remain undeveloped in perpetuity. CEQA Guidelines Section 15126.6(e)(2) states that if the No Project alternative is identified as the environmentally superior alternative, then an environmentally superior alternative should be identified among the other alternatives. Among the other alternatives, not including the proposed project, the No Project/Reduced Density Alternative is the environmentally superior alternative because it would provide a reduced level of impact in some environmental analysis areas including air quality, energy, noise, public services, and utilities/service s ystems. Mitigation measures would still be required to mitigate impacts to biological resources, cultural resources/tribal cultural resources , and noise. However, the Reduced Density Alternative was not selected as it would result in a new significant and unmitigated impact related to transportation (VMT impact).
4.0 Alternatives
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Table 4-1. Summary of Alternatives and Project Objectives Objective Proposed Project
(46 units)
No Project/No
Development
No Project/Existing
Plan Alternative
(50 units)
Reduced Density
Alternative
(16 units)
Provide multi-family housing opportunities close to major transit, educational facilities, shopping opportunities, employment uses, and trails to optimize alternative modes of transportation, reduce reliance on automobiles, and
potentially reduce greenhouse gas emissions.
Meets objective Does not meet this
objective
Meets objective Does not meet this
objective
To the extent possible given site constraints, maximize the opportunity to provide housing for the City of San Marcos in the 4.1 to 8.0 dwelling unit density range which is
comparable to low-density housing developments in the
City of San Marcos.
Meets objective Does not meet this
objective
Meets objective Does not meet this
objective
Cluster development to lessen site impacts and minimize landform modification.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
Develop high-quality attainable housing which meets the housing needs of the City of San Marcos and the region.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
Create a development that promotes a high-quality-of-life by providing each dwelling unit its own private patio/yard space and by providing a common recreational open space gathering area.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
Establish development standards and design guidelines
that ensure distinctive architecture, landscaping and
recreational amenities that complements and enhances
the existing surrounding neighborhood while providing a desirable living environment for residents within the
Specific Plan Area.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
Institute a program for the long-term maintenance of the community to ensure all facilities are adequately
maintained to City standards.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
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Objective Proposed Project
(46 units)
No Project/No
Development
No Project/Existing
Plan Alternative
(50 units)
Reduced Density
Alternative
(16 units)
Finance or contribute a fair share of funding to all
community services and infrastructure needed to support Specific Plan development to promote economic stability.
Meets objective Does not meet this
objective
Could be designed in
a manner that meets
this objective
Could be designed in
a manner that meets
this objective
Table 4-2. Comparison of Impacts of Proposed Project and Alternatives Environmental Topic Proposed Project
No Project/No
Development
Alternative
No Project/Existing
Plan Alternative (50
Units)
Reduced Density
Alternative (16 Units)
Aesthetics LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
Air Quality LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Biological Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
Energy LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Geology and Soils LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
Hydrology and Water Quality LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
Land Use and Planning LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
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Environmental Topic Proposed Project
No Project/No
Development
Alternative
No Project/Existing
Plan Alternative (50
Units)
Reduced Density
Alternative (16 Units)
Noise LTSM No Impact
(Reduced)
LTSM
(Increased)
LTSM
(Reduced)
Public Services LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Transportation LTS No Impact
(Reduced)
LTSM
(Increased)
SU
(Increased)
Tribal Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
Utilities and Service Systems LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
Notes: Impact Status: LTS = Less than significant impact; LTSM = Less than significant with mitigation; SU = Significant and Unmitigated
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5.0 Environmental Effects Found not to be Significant
The City of San Marcos completed an Initial Study (IS) for the proposed project in accordance with Sections 21000-21189 of the Public Resources Code and Section 15063 of the California Environmental Quality Act (CEQA) Guidelines. A Notice of Preparation (N OP) was prepared by the City and mailed to applicable agencies, organizations, and neighboring property owners. The NOP is included in Appendix B.2 of this Environmental Impact Report (EIR).13 As required by Section 15128 of the CEQA Guidelines, the following is a discussion of the environmental effects that were considered as a part of the Initial Study but were determined to have “No Impact”, and, therefore, are not discussed in detail in this EIR.
In some instances, complete environmental issue areas were eliminated during the IS process, including agriculture/forestry resources, greenhouse gas emissions, hazards/hazardous materials, mineral resources, population and housing, recreation, and wildfire. In other instances, some of the specific CEQA thresholds were eliminated during the IS process including aesthetics (scenic vistas, scenic resources within a state scenic highway), biological resources (federally protected wetlands, wildlife movement), cultural resources (historical resources), geology and soils (septic systems), hydrology and water quality (groundwater, flood hazards/tsunami/seiche), land use and planning (physically divide and established community), and noise (project vicinity to priv ate airports or within and airport land use plan).
5.1 Aesthetics
Threshold of Significance: Have a substantial adverse impact on a scenic vista.
The project site is located within the Richland Neighborhood in the City. The City has a Ridgeline Protection and Management Overlay Zone to protect natural viewsheds and unique natural resources, minimize physical impacts to ridgelines, and to establish innovative sensitive architectures standards.
The project site is not located in the Ridgeline Protection and Management Overlay Zone. Further, the project site does not include any primary or secondary ridgelines, as identified in Figure 4 -5 of the Conservation and Open Space Element of the General Plan (San Marcos 2012). Therefore, development of the project site would not have a substantial adverse effect on a scenic vista and no impact would occur.
Threshold of Significance: Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway.
The project site is located approximately 0.4 miles north of SR-78. A portion of SR-78 is recognized as a Scenic Highway by California Department of Transportation (Caltrans); however, that portion is not in the project vicinity. The portion identified as a Scenic Highway is approximately 50 miles east of the project site near Anza Borrego (Caltrans 2019). At a local level, SR-78 is designated by the City of San Marcos as a view corridor. The highway corridor provides views of the Merriam Mountains, Mount Whitney, and Double Peak. There are no scenic resources on the project site. The project site is undeveloped and does not support any historic buildings (ASM 2024). In summary, the project would
13 The Initial Study, NOP, and comment letters received on the NOP are included in Appendices B.1, B.2 and B.3 of the EIR.
5.0 Environmental Effects Found not to be Significant
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not damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. No impact would occur.
A discussion of additional aesthetics significance thresholds is provided in Section 3.1, Aesthetics.
5.2 Agriculture and Forestry Resources
Threshold of Significance : Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use.
The project site is not mapped as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as determined by the Farmland Mapping and Monitoring Program, as shown on Figure 4- 4 (Agricultural Areas) in the San Marcos General Plan (San Marcos 2012). Therefore, the project would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. No impact is identified for this issue area.
Threshold of Significance : Conflict with existing zoning for agricultural use, or a Williamson Act contract.
The project site has a General Plan designation of SPA (Specific Plan Area) and a zoning designation of Specific Plan Area (SPA). The project site does not support zoning for agricultural use. The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space use. In return, landowners receive property tax assessments which are m uch lower than normal because they are based upon farming and open space uses as opposed to full market value. The project site is not located within a Williamson Act contract area. Therefore, the project would not conflict with existing zoning for agricultural use , or a Williamson Act contract, and no impact is identified for this topic.
Threshold of Significance: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)).
Forest land is defined as “land that can support ten percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, b iodiversity, water quality, recreation, and other public benefits” (California Public Resources Code Section 1220(g)). Timberland is defined as “land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees” (California Public Resources Code Section 4526). A Timberland Production Zone is defined as “an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses” (California Public Resources Code Section 51104(g)).
The project site has a General Plan designation of SPA (Specific Plan Area) and a zoning designation of Specific Plan Area (SPA). The proposed project is not located in an area that is zoned for forest land, timber land or for timber production nor is it adjacent to lands that are zoned forest land, timber land
5.0 Environmental Effects Found not to be Significant
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or for timber production. Implementation of the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned timberland production. No impact is identified for this topic.
Threshold of Significance: Result in the loss of forest land or conversion of forest land to non -forest use.
The project site is undeveloped. As described above, t he project site does not support forest lands, nor is there any forest land adjacent to the project site. Therefore, the proposed project would not result in the loss of forest land or the conversion of forest land to non-forest use. No impact is identified for this topic.
Threshold of Significance: Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.
The project would not result in any other changes to the existing environment that would, due to their location or nature, result in the conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. There is no agricultural activity on the project site or in the project vicinity. No impact is identified for this topic.
5.3 Biological Resources
Threshold of Significance: Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Based upon the Biological Resources Report prepared by Rincon (202 5), no natural drainages or wetlands were observed during the surveys or background research. Concrete v-ditches (brow ditches) were identified in the northeast portion of the study area along a chain link fence that runs along the slope and down towards the junction of Woodward Stre et and Vineyard Street. Vegetation has overgrown much of the areas along the man -made ditch. The concrete drainage ditches were constructed and installed by Ryland Homes as part of the Woodward Improvement Plan approved and permitted by the City of San Marcos on January 27, 2000. The construction of the “Type B” brow ditch along the northwestern boundary of the project site (including portions of the project impact area) was constructed on existing mitigated easements by Ryland Homes. An additional concrete v-ditch, constructed and installed by KB homes, is located along the southwest corner at the top of a retaining wall as part of the residential development to the south. The function of the concrete ditches is to safely direct stormwater flow off the road ways and slope as shown in site plans for the Woodward Improvement Plan. These manmade, non-natural, stormwater conveyance ditches originate in upland areas and not in any natural drainages.
The concrete ditches do not provide habitat functions for fish and wildlife. The ditches are intended to capture stormwater runoff and sheet flow from upslope areas and safely convey them for erosion control.. Riparian habitat located to the west of Woodwa rd Street adjacent and associated with San Marcos Creek is within the study area but outside of the project’s boundaries. A formal jurisdictional delineation was not conducted; however, these human -constructed concrete v -ditches were determined to not be jurisdictional, with no evidence of presence of Waters of the US (WoUS) or Waters of the State (WoS) occurring within the project site or project impact area. Human -constructed concrete v-ditches on slopes are typically not considered to comprise WoUS or WoS. No connection
5.0 Environmental Effects Found not to be Significant
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was identified from these ditches to San Marcos Creek or Twin Oaks Creek. Therefore, no direct or indirect impacts to state or federally protected wetlands have been identified for the implementation of the proposed project. No impact would occur.
Threshold of Significance: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Wildlife movement corridors are defined as areas that connect suitable wildlife habitat areas in a region otherwise fragmented by rugged terrain, changes in vegetation, or human disturbance. Natural features such as canyon drainages, ridgelines, and areas with vegetation cover provide corridors for wildlife travel. The project site is a habitat island, with Woodward Street along the western boundary of the project site which separates it from Twin Oaks Valley Creek to the west, Mission Road south of the project site, and residential development north, south, and east of the project site blocking any significant wildlife movement. There is an Open Space lot directly north of the project site, however the project area and vicinity are not identified as being within or adjacent to a wildlife corridor per Figure 4-2 of the City of San Marcos General Plan (San Marcos 2012). The project area is also not within or adjacent to a Biological Core and Linkage Area (BCLA) as illustrated in Figure 2-3 of the Final Multiple Habitat Conservation Program (MHCP) Plan (SANDAG 2003). Areas identified as Focused Planning Areas (FPAs) within the Multiple Habitat Conservation Plan occur to the north, northeast, east, and west of the project site. These designated preserved native habitats provide local movement (i.e., “stepping stone) rather than regional linkage, for local and migratory species such as birds, including federal, state, and MHCP covered species. No impact is identified for this topic.
A discussion of additional biological resources significance thresholds is provided in Section 3.3, Biological Resources.
5.4 Cultural Resources
Threshold of Significance: Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.
Based upon the cultural resources report prepared for the project (ASM 2024) there are no historical resources on the project site. Therefore, the project would not have the potential to cause a substantial adverse change in historic resources, as defined in Section 15064.5 of the CEQA Guidelines. No impact is identified for this topic.
A discussion of additional cultural resources significance thresholds is provided in Section 3.4, Cultural Resources.
5.5 Geology and Soils
Threshold of Significance: Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of wastewater.
Septic tanks and alternative wastewater disposal systems are not proposed as part of the project. The project would receive wastewater service from Vallecitos Water District (VWD) and would connect to existing sewer infrastructure in Woodward Street (VWD 2023). Therefore, no impact is identified for this issue area.
5.0 Environmental Effects Found not to be Significant
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A discussion of additional geology and soils significance thresholds is provided in Section 3.6, Geology and Soils.
5.6 Greenhouse Gas Emissions
Threshold of Significance: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
The City adopted a Climate Action Plan (CAP) which was developed to help reduce the City’s greenhouse gas (GHG) emissions (San Marcos 2020). As part of the CAP, the City developed a CAP Consistency Review Checklist (Checklist). The purpose of the Checklist is to implement the GHG reduction measures from the CAP that apply to new discretionary development. New development that demonstrates consistency with relevant CAP strategies would not conflict with the City’s ability to achieve the identified GHG reduction targets through implementation of applicable measures. Projects that are consistent with the CAP, as determined through the use of the CAP Checklist, may rely on the CAP for the cumulative impact analysis of GHG emissions. The CAP Checklist identifies certain sizes and types of projects that would emit fewer than 500 metric tons ( MT) of carbon dioxide equivalent (CO
2e) per year. Projects that emit fewer than 500 MT CO 2e per year would be determined to have a less than significant GHG impact and would not be subject to the measures of the CAP. Multifamily residential projects of 55 dwelling units or less are considered to emit fewer than 500 MT CO2e per year. The project proposes 46 multifamily units. Therefore, it would fall under the 55 multifamily unit criteria and GHG impacts would be less than significan t. The project’s CAP Checklist is included as Appendix F of the EIR.
Threshold of Significance: Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases? Under the City’s CEQA thresholds, the method for determining significance for project -level environmental documents is through the CAP Checklist. The city's CAP is also consistent with state/regional goals. As discussed above, the project would be consistent with the City’s CAP , no conflict is identified and GHG impacts would be less than significant.
5.5 Hazards and Hazardous Materials
Threshold of Significance: Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials? Hazardous materials include solids, liquids, or gaseous materials that, because of their quantity, concentration, or physical, chemical, or infectious characteristics could pose a threat to human health or the environment. Hazards include the risks associated with potential explosions, fires, or release of hazardous substances in the event of an accident or natural disaster, which may cause or contribute to an increase in mortality or serious illness or pose substantial harm to human health or the environment. The proposed project would involve the transport of fuels, lubricants, and various other liquids needed for operation of construction equipment at the site on an as-needed basis by equipment service trucks. Materials hazardous to humans, wildlife, and sensitive environments, including diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets, would be present during project construction. The potential exists for direct impacts to human health from accidental spills of small amounts of hazardous materials from construction equipment; however, the proposed project would be required to comply with Federal, State, and City Municipal Code restrictions which regulate and control those materials handled onsite.
5.0 Environmental Effects Found not to be Significant
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Compliance with these restrictions and laws would ensure that potentially significant impacts would not occur during project construction.
In addition, as a residential project, the only hazardous materials anticipated for transport or disposal associated with the proposed project during operation are routinely used household products such as cleaners, paint, solvents, motor oil/ automotive products, batteries, and garden maintenance products.
It is anticipated that the use, handling, and disposal of these products would be addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan of the County of San Diego and other Federal, State, and City Municipal Code regulations.
In summary, the project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impacts would be less than significant.
Threshold of Significance: Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The project site is vacant and undeveloped. There are no existing site conditions which would result in a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions that could involve the release of hazardous materials into the environment. No impact is identified for this issue area.
Threshold of Significance: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The project site is not located within 0.25 miles of an existing or proposed school. The closest school is San Marcos Elementary school, which is located approximately 0.5 miles to the southwest. No impact is identified.
Threshold of Significance: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The provisions of Government Code Section 65962.5 are commonly referred to as the Cortese List.
The Cortese List is a planning document used by the state and local agencies to provide information about hazardous materials release sites. Government Code Sec tion 65962.5 requires California Environmental Protection Agency (CalEPA) to develop an updated Cortese List annually, at minimum.
California Department of Toxic Substances Control ( DTSC) is responsible for a portion of the information contained in the Cor tese List. Other California state and local government agencies are required to provide additional hazardous material release information for the Cortese List.
A search of the DTSC EnviroStor site was conducted on May 16, 2023, to see if there are any current or historical environmental cleanups or permitted facilities on or adjacent to the project site. There are no current or past permitted facilities or cleanup activities on the project site (DTSC 2023). The closest listed sites per EnviroStor are:
• TRI-M-CO, 528 E. Mission Road - A leaking underground storage tank (LUST) cleanup site located approximately 0.4 miles east of the project site. The cleanup was completed in 1993 and the case is closed.
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• United States Post Office, 420 N. Twin Oaks Valley Road - A LUST cleanup site located approximately 0.2 miles west of the project site. The cleanup was completed in 2006 and the case is closed.
Due to the distance of these listings from the project site as well as the fact that they have been cleaned up, there would be no impact associated with the project.
Threshold of Significance: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The nearest airport is the McClellan -Palomar Airport in Carlsbad, which is located approximately 6.5 miles to the southwest of the project site. According to Figure 6-5 of the Safety Element of the City’s General Plan, the project site is located within Review Area 2 of the airport influence area. Review Area 2 limits the heights of structures in areas of high terrain. While the project is on an elevated hillside, the site is situated, overall, in the lower elevation portion of the City. According to the Airport Land Use Compatibility Plan (ALUCP) for the McClellan-Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, the project would not result in a safety hazard of excessive noise for people residing or working in the project area. No impact is identified.
Threshold of Significance: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
According to the General Plan Safety Element, the San Marcos Emergency Operations Plan (EOP) governs the operations of the City during a disaster. This plan addresses response to moderate evacuation scenarios, including the identification of evacuation points and general routes (San Marcos 2012). The project would not result in any changes to the transportation network which could impair implementation of or physically interfere with an adopted emergency response plan. No impact would occur.
Threshold of Significance: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? The project site is located in a developed part of the City and is not located where wildlands are adjacent to urbanized areas, nor does the project propose residences mixed in with wildlands. There are two easements on the site associated with vegetation management for fire fuel reduction. One is located along a portion of the site’s eastern boundary and the other is located along a portion of the site’s southern boundary. The project site is located in a Local Responsibility Area, not a State Responsibility area (CAL FIRE 2022). The project site is in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non -VHFHSZ) designation per the California Department of Forestry and Fire Protection (CAL FIRE) San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a San Marcos Fire Protection District (SMFPD) Community Hazard Zone. Impacts would be less than significant.
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5.7 Hydrology and Water Quality
Threshold of Significance: Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.
The project would be served by VWD for water service. VWD water supplies come from the Metropolitan Water District and the San Diego County Water Authority. Both of these agencies use some groundwater for their supplies. The proposed project will be supplied from existing VWD supplies, which would have assumed the use of groundwater. VWD assumed development of the project site in the 2018 Master Plan and VWD has indicated their availability to serve the project (VWD 2023). The project would not develop any new groundwater wells to serve the project. The project site is not located within a sustainable groundwater management area and is not part of a significant groundwater recharge area. Therefore, the project would not substantially deplete groundwater supplies. The project would increase the amount of impervious surfaces on the project site; however, 37% of the proposed development area will revegetated/landscaped. Additional areas on the project site will remain as open space, which will allow for infiltra tion. The project would not interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. No impact is identified for this issue area.
Threshold of Significance: In flood hazards, tsunami or seiche zones, risk release of pollutants due to project inundation.
Per the Federal Emergency Management Agency’s (FEMA’s) Flood Insurance Rate Map Number 06073C0793G the project site is not located within a 100-year flood hazard area (FEMA 2012). The project site is approximately 10 miles inland from the Pacific Ocean and would not be subject to inundation by tsunami. Given that the project site is not located near a large standing body of water, inundation by seiche (or standing wave) is considered negligible. No impact would occur.
A discussion of additional hydrology and water quality significance thresholds is provided in Section
3.7, Hydrology and Water Quality.
5.8 Land Use and Planning
Threshold of Significance: Physically divide an established community.
The project site is currently undeveloped. The project proposes residential uses in an area that is already developed with similar uses. The project would not physically divide an established community.
No impact is identified for this issue area.
A discussion of additional land use and planning significance thresholds is provided in Section 3.8, Land Use and Planning.
5.9 Mineral Resources
Threshold of Significance: Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.
According to the City of San Marcos General Plan Conservation & Open Space Element, the City contains land classified in all four Mineral Resource Zones (MRZ) (San Marcos 2012). California does
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not require that local governments protect land designated as MRZ-1, MRZ-3, or MRZ-4. However, the City is responsible for recognizing lands designated as MRZ -2 and protecting these areas from premature development incompatible with mining. The lands designated as MRZ- 2 include small portions between Double Peak, Mount Whitney, and Franks Peak; and small portions in the northern Sphere of Influence within Twin Oaks Valley Neighborhoo d. These locations do not overlap with the project site; therefore, no loss of known mineral resources would occur. No impact is identified.
Threshold of Significance: Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan The project site is not designated as a locally important mineral resource recovery site on any local general plan, specific plan, or other land use plan (City of San Marcos 2012). Due to the location and the nature of the proposed project, there would be no impact on mineral resources.
5.10 Noise
Threshold of Significance: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
The proposed project is not located within the vicinity of a private airstrip. The public airport closest to the project site is the McClellan -Palomar Airport, located approximately 6.5 miles to the southwest.
According to the ALUCP for the McClellan -Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, people residing or working in the project area would not be exposed to substant ial airport noise.
A discussion of additional noise significance thresholds is provided in Section 3.9, Noise.
5.11 Population and Housing
Threshold of Significance: Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The project site has a General Plan Designation of SPA and is associated with the Heart of the City Specific Plan (HOCSP). The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Missio n Road corridor, including the project site, have a sub-plan designation of Richmar Specific Plan. Prior to the site’s inclusion under the Richmar sub-plan, the underlying designation for the property was Single-Family Detached 2 to 4 du/ac per the HOCSP.
Development criteria for the Richmar Specific Plan has not been adopted by the City; therefore, properties requesting development within this sub -plan area are required to establish individual specific plans. As such, there is no fixed land use or density currently assigned to the project site. The General Plan identifies commercial, office and multifamily residential as land use options within the Richmar Specific Plan Area. Due to its location and the adjacent residential land uses, a multifamily residential development, under a Specific Plan, is the most suitable land use for the subject property.
City policy requires that a secondary access be provided if more than 50 units are proposed. Given the
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topographical constraints and the lack of availability of a secondary/emergency vehicle access point, a maximum of 50 multifamily residential units could be built on the site. This would result in a density of 5.9 du/acre. The project site would not be suitable for commercial or office development given the site topography and adjacent uses. The Specific Plan allows for a density of 5.7 du/acre and the project is proposing 5.4 du/acre. Therefore, the project’s development intensity and density would be slightly less than what is identified in the current General Plan and the project would not result in substantial unplanned population growth in an area, directly or indirectly and no impact is identified.
Threshold of Significance: Displace substantial numbers of existing housing or people, necessitating the construction of replacement housing elsewhere.
There is no existing housing on the project site. Therefore, the project would not remove existing housing. The project proposes 46 multifamily units which would add to the housing stock in the City.
No impact is identified for this issue area.
5.12 Recreation
Threshold of Significance: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration of the facility would occur or be accelerated?
Threshold of Significance: Does the project include any recreational facilities or require the construction or expansion of recreation facilities which might have an adverse physical effect on the environment?
The project proposes residential uses which can result in an increase in demand for neighborhood and regional parks. The project proposes common open space area s, including a tot lot, turf play areas and a sensory garden. These features would be included within the development footprint of the project. This provides an opportunity for residents to recreate on site. Additionally, the project will pay Public Facility Fees (PFF), a portion of which goes toward funding a c ity-wide park and recreation facilities and would offset the future residents demand for such facilities . Since the project provides on-site recreational amenities and will pay PFF, impacts would be less than significant.
5.13 Wildfire
Threshold of Significance: A significant wildfire would be identified if the project was located in or near a state responsibility area or lands classified as very high fire hazard severity zone and would:
• Substantially impair an adopted emergency response plan or emergency evacuation plan; • Due to slope, prevailing wind, and other factors exacerbate wildlife risk, and thereby, expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire;
• Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or • Expose people or structure to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability or drainage changes.
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The project site is located in a Local Responsibility Area, not a State Responsibility area (CAL FIRE 2022). The project site is in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per California Department of Forestry and Fire Protection (CAL FIRE) San Marcos Fire Hazards Severity Zones Map (2009) and is surroun ded by areas identified as Non - VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. It should be noted there are two easements on the site associated with vegetation management for fire fuel reduction. One is located along a portion of the site’s eastern boundary and the other is located along a portion of the site’s southern boundary.
These are associated with fire buffer maintenance requirements of adjacent development. The project will also implement a zoned brush management plan which will provide a minimum of 150 feet of clearance. The brush management plan will follow CAL FIRE’s guidance for defensible space (CAL FIRE 2023) which includes three zones of defensible space. No impact is identified for this issue area.
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6.0 Other CEQA Considerations
6.1 Significant and Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines, Section 15126.2(b), requires that an Environmental Impact Report (EIR) describe any significant impacts that cannot be avoided, including those impacts that can be mitigated but not reduced to a less -than-significant level. Chapter 3, Environmental Analysis, of this EIR describes the potential environmental impacts of the proposed project and recommends mitigation measures to reduce impacts, where feasible. Based upon the analysis in Sections 3.1 through 3.13 of this EIR, the proposed project would not have any significant and unavoidable impacts. All impacts would be mitigated to below a level of significance through the incorporation of mitigation measures. These mitigation measures would be identifie d in a Mitigation Monitoring and Reporting Program that will be adopted as part of the project and also be made a condition of approval of the project.
6.2 Growth Inducement
Section 15126.2(e) of the CEQA Guidelines mandates that the growth inducing nature of a proposed project be discussed. This CEQA Guideline states the growth-inducing analysis is intended to address the potential for the proposed project to “foster economic or population growth, or the construction of additional housing, either dir ectly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) also mandates that a CEQA document speak to the proposed project’s likelihood to induce substantial population growth in an area, either d irectly (e.g., by proposing new homes or businesses) or indirectly (e.g., through extension of roads or other infrastructure).
A project may be distinguished as either facilitating planned growth or inducing unplanned growth.
Facilitating growth is related to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing grow th is related to lowering or removing barriers to growth or by creating an amenity or facility that attracts new population/economic activity.
For purposes of this EIR analysis, a significant growth inducement impact would occur if the proposed project, and associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burden existing community services, the environment or cause a demand for General Plan Amendments. This section contains a discussion of the growth inducing factors related to the proposed project and as defined under CEQA Guidelines, Section 15126.2(e). A project is defined as growth inducing when it directly or indirectly:
• Fosters population growth;
• Includes the construction of additional housing in the surrounding environment; • Removes obstacles to population growth;
• Taxes existing community service facilities, requiring construction of new facilities that could cause significant environmental effects; and/or
• Encourages or facilitates other activities that could significantly affect the environments, either individually or cumulatively.
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It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
As discussed in Section 5.12, Population and Housing, the project site has a General Plan Designation of SPA and is associated with the Heart of the City Specific Plan (HOCSP). The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Mission Road corridor, including the project site, have a sub-plan designation of Richmar Specific Plan. Prior to the site’s inclusion under the Richmar sub -plan, the underlying designation for the property was Single-Family Detached 2 to 4 du/ac per the HOCSP.
Development criteria for the Richmar Specific Plan has not been adopted by the City; therefore, properties requesting development within this sub -plan area are required to establish individual specific plans. As such, there is no fixed land use or density currently assigned to the project site. The General Plan identifies commercial, office and multifamily residential as land use options within the Richmar Specific Plan Area. Due to its location and the adjacent residential land uses, a multifamily residential development, under a Specific Plan, is the most suitable land use for the subject property.
City policy requires that a secondary access be provided if more than 50 units are proposed. Given the topographical constraints and the lack of availability of a secondary/emergency vehicle access point, a maximum of 50 multifamily residential units could be built on the site. This would result in a density of 5.9 du/acre. The project site would not be suitable for commercial or office development given the site topography and adjacent uses . The proposed project has a proposed density of 5.7 du/acre.
Therefore, the project’s development intensity and density would be slightly less than what is identified in the current General Plan , and the project would not result in substantial unplanned population growth in an area, directly or indirectly and no impact is identified.
As detailed in Section 3.13, Utilities and Service Systems, the proposed project would extend the existing 8 -inch gravity sewer main located north of the project site in Woodward Street for approximately 490 feet. This extension is only intended to serve the proposed project.
Additionally, the majority of the surrounding area is developed. The SANDAG population growth forecasts rely, in part, on individual jurisdiction’s planning documents, such as the City’s General Plan.
The City has a population rate of 3.1 persons per dwelling unit. Therefore the project would result in the addition of approximately 143 people. Because the project proposes a General Plan Amendment the estimated population of 143 people would not have been accounted for in SANDAG’s projections.
Therefore, the project’s induced population would exceed these projections. However, determination of impacts related to population growth are based upon whether the induced growth would be considered substantial.
The City’s population is projected to grow from 94,258 people in 2016 to 104,365 people by 2035 (an increase of 10,107 people) (SANDAG 2022). The population increase of 143 people would account for 1.4% of SANDAG’s projected population growth.
There is no hardline number or percentage available to determine whether or not this estimated introduction of 143 people (1.4 % of projected growth) could be considered a substantial increase in population. However, SANDAG’s 2050 Regional Growth Forecast is intended to be used as a starting point for regional planning as opposed to a prescribed growth pattern. Although the City determined that there are adequate sites available with appropriate designations/zoning to accommodate the remaining Regional Housing Needs Allocation (RHNA) for the current Housing Element planning period, the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with approved/constructed residential development (City of San
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Marcos 2021). Therefore, while the proposed project would directly induce growth beyond current estimates and forecasts, it would not be considered substantially growth inducing. Impacts would be less than significant.
6.3 Significant Irreversible Environmental Changes
CEQA Guidelines, Section 15126.2(d), requires that an EIR discuss any significant irreversible environmental changes which would be caused by the proposed project should it be implemented. Per this guideline “Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses.
Also irreversible damage can result from environmental accidents associated with the project.
Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.”
Approval of the project would involve the development of 46 duplex residential units and associated infrastructure improvements.. Con struction and/or operation of the proposed project would require the use of resources that include, but are not limited to, soils, gravel, concrete, and asphalt, lumber and other related forest products, petrochemical construction materials, steel, copper, and other metals, water, fuels, and energy. As such, the proposed project would result in the short-term and long- term use of fossil fuels and other nonrenewable resources. The grading proposed by the project would modify the undeveloped slopes permanently. These are irreversible environmental changes that would be realized with implementation of the proposed project.
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7.0 References
Summary
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
Project Description (Section 2.0)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
California Department of Forestry and Fire Protection (CAL FIRE). 2023. Defensible Space. https://www.fire.ca.gov/dspace Viewed January 30, 2024.
GeoTek. 2019. Preliminary Geotechnical Investigation – Proposed Residential Development APN 220- 210-49-00, Northeast of Woodward & Mission, San Marcos, California. May 16.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
Aesthetics (Section 3.1)
City of San Marcos. 2023a. Zoning Ordinance, Section 20.300.080- Light and Glare Standards.
Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library. municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.300SIPLGEDES T_S20.300.080LIGLST Viewed February 7, 2024.
City of San Marcos. 2023b. Zoning Ordinance, Section 20.260 -Ridgeline Protection & Management Overlay Zone. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 260RIPRMAOVZO Viewed February 7, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
United States Census Bureau (USCB). 2023. Quick Facts Escondido City, San Marcos City, California, United States. https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia,sanmarcos %20citycalifornia,US/PST045219 Viewed November 21, 2023.
Air Quality (Section 3.2)
California Air Resources Board (CARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October . https://ww2.arb.ca.gov //sites/default/files/classic/diesel/documents/rrpfinal.pdf Viewed February 7, 2024.
California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. https://www.aqmd.gov/docs/default -source/ceqa/handbook/california-air- resources-board-air-quality-and-land-use-handbook-a-community-health-perspective.pdf Viewed February 7, 2024.
California Air Resources Board (CARB). 2016. Ambient Air Quality Standards. May 4. http://www.arb.ca.gov/research/aaqs/aaqs2.pdf Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-2
LDN Consulting (LDN). 2025. Air Quality Assessment, Woodward 46 Specific Plan SP22 -005, SP22- 0006, GPA22-0004, MFSD22-0005, TSM22-0004, City of San Marcos, CA. January 7.
Linscott Law & Greenspan (LLG). 2023. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
San Diego Air Pollution Control District ( SDAPCD). 1976. Regulation IV; Rule 51: Public Nuisance. https://www.sdapcd.org/content/sdapcd/rules.html Viewed October 9, 2023.
San Diego Air Pollution Control District ( SDAPCD). 2019. Rule 20.2: New Source Review Non- Major Stationary Sources. https://www.sdapcd.org/content/sdapcd/rules.html Viewed February 7, 2024.
San Diego Air Pollution Control District (SDAPCD). 2020. 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County. October. https://ww2.arb.ca.gov/our- work/programs/california-state-implementation-plans/nonattainment-area-plans/san-diego-county-0 Viewed February 7, 2024.
San Diego Air Pollution Control District ( SDAPCD). 2021. Regulation XII; Rule 1210: Toxic Air Contaminant Health Risks - Public Notification and Risk Reduction. https://www.sdapcd .org/content/sdapcd/rules.html Viewed February 7, 2024.
San Diego Air Pollution Control District (SDAPCD). 2023. Attainment Status. https://www.sdapcd .org/content/sdapcd/planning/attainment-status.html Viewed February 7, 2024.
Biological Resources (Section 3.3)
Alden Environmental. 2024. 2024 Survey Report for Foraging Crotch’s Bumble Bee (Bombus crotchii) on the Woodward Specific Plan Development Project. August 15.
AMEC Earth & Environmental, Inc. (AMEC). 2003 . Volume II Final MHCP Plan Biological Analysis and Permitting Conditions. March. https://www.sandag.org/-/media/SANDAG/Documents/PDF/projects- and-programs/environment/regional-habitat-conservation/volume-2-final-multiple-habitat- conservation-program-plan-biological-analysis-permitting-2003-03-01.pdf Viewed February 7, 2024.
California Department of Fish and Wildlife (CDFW). 2023. Survey Considerations for California Endangered Species Act (CESA) Candidate Bumble Bee Species. June 6. https://nrm .dfg.ca.gov/FileHandler.ashx?DocumentID=213150&inline Viewed February 11, 2024.
KMEA. 2018. Coastal California Gnatcatcher (Polioptila californica californica) Protocol Survey Results for the Mission 316 Project, San Marcos, California. November 29.
KMEA. 2020. 2020 Coastal California Gnatcatcher (Polioptila californica californica) Pre-Construction Survey Results for the Mission 316 Project, San Marcos, California. October 9.
Oberbauer, Thomas, Meghan Kelly, and Jeremy Buegge (Oberbauer, et.al). 2008. Draft Vegetation Communities of San Diego County. March Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California.” Robert F. Holland, Ph.D., October 1986 . https://www.sand iegocounty.gov/content/dam/sdc/pds/ceqa/Soitec-Documents/Final-EIR-Files/references/rtcref /ch9.0/rtcrefaletters/O14%202014-12-19_OberbauerTM2008.pdf Viewed January 30, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-3
Rincon Consultants (Rincon). 2024. Focused Rare Plant Survey Report for Woodward Specific Plan Development Project. February 7.
Rincon Consultants (Rincon). 2023. Coastal California Gnatcatcher Protocol Survey Report for Woodward Specific Plan Development Project. October 4.
San Diego Association of Governments (SANDAG). 2003. Final MHCP Plan – Volume 1. https://www. sandag.org/-/media/SANDAG/Documents/PDF/projects-and-programs/environment/regional- habitat-conservation/volume-1-final-multiple-habitat-conservation-program-plan-2003-03-01.pdf Viewed February 7, 2024.
Sawyer, J. O., T. Keeler-Wolf, and J.M. Evens (Sawyer et.al). 2009. A Manual of California Vegetation, Second Edition. California Native Plant Society, Sacramento, California.
Xerces Society for Invertebrate Conservation, 2023. At Risk Bumble Bees, Crotch’s Bumble Bee. https://xerces.org/endangered-species/species-profiles/bumble-bees/crotchs-bumble-bee Viewed October 19, 2023.
Cultural Resources (Section 3.4)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
City of San Marcos. 2023. Archaeological and Historical Resources Consultant Guidelines. January. https://www.san-marcos.net/home/showpublisheddocument/27022/638090369405800000 Viewed February 7, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
Energy (Section 3.5)
California Air Resources Board (CARB). 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf. Viewed February 7, 2024.
California Air Resources Board (CARB). 2022b. EMFAC2021 v1.0.1. https://arb.ca.gov/emfac/ Accessed 2022.
California Air Resources Board (CARB). 2023. Advanced Clean Cars II. https://ww2.arb.ca.gov/our- work/programs/advanced-clean-cars-program/advanced-clean-cars-ii Viewed February 7, 2024.
California Energy Commission (CEC). 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” March . https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_ Building_Standards_FAQ_ada.pdf Viewed February 7, 2024.
California Energy Commission (CEC). 2021. 2022 Building Energy Efficiency Standards Summary.
August. https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdate Summary_ADA.pdf Viewed February 7, 2024.
California Public Utility Commission (CPUC). 2021. Natural Gas and California. https://www.cpuc. ca.gov/natural_gas/ Viewed February 7, 2024.
Energy Information Administration, United States (EIA). 2023 a. California State Energy Profile. April
20. https://www.eia.gov/state/print.php?sid=CA Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-4
Energy Information Administration, United States (EIA). 2023b. State Electricity Profiles: Table 1. 2022 Summary Statistics (California). Released November 2 . https://www.eia.gov/electricity /state/california/index.php Viewed February 7, 2024.
LDN Consulting (LDN). 2023. Energy Usage Letter – Woodward 46 Specific Plan (SP22 -0005, SP22- 0006, GPA22-0004, MFSD22-0005, TSM22-0004). August 29.
San Diego Gas & Electric (SDG&E). 2022a. About Us. https://www.sdge.com/more-information/our- company/about-us Viewed February 7, 2024.
San Diego Gas & Electric (SDG&E). 2022b. The Path to Net Zero: A Decarbonization Roadmap for California. April. https://www.sdge.com/sites/default/files/documents/netzero2.pdf. Viewed February 7, 2024.
Geology and Soils (Section 3.6)
California Department of Conservation. 2023. EQ Zapp: California Earthquake Hazards Zone Application. April 4. https://maps.conservation.ca.gov/cgs/EQZApp/app/ Accessed September 21, 2023.
California Geological Survey. 2008. Special Publication 117A Guidelines for Evaluating and Mitigating Seismic Hazards in California. https://www.conservation.ca.gov/cgs/Documents /Publications/Special-Publications/SP_117a.pdf Viewed February 1, 2024.
City of San Marcos. 2012. City of San Marcos General Plan, Safety Element. Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument/8476/636573113845230000 Viewed February 7, 2024.
County of San Diego. 2009. Guidelines for Determining Significance for Paleontological Resources.
January 15 . https://www.sandiegocounty.gov/dplu/docs/Paleo-Guidelines.pdf Viewed February 7, 2024.
GeoTek. 2019. Preliminary Geotechnical Investigation – Proposed Residential Development APN 220- 210-49-00, Northeast of Woodward & Mission, San Marcos, California. May 16.
Hydrology/Water Quality (Section 3.7)
Carlsbad Watershed Management Area. 2022. Overview http://www.projectcleanwater.org/ watersheds/carlsbad-wma/#plan Viewed February 7, 2024..
City of San Marcos. 2017. City of San Marcos Jurisdictional Runoff Management Plan. January 26. https://www.san-marcos.net/home/showpublisheddocument?id=15523 Viewed February 7, 2024.
City of San Marcos 2023. BMP Design Manual for Permanent Site Design, Storm Water Treatments and Hydromodification Management. February. https://www.san-marcos.net/home/ showpublisheddocument/27192/638114580843700000 Viewed February 7, 2024.
Excel Engineering (Excel). 2022. Priority Development Project Stormwater Quality Management Plan Cornerstone Communities Woodward, Woodward Street, San Marcos, CA, September 22.
Excel Engineering (Excel). 2023. Priority Project Hydrology Study for Cornerstone Communities Cornerstone Communities Woodward, Woodward Street, San Marcos, CA, September 22.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-5
Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0793G. https://msc.fema.gov/portal/search Viewed October 16, 2023.
Regional Water Quality Control Board San Diego Region. 2015. Order No. R9 -2015-0100. An Order Amending Order No. R9-2013-001, NPDES No. CAS 010266, As Amended by Order No. R9-2015-001.
National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4s) Draining the Watersheds within the San Diego Region. https://www.waterboards.ca.gov/sandiego/board_decisions /adopted_orders/2015/R9-2015-0100.pdf Viewed February 7, 2024.
State Water Resources Control Board (SWRCB). 2022. California 2020 -2022 Integrated Report (303(d) List/305(b) Report). State Water Board Approval January 19. U.S . EPA Approval May 11. https://www.waterboards.ca.gov/water_issues/programs/water_quality_assessment/ Viewed February 7, 2024.
Land Use and Planning (Section 3.8)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
California Department of Forestry and Fire Protection (CAL FIRE). 2009.
Fire Hazard Severity Zones, San Marcos. https://osfm.fire.ca.gov/what -we-do/community-wildfire- preparedness-and-mitigation/fire-hazard-severity-zones Viewed February 7, 2024.
California Department of Resources Recycling and Recovery (CalRecycle). 202 2. Jurisdiction Diversion/ Disposal Rate Summary . https://www2.calrecycle.ca.gov/LGCentral /DiversionProgram/JurisdictionDiversionPost2006 Viewed February 7, 2024.
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November 16. https://www.san- marcos.net/home/showpublisheddocument?id=25036 Viewed February 7, 2024.
City of San Marcos. 2023. Zoning Ordinance, Section 22.250.020 – Specific Plan Area Zone. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library.municode.com/ca/ san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.250SPPLARZO Viewed February 7, 2024.
Linscott Law & Greenspan (LLG). 2023. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
San Diego Association of Governments (SANDAG). 2002. SANDAG (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region. April https://www.sandiego county.gov/content/dam/sdc/pds/ceqa/LehmanTPM/38%20Appendix%20T9_SANDAG%20Trip%20 Generation%20Rates.pdf Viewed February 2, 2024.
Noise (Section 3.9)
California Department of Transportation (Caltrans) 2020. Transportation and Construction Vibration Guidance Manual. April. https://dot.ca.gov/-/media/dot-media/programs/environmental- analysis/documents/env/tcvgm-apr2020-a11y.pdf Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-6
City of San Marcos. 2023. Zoning Ordinance, Section 20.300.0 70- Performance Standards. Adopted November 13, 2012, Last Supplemented November 20, 2023. https://library.municode. com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20.300SIPLGEDEST_S20.30
0.070PEST Viewed February 2, 2024.
Federal Transit Administration (FTA) 2018. Transit Noise and Vibration Impact Assessment Manual.
September. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/ transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf Viewed February 7, 2024.
Linscott Law & Greenspan (LLG). 2023. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
LDN Consulting (LDN). 2021. San Marcos Rock Crusher Noise.
LDN Consulting (LDN). 2025. Noise Assessment, Woodward 46 Specific Plan, SP22 -0005, SP22- 0006, GPA22-0004, MFSD22-0005, TSM22-0004, City of San Marcos, January 7.
Public Services (Section 3.10)
California Department of Forestry and Fire Protection (CAL FIRE). 2023. Defensible Space. https://www.fire.ca.gov/dspace Viewed February 7, 2024.
California State University San Marcos (CSUSM). 202 4. Borrowing Books and Media. https://biblio.csusm.edu/content/borrowing-policies-books-and-media Viewed February 7, 2024.
City of San Marcos. 2012a. City of San Marcos General Plan. Parks, Recreation and Community Health Element. Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument /8477/636573113841930000 Viewed February 7, 2024.
City of San Marcos. 2012b. San Marcos General Plan EIR. Adopted February 14.
City of San Marcos. 202 4. Fire Department Overview. https://www.san -marcos.net /departments/public-safety/fire-department/department-overview. Viewed February 7, 2024.
San Diego County Library. 202 4 About the Library. https://www.sdcl.org/about/ Viewed February 7, 2024.
San Diego County Sheriff’s Department (SDCSD). 2024 . San Marcos Station. https://www. sdsheriff.gov/Home/Components/FacilityDirectory/FacilityDirectory/40/ Viewed February 7, 2024.
San Marcos Unified School District (SMUSD). 2023a. SMUSD Fast Facts. https://www.smusd.org/ about_us/district_overview Viewed February 7, 2024.
San Marcos Unified School District (SMUSD). 2023b. Woodward 46 Specific Plan Project Letter from Tova K. Corman, Executive Director Facilities Planning & Development, SMUSD. November 7.
San Marcos Unified School District (SMUSD ) 2023c. Residential and Commercial Developer Fees. https://www.smusd.org/departments/facilities_planning_and_development/residential_and_comm ercial_developer_fee_summary Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-7
Transportation (Section 3.11)
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November https://www.san- marcos.net/home/showpublisheddocument?id=25036 Viewed February 7, 2024.
Linscott Law & Greenspan (LLG). 2023a. Local Transportation Analysis: Woodward 46 Apartment Project, San Marcos California. February 24, 2023.
Linscott Law & Greenspan (LLG). 2023b. Vehicle Miles Traveled Study: Woodward 46 Apartment Project, San Marcos California. March 13, 2023.
Tribal Cultural Resources (Section 3.12)
ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
City of San Marcos. 202 4. Archaeological and Historical Resources Consultant Guidelines. January. https://www.san-marcos.net/home/showpublisheddocument/27022/638090369405800000 Viewed October 10, 2024.
Utilities and Service Systems (Section 3.13)
California Department of Resources Recycling and Recovery (CalRecycle) . 2019a. SWIS Facility/Site Activity Details: Escondido Resource Recovery (37 -AA-0906). https://www2.calrecycle.ca.gov/Solid Waste/SiteActivity/Details/1830?siteID=2903 Viewed February 7, 2024.
California Department of Resources Recycling and Recovery (CalRecycle) . 2019b. Estimated Solid Waste Generation Rates. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates Viewed February 7, 2024.
California Department of Resources Recycling and Recovery ( CalRecycle). 2022. Jurisdiction Diversion/ Disposal Rate Summary . https://www2.calrecycle.ca.gov/LGCentral /DiversionProgram/JurisdictionDiversionPost2006 Viewed February 7, 2024.
City of San Marcos 2012. Land Use and Community Design Element, City of San Marcos General Plan. https://www.san-marcos.net/work/economic-development/general-plan Viewed February 7, 2024.
County of San Diego. 2005. Integrated Waste Management Plan Countywide Siting Element.
September. https://www.sandiegocounty.gov/content/dam/sdc/common_components/images/dpw /recyclingpdfs/2005_sitingelement.pdf Viewed February 7, 2024.
County of San Diego. 2022. Five-Year Review Report of the Countywide Integrated Waste Management Plan. https://www.sandiegocounty.gov/content/dam/sdc/dpw/SOLID_WASTE_PLANNING_and_ RECYCLING/Files/2022%20Five-Year%20Review.pdf Viewed February 7, 2024.
Metropolitan Water District of Southern California (MWD). 2021. 2020 Urban Water Management Plan (UWMP). June. https://www.mwdh2o.com/media/21641/2020-urban-water-management-plan-june- 2021.pdf Viewed February 7, 2024.
San Diego County Water Authority (SDCWA). 2021. 2020 Urban Water Management Plan (UWMP).
March. https://www.sdcwa.org/wp-content/uploads/2021/03/Draft-2020-UWMP.pdf Viewed February 7, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-8
Vallecitos Water District (VWD). 2018. 2018 Water, Wastewater and Recycled Water Master Plan.
October 4. https://www.vwd.org/home/showpublisheddocument/10656/636752049380230000 Viewed February 7, 2024.
Vallecitos Water District (VWD). 2023. Woodward 46 Water and Sewer Study, Work Order #269767, Final Technical Memorandum, prepared by Elizabeth Lopez and Eileen Koonce. April 6.
Alternatives (Section 4.0)
GeoTek. 2019. Preliminary Geotechnical Investigation – Proposed Residential Development APN 220- 210-49-00, Northeast of Woodward & Mission, San Marcos, California. May 16.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
SANDAG. 2023. San Diego Region SB743 VMT Maps. https://www.arcgis.com/apps/webappviewer /index.html?id=bb8f938b625c40cea14c825835519a2b Viewed November 21, 2023.
Vallecitos Water District (VWD). 2023. Woodward 46 Water and Sewer Study, Work Order #269767, Final Technical Memorandum, prepared by Elizabeth Lopez and Eileen Koonce. April 6.
Environmental Effects Found Not to be Significant (Section 5.0) ASM Affiliates (ASM). 2024. Archaeological Survey and Evaluation Report for the Woodward 46 Project, San Marcos, California. January.
California Department of Forestry and Fire Protection (CAL FIRE). 2009. Fire Hazard Severity Zones, San Marcos. https://osfm.fire.ca.gov/what -we-do/community-wildfire-preparedness-and-mitigation /fire-hazard-severity-zones Viewed February 7, 2024.
California Department of Forestry and Fire Protection (CAL FIRE). 2022. State Responsibility Area Fire Hazard Severity Zones. November 21. https://osfm.fire.ca.gov/media/dqfbrtl1 /fhsz_county_sra_11x17_2022_sandiego_ada.pdf Viewed February 7, 2024.
California Department of Forestry and Fire Protection (CAL FIRE). 2023. Defensible Space. https://www.fire.ca.gov/dspace Viewed February 7, 2024.
Caltrans. 2019. Designated and Eligible Scenic Highways Spreadsheet. https://dot.ca.gov/pro grams/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways Viewed February 2, 2024.
City of San Marcos. 2012. City of San Marcos General Plan , Conservation and Open Space Element and Safety Element. Adopted February 14. https://www.san-marcos.net/home /showpublisheddocument?id=8476 https://www.san-marcos.net/home/showpublisheddocument /8478/636597348039500000 Viewed September 28, 2023.
City of San Marcos. 2020. Final Climate Action Plan. December. https://www.san-marcos. net/home/showpublisheddocument/25084/637435406644270000 Viewed February 7, 2024.
Department of Toxic Substance Control (DTSC) 2023. EnviroStor D atabase. https://geotracker.waterboards.ca.gov/profile_report?global_id=T06019712665 Accessed May 16, 2023.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-9
Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0793G . https://msc.fema.gov/portal/search Viewed February 7, 2024.
Rincon Consultants (Rincon). 2025. Woodward Specific Plan Full Biological Resources Report. March.
San Diego Association of Governments (SANDAG). 2003. Final MHCP Plan – Volume 1. https://www. sandag.org/-/media/SANDAG/Documents/PDF/projects-and-programs/environment/regional- habitat-conservation/volume-1-final-multiple-habitat-conservation-program-plan-2003-03-01.pdf February 7, 2024.
San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan. Adopted January 25, 2010. Amended March 4, 2010, and December 1, 2011. http://www.san.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command=Core_Download &EntryId=2991&language=en-US&PortalId=0&TabId=225 Viewed February 9, 2024.
Vallecitos Water District (VWD). 2023. Woodward 46 Water and Sewer Study, Work Order #269767, Final Technical Memorandum. April 6.
Other CEQA Considerations (Section 6.0)
City of San Marcos. 2021. 2021-2029 Housing Element. July 31. https://www.san- marcos.net/home/showpublisheddocument/25740/637689416879030000 Viewed February 9, 2024.
San Diego Association of Governments (SANDAG). 2022. Series 14 Regional Growth Forecast Documentation and Baseline Subregional Allocation https://www.sandag.org/-/media/SANDAG /Documents/PDF/data-and-research/socioeconomics/estimates-and-forecasts/series-14-regional- growth-forecast-documentation-and-baseline-subregional-allocation.pdf Viewed February 9, 2024.
7.0 References
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 7-10
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Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page 8-1
8.0 List of Preparers
City of San Marcos (Lead Agency)
Scott Nightingale, Principal Planner
Norm Pedersen, Associate Planner
Bradley Holder, PE, CFM, Associate Civil Engineer – Land Development Kyrenne Chua, PE, MPA, Senior Civil Engineer
Environmental Impact Report
Sophia Mitchell & Associates, LLC
Sophia Habl Mitchell, LEED AP, Project Manager
Melyssa Sheeran, Senior Environmental Consultant
Air Quality, Energy, Greenhouse Gas, and Noise Reports
LDN Consulting
Jeremy Louden, Principal
Archeological Resources Inventory
ASM Affiliates
Holly Drake, RPA
Shelby Castells, RPA
Biological Resources Report, Rare Plant Surveys and CAGN Surveys Rincon Consultants
Jacob Hargis, Biologist
Jared Reed, Senior Biologist/Project Manager
Kelly Rios, Biologist (Coastal California Gnatcatcher Surveys) Casey Clark, Biologist (Rare Plant Surveys)
Jessica Quinn, Supervising Biologist/Project Manager
Angie Harbin, Director-Natural Resources
Isabelle Radis, GIS Specialist
Abby Robles, GIS Analyst
Biological Resources, Crotch’s Bumble Bee Survey
Alden Environmental
Brian Lohstroh, Principal Biologist
Geotechnical Investigation
GeoTek, Inc.
Christopher D. Livesey, P
Benjamin R. Grenis, RCE
Stormwater Quality Management Plan/Hydrology Report
Excel Engineering
Robert D. Dentino, RCE
Transportation Analysis
Linscott, Law & Greenspan Engineers
John Boarman, PE, Principal
Renald Espiritu, Transportation Engineer II
8.0 Preparers
Woodward Specific Plan Draft EIR March 2025
City of San Maros Page 8-2
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