EXHIBIT A.1 Findings of Fact & FEIR23-005 — San Marcos City Council, September 9, 2025 (part 1 of 3)

1 California Environmental Quality Act (CEQA) Findings Regarding Significant Effects for the Woodward 46 Specific Plan Project SCH #2023080449
SP22-0006, SP22-0005, GPA22-0004, MFSDP22-0005, TSM22-0004, CUP22-0005 ---------------------------------------------------------------------------------------------- The City of San Marcos has prepared an Environmental Impact Report (EIR) for the proposed Woodward 46 Specific Plan Project (Project) in compliance with the California Environmental Quality Act (CEQA; Public Resources Code Section 21000 et seq.) and the State CEQA Guidelines (14 California Code of Regulations Section 15000 et seq. as amended).

Final EIR Evaluation
The Final EIR evaluated potentially significant effects for the following environmental areas of potential concern: 1) Aesthetics ; 2) Air Quality; 3) Biological Resources; 4) Cultural Resources; 5) Energy; 6) Geology and Soils; 7) Hydrology and Water Quality; 8) Land Use and Planning ; 9) Noise; 10) Public Services; 11) Transportation; 12) Tribal Cultural Resources; and 13) Utilities and Service Systems. The issue areas of Agriculture/Forestry Resources , Greenhouse Gas Emissions, Hazards and Hazardous Materials, Mineral Resources, Recreation, and Wildfire were analyzed during the scoping process for the EIR and were determined to have no impact or less than significant impacts.

The Final EIR identified potentially significant environmental effects related to Biological Resources (nesting birds , sensitive species and sensitive habitat ); C ultural Resources (unknown cultural resources and human remains during project grading); Noise (rock drill and rock crushing noise during construction); and Tribal Cultural Resources (tribal cultural resources).

Public Resources Code Section 21081 and CEQA Guidelines Section 15091 require that the City of San Marcos, as lead agency for this Project , prepare written findings for any identified significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings under CEQA and the CEQA Guidelines are:
(
1) Ch
anges or alterations have been required in, or incorporated into, the project which mitigate, avoid or substantially lessen the significant effects on the environment. (2) S
uch changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (
3) S
pecific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the Final EIR.

A
fter consideration of an EIR, the lead agency may decide whether or how to approve or carry out the Project. Pursuant to Public Resources Code Section 21081(a)(1) and CEQA Guidelines Section 15091(a)(1) of the Guidelines, the City finds that for each of the significant effects identified in the Final EIR, changes or alterations (mitigation measures) have been required in, or incorporated into, the Project which will avoid or substantially lessen each of the significant environmental effects 2 identified in the Final EIR. The significant effects (impacts) and mitigation measures are stated fully in the Final EIR. The rationale for this finding for each impact is discussed below.

T
he official custodian of the documents and other materials that constitute the record of proceedings is:

C
ity of San Marcos Planning Division
1 Civic Center Drive
San Marcos, CA 92069
C
opies of all these documents, which constitute the record of proceedings upon which the City’s decision is based, are, and at all relevant times have been, available upon request at the offices of the City, the custodian for such documents.

Project Description
The applicant, Cornerstone Communities, is proposing to develop 46 duplex residential units, associated infrastructure and common and private open space on an approximately 8.57 gross acre site located on Woodward Road in the City of San Marcos.

The project applicant is requesting the following discretionary approvals from the City to allow for development of the proposed project:

Specific Plan Amendment (SP22-0006) – A Specific Plan Amendment to modify the Heart of the City Specific Plan to remove the current Richmar Sub-Plan designation on the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan..

Specific Plan (SP22-0005) – The Woodward 46 Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan.

General Plan Amendment (GPA22-0 004) – A General Plan Amendment to the Land Use Element for the purpose of amending land use maps and text related to changing the sub-plan designation of the subject property from Richmar Specific Plan to Woodward 46 Specific Plan.

Multi-Family Site Development Plan (MFSDP22-0 005) - Multi-Family Site Development Plan approval would be required to construct 46 multi-f amily residential units and address the details of the architectural style, building elevation, fencing, and landscaping, among other criteria, within the development.

Tentative Subdivision Map (TSM22-0 004) - Tentative Subdivision Map approval would be required for formation of residential condominium units, private driveways, and open space areas.

Conditional Use Permit (CUP22-0005) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.
3 Project Objectives

The City identified project objectives to develop a reasonable range of alternatives to analyze within the Final EIR. The objectives for the Project are:

• 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 greenhous e 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 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.

These objectives have been considered in preparing the findings discussed below.

4 Section 1. Findings Regarding Certification of Final EIR

Pursuant to CEQA and the Guidelines, the City Council of the City of San Marcos as the lead agency under CEQA is responsible for certification of the EIR and therefore makes the following findings:

1. The City Council has reviewed and considered the information in the Final EIR, which has been completed in compliance with CEQA;

2. The Final EIR reflects the City’s, as lead agency, independent judgment and analysis; and,

3. The City Council adopts the Mitigation Monitoring and Reporting Program ( Attachment A) to reduce or avoid the significant and mitigable impacts of the Project.

Section 2. Environmental Effects Found Not to be Significant

Through Project scoping and the environmental analysis conducted for and included within the Final EIR, it was determined that the Project would not result in a potential significant effect on the environment with respect to Aesthetics, Agriculture and Forestry Resources, Air Quality, Energy, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, Transportation, Utilities and Service Systems, and Wildfire. A summary of the reasons for this determination can be found in Sections 3.1, 3.2, 3.5, 3.6, 3.7, 3.8, 3.10, 3.11, 3.13, and 5.0 of the Final EIR. No further findings are required for these subject areas.

Section 3. Environmental Effects Mitigated to Below a Level of Significance

The following findings supported by substantial evidence in the record, including the Final EIR, and technical appendices, have been made for the significant environmental effects identified in the Final EIR related to Biological Resources, Cultural Resources, Noise and Tribal Cultural Resources.

3.1 Biological Resources

3.1.1 Biological Resources Impacts

The Project has the potential for: direct and indirect impacts to coastal California gnatcatcher (Impact BIO-1), direct and indirect impacts to Crotch’s bumble bee through vegetation removal and grading, (Impact BIO-2), direct and indirect impact to special-status wildlife species including orange-throated whiptail, coastal whiptail, Southern California rufous -crowned sparrow, Cooper’s hawk, and Bryant’s woodrat (Impact BIO-3), impacts to nesting birds and raptors protected under the Migratory Bird Treaty Act (Impact BIO -4), indirect impacts to sensitive species (Impact BIO -5) and impacts to sensitive vegetation communities including Diegan coastal sage scrub and Disturbed Diegan coastal sage scrub (Impact BIO-6).

3.1.2 Biological Resources Mitigation Measures

The Project includes mitigation measures in the Mitigation Monitoring and Reporting Program (MMRP) that is to be adopted concurrently with these findings.

All biological resource impacts and mitigation measures are detailed in Attachment A at the end of this document. Mitigation measures MM-BIO-1a and MM-BIO-1b will mitigate Impact BIO-1 to below a level of significance. Mitigation measure MM -BIO-2, MM-BIO-3a, MM-BIO-3c, and MM-BIO-6 will mitigate 5 Impact BIO-2 to below a level of significance. MM-BIO-3a, MM-BIO-3b, MM-BIO-3c, and MM-BIO-3d will mitigate Impact BIO-3 and Impact BIO-5 to below a level of significance. Mitigation measure MM-BIO- 4 will mitigate Impact BIO-4 to below a level of significance. Mitigation measure MM-BIO-6 will mitigate Impact BIO-6 to below a level of significance.

In order to mitigate direct and indirect impacts to coastal California gnatcatcher (Impact BIO -1), implementation of the following mitigation measures will be required:

MM-BIO-1a An updated presence/absence protocol survey of the project site and a 500 -foot buffer around the project site shall be conducted by a qualified biologist with a valid United States Fish and Wildlife Service 10(a)(1)(A) permit to further evaluate the coastal California gnatcatcher (CAGN) territories that could be affected by short term project construction activities, including vegetation clearance, and long term habitat loss and indirect impacts. In accordance with the USFWS survey protocol, a minimum of six breeding season surveys shall be conducted at least 1 week apart from March 15, through June 30, pending the anticipated construction timeline for the project. The results of the survey shall be submitted to the City and USFWS upon completion.

If CAGN is detected during the protocol survey, vegetation clearing shall only be conducted between September 1 and February 14, outside of the breeding season for CAGN. If vegetation clearing must start outside of those dates, then focused nesting surveys would be conducted prior to vegetation clearing for the project site and a 500-foot buffer zone. No more than 3 days prior to the clearing of vegetation, a qualified biologist shall conduct a pre-construction clearance survey for CAGN to confirm that the vegetation on -site is not occupied by the species. If nests are found, they would be avoided by establishing a 500 -foot non-disturbance buffer around the nest. Vegetation clearance may continue with regular biological monitoring if there is no indication o f disturbance to the nest(s). If the vegetation clearance is potentially disruptive to active nests a larger buffer may be implemented as determined by the qualified biologist. If CAGN are observed moving through the area during vegetation clearing activities, the project biologist may delay the removal of vegetation and/or grading until CAGN has left the area of their own volition.

If CAGN is found to be within the survey area (project site plus a 500 -foot buffer) during protocol or pre -construction surveys, the following avoidance and minimization measures shall be implemented.
a) To reduce potential noise impacts to nesting CAGN, a qualified biologist shall monitor noise levels with a noise monitoring device at an appropriate distance from the nest to determine if construction activity noise is above 60 dBA Leq, the standard level requested by the USFWS, or if noise levels above 60 dBA Leq have the potential to affect any CAGN nests.
b) If/when an active CAGN nest is identified, an acoustician shall monitor noise at the edge of construction as directed by the qualified biologist. If noise levels continue to exceed 60 dBA Leq, the acoustician shall consult with the qualified biologist and provide requirements for the construction contractor to make operational and barrier changes to reduce noise levels to 60 dBA Leq during the breeding season (February 15 through August 31). Noise monitoring shall 6 occur during operational changes and installation of barriers, as needed, to ensure their effectiveness. If the noise meets or exceeds the 60 dBA Leq threshold, or if the biologist determines that the activities in general are disturbing the nesting activi ties, the biologist shall have the authority to halt construction and shall consult with the USFWS to devise methods to reduce the noise and/or disturbance in the vicinity. This may include methods such as, but not limited to, turning off vehicle engines a nd other equipment whenever possible to reduce noise, installing a protective noise barrier between the nesting coastal CAGN and the activities, and working in other areas until the young have fledged.

All active nests will be reported within 24 hours to the USFWS upon detection.

MM-BIO-1b Long-Term Open Space Management: A long-term open space management plan shall be developed to minimize impacts of the residential development on the adjacent coastal California gnatcatcher (CAGN) and Diegan Coastal Sage scrub habitat. The adjacent area falls within a Multiple Habitat Conservation Program Hardline Reserve, occupied by CAGN, and additional mitigation measures are necessary to minimize impacts associated with increased human and domestic pet presence from the project. The plan shall include a program of education to reduce domestic and feral cat encroachment (using the program developed by the American Society for the Prevention of Cruelty to Animals). Use of invasive exotic plant species in landscaped areas adjacent to or near sensitive vegetation communities shall be restricted. The applicant shall encourage the use of native species in the landscaping plan and shall avoid the use of species listed in Lists A & B of the California Invasive Plant Council's list of Exotic Pest Plants of Greatest Ecological Concern in California as of October 1999. This list includes such species as pepper trees (Schinus mole), pampas grass (Cortaderia selloana), fountain grass, ice plant (Carpobrotus sp.), myoporum (myoporum sp.), black locust (Robinia pseudoacacia), capeweed (Arctotheca calendula), tree of heaven (Ailanthus altissima), periwinkle Vinca major), sweet alyssum (Lobularia maritima), English ivy (Hedera helix), French broom (Genista monspessulana), Scotch broom (Cytisus scoparius), and Spanish broom (Spartium junceum). The plan shall also address permanent residential lighting to be directed away from the open space.

In order to mitigate potential direct and indirect impacts to Crotch’s bumble bee through vegetation removal and grading (Impact BIO -2), implementation of the following mitigation measure will be required:

MM-BIO-2 Focused surveys found the Diegan Coastal Sage Scrub on site to be occupied by Crotch’s bumble bee (CBB). Thus, there is potential for take of CBB and adverse impacts may occur through the removal of occupied habitat. However, the project would incorporate the following CBB avoidance, minimization and mitigation measures to reduce significant impacts to below a level of significance. should the species remain a candidate for state listing . If the State ultimately does not list 7 Crotch’s bumble bee under the California Endangered Species Act and the species is removed from candidate status, the mitigation measures outlined below would no longer be applicable.

Avoidance, Minimization, and Mitigation Measure for Crotch’s Bumble Bee Prior to the Notice to Proceed (NTP) for any construction permits, including but not limited to, the first Grading Permit, The City shall verify the following project requirements regarding the CBB are shown on the construction plans. Should this species no longer be a potential candidate for listing at the time of the preconstruction meeting, then no avoidance measures shall be required.

Incidental Take Permit:

Crotch’s bumble bee has been detected onsite, and all suitable habitat is considered occupied. As avoidance of impacts is not feasible, the Project applicant shall consult with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Ga me Code, § 2080 et seq.). If an Incidental Take Permit is issued, the Project applicant shall comply with the mitigation measures detailed in the take authorization issued by CDFW. In addition, the terms and conditions of that permit shall supersede any conflicting measures contained in this document.

The Project applicant shall provide a copy of a fully executed take authorization prior to the issuance of a grading permit and before any ground disturbance and vegetation removal. Should the State decline to list the species under the California Endangered Species Act and remove its candidate status, this measure shall no longer be applicable, and an Incidental Take Permit will not be required.

Pre-activity surveys:

To avoid direct impacts on CBB , removal of habitat (i.e., defined as any habitat disturbance) must occur outside of the Colony Active Period (generally occurring between February 1 through August 31). If the removal of habitat must occur during the Colony Active Period, a Qualified Biologist shall conduct a pre -activity survey no more than three days prior to the initiation of construction activities to determine the presence or absence of CBB within the proposed area of disturbance following CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023) or the latest guidance from CDFW no more than 10 days and no less than 3 days prior.

A Qualified Biologist must meet the qualifications discussed in the CDFW guidance (i.e., Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species, dated June 6, 2023). Resumes shall be provided to CDFW for review.

The pre -activity survey shall consist of non-lethal photo vouchers following California Department of Fish and Wildlife (CDFW) guidance (CDFW 2023). he surveys shall consist of passive methods unless a Memorandum of Understanding is obtained. The Qualified Biologist shall send all photographic vouchers to a CDFW approved taxonomist to confirm the identifications of the bumble bees encountered during surveys. If candidate bumble bees will be captured or handled during surveys, then the Qualified Biologist shall obtain the required authorization 8 via a Memorandum of Understanding or Scientific Collecting Permit pursuant to CDFW guidance (CDFW 2023).

If pre-activity surveys identify CBB individuals on-site, the Qualified Biologist shall notify and consult with CDFW to establish, monitor, and maintain no-work buffers around the associated floral/nest resources or identified nesting locations . The size and configuration of the no-work buffer shall be based on the best professional judgment of the Qualified Biologist in consultation with CDFW. Construction activities shall not occur within the no-work buffers until the bees appear are no longer active (i.e., associated floral resources appear desiccated and no bees are seen flying for three consecutive days indicating dispersal from the area). Take of any endangered, threatened, candidate species that results from the project is prohibited, except as authori zed by State law (Fish and Game Code section 86, 2062, 2067, 2068, 2080, 2085; California Code Regulations, Title 14, section 786.9) under CESA.

Survey data shall be submitted by the Qualified Biologist to the California Natural Diversity Database (CNDDB) in accordance with the Memorandum of Understanding with CDFW, or Scientific Collecting Permit requirements, as applicable.

Specifically, the Diegan coastal sage scrub mitigation shall include habitat compensation at a minimum 1:1 ratio or as negotiated through consultation with the CDFW for an Incidental Take P ermit, to also benefit the CBB. This mitigation may be satisfied through off-site acquisition, in lieu fees, purchase of credits from an approved mitigation bank, or a combination thereof. If necessary, habitat enhancement or restoration also may be incorporated, to be described in a Habitat Management and Monitoring Plan (i.e. planting of native Diegan coastal sage scrub flowering plant species known to support bumble bee populations, removal of invasive species, etc.). If prepared, the HMMP or other plans for Crotch’s bumble bee habitat enhancement or restoration will be provided to CDFW for review and approval. Any land acquired as off -site mitigation to benefit CBB shall include a cost estimate for long -term management, an endowment, and a land protectio n mechanism such as a conservation easement. Mitigation lands for CBB must be occupied or include high quality suitable habitat. This species shall also be included in the Worker Environmental Awareness Program educational program described in MM-BIO-3a and BMP’s implemented per MM-BIO-3c.

In order to mitigate potential direct and indirect impacts to special -status wildlife species including orange-throated whiptail, coastal whiptail, Southern California rufous -crowned sparrow, Cooper’s hawk, and Bryant’s woodrat (Impact BIO -3 and Impact BIO -5), implementation of the following mitigation measures will be required:
9 MM-BIO-3a Worker Environmental Awareness Program (WEAP): The applicant shall implement a Worker Environmental Awareness Program (WEAP) for the construction crew that will be developed by a qualified biologist. Each employee (including temporary, contractors, and subcontractors) will receive the WEAP presentation on the first day of project work. They will be advised of sensitive species in the area and avoidance measures being implemented to protect them at the site. At a minimum, the WEAP will include the following topics: occurrence of the listed and sensitive species in the area, their general ecology, sensitivity of the species to human activities, legal protection afforded these species, penalties for violations of federal and State laws, reporting requ irements, and project features and conditions designed to reduce direct and indirect impacts to these species, role of the Biological Monitor, and worker responsibilities to maintain compliance with mitigation measures while working at the site.

MM-BIO-3b Work Limit Delineations: Approved construction work area limits shall be delineated and marked clearly, by flagging or temporary orange construction fencing, in the field prior to vegetation removal. The marked boundaries shall be maintained and clearly visible to personnel on foot and by heavy equipment operators. Fencing shall be placed on the impact side of the work area to reduce the potential for encroachment and additional vegetation loss within adjacent open space. Fencing shall be put in p lace by a qualified surveyor per the project applicant’s approved construction and grading plans. All temporary fencing shall be removed only after the conclusion of all grading, clearing, and construction.

Employees shall strictly limit their activities and vehicles to the designated project areas, staging areas, and routes of travel. The biological monitor shall verify that the limits of construction have been properly staked and are readily identifiable.

Intrusion by unauthorized vehicles outside of cons truction limits shall be prohibited, with control exercised by an on -site foreman. Access routes to the construction area outside of work hours shall be blocked with physical barriers, such as concrete blocks or large equipment.

MM-BIO-3c Biological Monitor and Construction BMPs: A City of San Marcos -approved, qualified biologist shall be present during all vegetation clearing and other activities with the potential to affect coastal California gnatcatcher (CAGN), orange throated whiptails, coastal whiptails, Bryant’s woodrat, Coop ers hawks, and southern rufus-crowned sparrow, nesting birds, and any other sensitive plant or wildlife resource, and will monitor the project for avoidance of unanticipated impacts to the aforementioned species and their habitats. Standard construction Best Management Practices will be implemented by the contractor to minimize potential impacts to sensitive species. The biologist shall have the authority to halt all associated project activities that may be in violation of the protective measures.

Daily monitoring logs shall be maintained and a monthly report of compliance with biological resource measures will be provided to the City during construction.

Standard Construction Best Management Practices shall include the following:

 Vehicle speeds will not exceed 10 miles per hour (mph) adjacent to CAGN habitat. Clear signage will be installed and maintained throughout the construction period.
10  Placement of drip pans under parked equipment and vehicles.  Regular inspection and maintenance of equipment to avoid spills and immediate containment of any spills.
 Chemicals and pesticides will not be used.
 Pets and firearms will not be allowed at the site.
 Trash will be removed from the site daily or be stored in wildlife proof containers
 Stormwater protection (i.e., straw waddles, silt fence) will be employed to prevent spills, runoff, or sediment from entering nearby aquatic habitats.

These materials will be weed free and no project debris or rubbish will be allowed to enter into or be placed where it may be washed by rainfall or runoff in the wetlands.
 Staging/storage areas for equipment and materials will be located at least 100 feet away from the riparian areas. Equipment will be checked and maintained daily to prevent leaks of pollutants into the wetlands.  No equipment maintenance will be carried out within 100 feet of the riparian area.
 All pipes, culverts, or similar structures with a 4 -inch diameter or greater that are stored on the construction site overnight shall be thoroughly inspected for wildlife or nesting birds before the pipe is subsequently curried, capped, or otherwise used or moved in any way.
 To prevent inadvertent entrapment of wildlife during construction, all excavated, wells, steep-walled holes, or trenches more than 2 feet deep shall be covered with plywood or similar materials at the close of each working day.  Any construction lighting will be directed toward the work area and away from adjacent habitats.

MM-BIO-3d Woodrat Middens: Woodrat middens (nests) are large nests or dens made of woody debris, such as sticks, dead cacti, and bark. Middens were observed throughout the project site and within the project impact area. The project may contain both big-eared woodrat Bryant’s woodra t and all middens will be treated as potentially sensitive. Within 30 days of initial site disturbance, a pre - construction survey shall be conducted for woodrat middens. All occupied woodrat middens shall be mapped and flagged for avoidance to the extent feasible, with a minimum of 10- feet surrounding the active midden. If avoidance is not feasible, middens will be disturbed “daylighted” by a qualified biologist one night before anticipated vegetation removal to allow for the rats to escape and passively relocate prior to disturbance of the area.

In order to mitigate potential impacts to nesting birds and raptors protected under the Migratory Bird Treaty Act (Impact BIO-4), implementation of the following mitigation measure will be required:

MM-BIO-4 If site clearing activities are conducted between January 1 and August 31, a qualified biologist shall conduct a nesting bird survey no more than 3 days prior to the start of such activities to identify actively nesting birds within the project site and a 500-foot buffer around the project site. If any nests are found, their locations shall be flagged and an appropriate avoidance buffer, ranging in size from 25 to 50 feet for passerines, and up to 500 feet for raptors depending upon the species and the proposed work activity. The non -disturbance buffer zone shall be determined and demarcated by a qualified biologist with bright orange 11 construction fencing or other suitable flagging materials. Active nests shall be monitored at a minimum of once per week until it has been determined that the nest is no longer being used by either the young or adults. No disturbance shall occur within this buffer until the qualified biologist confirms that breeding/nesting is completed, and all the young have fledged. If project activities must occur within the buffer, activities shall be conducted at the discretion of the qualified biologist and with monitoring and management to confirm that nesting birds and the nests are not disturbed. If no nesting birds are observed during the nesting survey or during other monitoring activities, then no further actions shall be necessary. A follow-up survey will be ne eded if site clearing does not occur within 3 days after the initial survey and/or a pause in construction activity occurs for more than 7 days.

In order to mitigate indirect impacts to sensitive species (Impact BIO -5), implementation of aforementioned mitigation measures MM-BIO-3a through MM-BIO-3d will be required.

In order to mitigate potential impacts to sensitive vegetation communities including Diegan coastal sage scrub and Disturbed Diegan coastal sage scrub (Impact BIO-6), implementation of the following mitigation measure will be required:

MM-BIO-6 The permanent loss of 5.5 acres of Diegan Coastal Sage Scrub, and Disturbed Diegan Coastal Sage Scrub shall be mitigated at a minimum 1:1 ratio. Section

5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on -site mitigation, off -site acquisition, in -lieu fees, or mitigation credits. For mitigation purposes, the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub acreages on the project site that would be impacted have been combined as these two vegetation communities are considered to have similar se nsitivity under the Multiple Habitat Conservation Program. Thus, 5.5 acres of occupied coastal California gnatcatcher Diegan Coastal Sage Scrub will be preserved by the project applicant through off -site acquisition, in lieu fees, a purchase of credits fro m Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City of San Marcos Planning Manager and the Wildlife Agencies prior to issuance of the grading permit.

If on site or off-site habitat mitigation will be completed by the Applicant to satisfy the compensatory mitigation requirements, it shall be carried out in accordance with a Habitat Mitigation and Monitoring Plan (HMMP) that outlines the strategy for enhancement and maintenance of the habitat for locally sensitive species occupying Diegan Coastal Sage Scrub. The HMMP will be provided to the Wildlife Agencies for review and approval. Any land acquired as off-site mitigation to benefit gnatcatcher shall include a cost estimate for long -term maintenance, and endowment, a land protection mechanism such as a conse rvation easement.

Mitigation lands for gnatcatcher must be occupied or include high quality suitable habitat.

3.1.3 Finding

12 Changes or alterations have been required in, or incorporated into, the Project as mitigation measures MM-BIO-1a through MM-BIO-6, which are feasible, and would mitigate, avoid or substantially lessen the significant environmental effects as identified in the Final EIR to coastal California gnatcatcher, Crotch’s bumble bee, other special status wildlife species, nesting birds and sensitive habitats . (Impacts BIO-1, BIO-2, BIO-3, BIO-4, BIO-5, and BIO-6).

3.1.4 Facts in Support of Finding

Implementation of mitigation measures MM -BIO-1 through MM -BIO-6 would reduce potential direct and indirect impacts to sensitive wildlife species to below a level of significance. These measures require pre-construction surveys during the applicable nesting seasons and other measures to ensure that there are no direct impacts to California gnatcatcher, Bryant’s woodrat, other sensitive species, and nesting birds.

The proposed project would also impact 5.5 acres of Diegan coastal sage scrub habitat. The project would mitigate the impact at a 1:1 ratio, as identified in mitigation measure MM-BIO-6. Per mitigation measure MM-BIO-6, 5.5 acres of CAGN -occupied Diegan Co astal Sage Scrub and disturbed Diegan coastal sage scrub would be preserved by the project applicant through off -site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination th ereof as approved by the City’s Planning Manager and wildlife agencies prior to issuance of the grading permit. In addition, MM-BIO-2 includes consultation with CDFW, potentially an Incidental Take Permit, and requires that the habitat compensation for Die gan Coastal Sage Scrub includes enhancements to benefit Crotch’s bumble bee . The Diegan Coastal Sage Scrub mitigation identified under MM-BIO-6 would also serve as the habitat mitigation for Crotch’s bumble bee.

With the incorporation of the above mitigation measures, significant environmental effects to biological resources would be less than significant.

3.2 Cultural Resources

3.2.1 Cultural Resources Impacts

The project would result in potentially significant impacts related to previously unidentified archeological resources on the project site during grading and ground disturbing activities (Impact CR- 1), and potential disturbance of human remains (Impact CR-2).

3.2.2 Cultural Resources Mitigation Measures

The Project includes mitigation measures in the MMRP that is to be adopted concurrently with these findings.

All cultural resources impacts and mitigation measures are detailed in Attachment A at the end of this document. Mitigation measure MM -CR-1 will mitigate Impact CR -1 (potential impact to previously unknown archaeological resources) to below a level of significance. MM-CR-2 will mitigate Impact CR- 2 (potential impact to human remains) to below a level of significance.

In order to mitigate potential impacts to previously unidentified archaeological resources (Impact CR- 1), implementation of the following mitigation measures will be required:

13 MM-CR-1 Unanticipated Discovery Procedures. In the event of the unanticipated discovery of cultural resources, all ground disturbing activity at that location shall temporarily halt or be diverted. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. A Qualified Archaeologist shall be retained to assess the discovery. If the resource is determined to be associated with Native American culture, it will be considered a tribal cultural resource and subject to MM -TCR-8. Non-Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture, then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.

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

In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project c onstruction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the curation facility that the curation has been completed.

MM-CR-2 Human Remains : As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the 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 the Medical Examiner recognizes the remains to be Native American, and not 14 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 h ours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

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

3.2.3 Finding

Changes or alterations have been required in, or incorporated into, the Project as mitigation measures MM-CR-1 and MM-CR-2, which are feasible, and will mitigate, avoid or substantially lessen the significant environmental effects as identified in the Final EIR related to archaeological resources (Impact CR-1) and human remains (Impact CR-2).

3.2.4 Facts in Support of Finding

The potential exists for impacts to previously unidentified archaeological resources during project grading. These potentially significant impacts to archaeological resources and human remains would be mitigated to below a level of significance through implementation of mitigation measures MM-CR- 1 and MM-CR-2. MM-CR-1 includes measures to take in the event of unanticipated discovery of cultural resources including stopping or diverting work, retaining a qualified archaeologist to assess discovery, and if applicable, curation procedures. MM -CR-2 includes measures consistent with California Health and Safety Code Section 7050.5 to follow if human remains are found on site. With incorporation of these mitigation measures, cultural resources impacts would be reduced to below a level of significance.

3.3 Noise

3.3.1 Noise Impacts

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 -1). 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 use (65 dBA Leq) if the rock crusher is staged within 400 feet of a single-family residential use (Impact N-2). 15 3.3.2 Noise Mitigation Measures

The Project includes mitigation measures in the MMRP that is to be adopted concurrently with these findings.

All noise impacts and mitigation measures are detailed in Attachment A at the end of this document.

Mitigation measure MM -N-1 will mitigate Impact N-1 (exterior noise levels related to rock drill and blasting) to below a level of significance. Mitigation measure MM-N-2 will mitigate Impact N-2 (exterior noise levels related to rock crushing) to below a level of significance.

To mitigate potential noise impacts related to rock -drilling and blasting , implementation of the following mitigation measure will be required:

MM N-1 Prior to issuance of a blasting permit, the project applicant or contractor shall provide the final location of the construction equipment, topography and construction schedule to the Planning Division. If the rock drill is shown to be located within 160 f eet from a sensitive land use’s property line, an acoustical engineer shall prepare a noise assessment to determine whether noise levels in excess of the 75 dBA standard would occur during construction.

If the rock drilling and blasting noise assessment determines noise levels at the affected property lines would exceed 75 dBA, the acoustical engineer shall develop a mitigation plan to ensure during rock drilling and blasting would be below 75 dBA at the property line. Potential measures to reduce drilling and blasting noise levels could include: 1) construction of a temporary noise barrier of solid non -gaping material ranging from 8 to 12 feet in height along any property line where the impacts could occu r; 2) limits on usage of the equipment (amount of time used and/or the location in respect to the property line) or other measures to ensure the levels would be below 75 dBA. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

To mitigate potential noise impacts related to rock crushing, implementation of the following mitigation measure will be required:

MM N-2 Prior to issuance of a Grading Permit for a rock crusher, the project applicant or contractor shall provide the final location and rock crusher type to the Planning Division. If the rock crusher is shown to be located within 400 feet of a single-family residential use without shielding, an acoustical engineer shall prepare a noise assessment to determine whether noise levels would be above the app lied thresholds of 60 dBA at any existing single family residential use and 65 dBA for multi-family.

If the rock crushing noise assessment determines noise levels at the affected property lines would exceed the standards, the acoustical engineer shall develop a mitigation plan to reduce noise levels to 60 dBA at any existing single-family use and 65 dBA at any existing multi-family use. Mitigation may include sound barriers, 16 sound absorbing materials, and/or operational limits on the crusher equipment’s usage. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

3.3.3 Finding

Changes or alterations have been required in, or incorporated into, the Project as mitigation measures MM-N-1 and MM-N-2, which are feasible, and will mitigate, avoid or substantially lessen the significant effects as identified in the Final EIR resulting from rock drilling and blasting (Impact N-1) and rock crushing noise (Impact N-2).

3.3.4 Facts in Support of Finding
Based on the proposed location of construction equipment relative to surrounding land uses, the noise analysis prepared for the project (LDN 2025) concluded that noise impacts during construction would be below City standards and less than significant. However, the potential exists that construction equipment, specifically the rock drill and rock crusher, could be staged closer to sensitive uses than anticipated potentially resulting in noise levels exceeding the 75 dBA (8-hour) threshold for rock drilling and the applied operational threshold of 60 dBA at any existing single family residential use. during operation of a rock crusher. These potentially significant impacts would be mitigated to below a level of significance through implementation of mitigation measures MM-N-1 through MM-N-2.

Specifically, implementation of mitigation measures MM-N-1 and MM-N-2 provide for preparation of a noise assessment to be prepared prior to issuance of a blasting permit for the rock drill and conditional use permit for the rock crusher to confirm that noise levels would not exceed applicable City standards.

If noise levels would exceed standards, then noise mitigation plans would be prepared and implemented to ensure noise levels are in compliance.

With incorporation of these mitigation measures, noise impacts related to Project implementation will be reduced to below a level of significance.

3.4 Tribal Cultural Resources

3.4.1 Tribal Cultural Resources Impact

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. (Impact TCR-1).

3.4.2 Tribal Cultural Resources Mitigation Measures

All tribal cultural resources impacts and mitigation measures are detailed in Attachment A at the end of this document. Mitigation measures MM-TCR-1 through TCR-12 will mitigate Impact TCR-1 (potential impact to tribal cultural resources) to below a level of significance.

In order to mitigate potential impacts to t ribal cultural resources (Impact TCR -1), implementation of the following mitigation measures will be required

17 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 accordance with the aforementioned proposal. In the event of a dispute between the parties in entering into the agreement for the ethnographic synthesis, and after a good faith and reasonable effort, the City shall serve as the final arbiter. The City will determine the scope and content of an ethnographic synthesis in that event.

The synthesis will draw from oral histories, elder knowledge, and other sources of confidential Indigenous knowledge that relate to the tribal cultural resource affected by the proposed project. The ethnographer shall be afforded up to 90 days following funding of the ethnography to carry out any field visits with appropriate tribal representatives. After 90 days, or sooner if the ethnographer completed 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 Ci ty. 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.

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 18 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 City shall allow construction to proceed without the Native American monitor(s) as long as the offer was extended and documented.

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

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 on all app licable 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 19 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 activ ity 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 a 10 foot by 10 foot area 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 pee l 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 cultur al 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 contin ue 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 be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be not associated with Native American culture, it will b e 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 signific ant archaeological resource that is associated with Native American culture (subject to MM -CR-2), then the Qualified 20 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 overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.

If the Medical Examiner recognizes the remains to be Native American, and not under his or her jurisdiction, then he or she shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment. 21 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 materials en countered 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.

3.4.3 Finding

Changes or alterations have been required in, or incorporated into, the Project as mitigation measure MM-TCR-1 through MM-TCR-12, which are feasible, and will mitigate, avoid or substantially lessen the significant effects as identified in the Final EIR related to tribal cultural resources.

22 3.4.4 Facts in Support of Finding
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.

Mitigation measures MM -TCR-1 through MM -TCR-12, which were developed in conjunction with the consulting Tribes and would reduce the level of impact to tribal cultural resources to less than significant.

Section 4. Findings Regarding Project Alternatives

The CEQA Guidelines states that the “range of potential alternatives to the Project 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 significant effects” (Section 15126[c]). The Final EIR evaluated a reasonable range of alternatives to the Project. These alternatives are:

• No Project/No Development Alternative
• No Project/ Existing Plan Alternative
• Reduced Density Alternative

When a lead agency has determined that, even after the adoption of all feasible mitigation measures, a project as proposed will still cause one or more significant environmental effects that cannot be substantially lessened or avoided, the agency, prior to approving the project as mitigated, must first determine whether, with respect to such impacts, there remain any project alternatives that are both environmentally superior and feasible within the meaning of CEQA. An alternative may be “infeasible” if it fails to achieve the most basic project objectives identified within the EIR.

Table 1 provides a qualitative comparison of each alternative’s conformance to the Project objectives.

Further, “feasibility” under CEQA encompasses the desirability of the project based on a reasonable balancing of relevant economic, environmental, social, or other considerations which make infeasible the Project alternatives identified in Section 4.0 of the Final EIR.

4.1 No Project/No Development Alternative
Under the No Project/No Development Alternative, the proposed project would not be implemented, and the project site would remain undeveloped and in its current condition. No grading or construction would occur on the project site under this alternative. T he project site is currently undeveloped and supports Diegan coastal sage scrub, disturbed Diegan coastal sage scrub, disturbed habitat, and urban/developed areas (Rincon 2025).

Feasibility of Alternative
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 realized under this alternative, incl uding 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 Fee (PFF), which goes toward supporting a variety of services and improvements in the City, including but not limited to Circulation Streets, State Route78 Interchanges, National Pollutant Discharge 23 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 ( See Table 1).

The No Project/No Development Alternative was rejected in favor of the Project , because it does not meet any of the Project objectives.

4.2 No Project/ Existing Plan Alternative
CEQA Guidelines Section 15126.6(e)(3), states that when the project is a revision of an existing land use plan, the no project alternative will be the continuation of the existing plan in the future. 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 th e 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 th e 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 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 could 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.

Feasibility of Alternative
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 proportiona l increase in air pollutants and noise from vehicles compared to the proposed project. Construction -related air pollutants 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. 24 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 sol id 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 1.

Because this alternative would not meet all of the project objectives and would increase ADT, air pollutants and vehicle noise, and increase demand for schools, parks, libraries and solid waste facilities, the No Project/Existing Plan Alternative was rejected in favor of the Project.

4.3 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 the 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 S treet. Grading, blasting and rock crushing as well as fire fuel modification would be required for this alternative.

Feasibility of Alternative
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 pollutants 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 1, but would not provide multi - family housing in the 4.1-8.0 dwelling unit range.

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 systems. 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 significant new and unmitigated impact related to transportation (vehicle miles traveled).
25 Table 1. Summary of Alternatives and Project Objectives Objective Proposed
Project
No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Density
Alternative
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
26 Objective Proposed
Project
No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Density
Alternative
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

Attachment A

Mitigation Monitoring and Reporting Program and
Project Design Features
1 Woodward 46 Specific Plan Mitigation Monitoring and Reporting Program Impact Mitigation Measure Action Timing Responsibility

BIOLOGICAL RESOURCES
BIO-1: The proposed
project has the potential
to result in direct and
indirect impacts to
coastal California
gnatcatcher.

MM-BIO-1a An updated presence/absence protocol survey of the project site and a 500-foot buffer around the project site shall be conducted by a qualified biologist with a valid United States Fish and Wildlife Service 10(a)(1)(A) permit to further evaluate the coastal California gnatcatcher (CAGN) territories that could be affected by short term project construction activities, including vegetation clearance, and long term habitat loss and indirect impacts. In accordance with the USFWS survey protocol, a minimum of six breeding season surveys shall be conducted at least 1 week apart from March 15, through June 30, pending the anticipated construction timeline for the project.

The results of the survey shall be submitted to the City and USFWS upon completion.

Vegetation clearance may continue with regular biological monitoring if there is no indication of disturbance to the nest(s).

If the vegetation clearance is potentially disruptive to active nests a larger buffer may be implemented as determined by the qualified biologist. If CAGN are observed moving through the area during vegetation clearing activities, the project biologist may delay the removal of vegetation and/or grading until CAGN has left the area of their own volition.

If CAGN is found to be within the survey area (project site plus a 500-foot buffer) during protocol or pre-construction surveys, the Conduct CAGN
protocol surveys and
submit results to City
and USFWS.

If CAGN is detected,
avoid vegetation
clearing during
breeding season but
If construction is
proposed during the
breeding season,
conduct a pre-
construction nesting
survey. If nests are
present, implement
buffer zone and
avoidance measures.

Protocol surveys
to occur
between March
15 and June 30
prior to
construction.

If CAGN is
detected during
the protocol
survey,
vegetation
clearing shall
only be
conducted
between
September 1
and February 14,
outside of the
breeding season
for CAGN. If
clearing occurs
during nesting
season
(February 15 to
August 31), pre-
construction
nesting surveys
shall be
conducted no
more than 3
days prior to
vegetation
clearing.

Applicant/
Landowner,
Project Biologist,
Contractor.
2 Impact Mitigation Measure Action Timing Responsibility following avoidance and minimization measures shall be
implemented.

a) To reduce potential noise impacts to nesting CAGN, a qualified biologist shall monitor noise levels with a noise monitoring device at an appropriate distance from the
nest to determine if construction activity noise is above 60 dBA Leq, the standard level requested by the
USFWS, or if noise levels above 60 dBA Leq have the
potential to affect any CAGN nests.

b) If/when an active CAGN nest is identified, an
acoustician shall monitor noise at the edge of
construction as directed by the qualified biologist. If noise levels continue to exceed 60 dBA Leq, the
acoustician shall consult with the qualified biologist and provide requirements for the construction contractor to make operational and barrier changes to reduce noise
levels to 60 dBA Leq during the breeding season
(February 15 through August 31). Noise monitoring shall occur during operational changes and installation of
barriers, as needed, to ensure their effectiveness. If the noise meets or exceeds the 60 dBA Leq threshold, or if
the biologist determines that the activities in general are disturbing the nesting activities, the biologist shall have the authority to halt construction and shall consult with the USFWS to devise methods to reduce the noise
and/or disturbance in the vicinity. This may include
methods such as, but not limited to, turning off vehicle engines and other equipment whenever possible to
reduce noise, installing a protective noise barrier
between the nesting coastal CAGN and the activities,
and working in other areas until the young have fledged.

All active nests will be reported within 24 hours to the USFWS upon detection.

All active nests
will be reported
within 24 hours
to the USFWS
upon detection.

MM-BIO-1b Long-Term Open Space Management
A long-term open space management plan shall be developed to minimize impacts of the residential development on the adjacent Develop long-term
open space
management plan.

Prior to issuance
of Grading
Permit.

Applicant/
Landowner, Project
Biologist.
3 Impact Mitigation Measure Action Timing Responsibility coastal California gnatcatcher (CAGN) and Diegan Coastal Sage scrub habitat. The adjacent area falls within a Multiple Habitat Conservation Program Hardline Reserve, occupied by CAGN, and additional mitigation measures are necessary to minimize impacts associated with increased human and domestic pet presence from the project. The plan shall include a program of education to reduce domestic and feral cat encroachment (using the program developed by the American Society for the
Prevention of Cruelty to Animals). Use of invasive exotic plant species in landscaped areas adjacent to or near sensitive vegetation communities shall be restricted. The applicant shall encourage the use of native species in the landscaping plan and shall avoid the use of species listed in Lists A & B of the California Invasive Plant Council's list of Exotic Pest Plants of Greatest Ecological Concern in California as of October 1999.

This list includes such species as pepper trees (Schinus mole), pampas grass (Cortaderia selloana), fountain grass, ice plant (Carpobrotus sp.), myoporum (myoporum sp.), black locust (Robinia pseudoacacia), capeweed (Arctotheca calendula), tree of heaven (Ailanthus altissima), periwinkle Vinca major), sweet alyssum (Lobularia maritima), English ivy (Hedera helix), French broom (Genista monspessulana), Scotch broom (Cytisus
scoparius), and Spanish broom (Spartium junceum). The plan shall also address permanent residential lighting to be directed away from the open space.

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.

MM-BIO-2 Focused surveys found the Diegan Coastal Sage
Scrub on site to be occupied by Crotch’s bumble bee (CBB).

Thus, there is potential for take of CBB and adverse impacts may occur through the removal of occupied habitat. However, the project would incorporate the following CBB avoidance,
minimization and mitigation measures to reduce significant impacts to below a level of significance. should the species remain a candidate for state listing. If the State ultimately does not list Crotch’s bumble bee under the California Endangered Species Act and the species is removed from candidate status, the mitigation measures outlined below would no longer be applicable.

Consultation with
CDFW regarding
Incidental Take
Permit.

Implement
avoidance measures
for CBB

Implement MM-BIO-6
and MM-BIO-3a and
3c.

Prior to notice to
proceed for any
construction
permits,
including
issuance of
Grading Permit.

Applicant/
Landowner, Project
Biologist.
4 Impact Mitigation Measure Action Timing Responsibility Avoidance, Minimization, and Mitigation Measure for Crotch’s Bumble Bee
Prior to the Notice to Proceed (NTP) for any construction permits, including but not limited to, the first Grading Permit, The City shall verify the following project requirements regarding the CBB are shown on the construction plans. Should this species no longer be a potential candidate for listing at the time of the preconstruction meeting, then no avoidance measures shall be required.

Incidental Take Permit:
• Crotch’s bumble bee has been detected onsite, and all suitable habitat is considered occupied. As avoidance of impacts is not feasible, the Project applicant shall consult with CDFW and obtain appropriate take authorization
from CDFW (pursuant to Fish & Ga me Code, § 2080 et
seq.). If an Incidental Take Permit is issued, the Project applicant shall comply with the mitigation measures
detailed in the take authorization issued by CDFW. In
addition, the terms and conditions of that permit shall supersede any co nflicting measures contained in this
document. The Project applicant shall provide a copy of a fully executed take authorization prior to the issuance of a grading permit and before any ground disturbance and
vegetation removal. Should the State decline to list the species under the California Endangered Species Act and remove its candidate status, this measure shall no longer be applicable, and an Incidental Take Permit will not be required.

Pre-activity surveys:
• To avoid direct impacts on CBB , removal of habitat (i.e., defined as any habitat disturbance) must occur outside
of the Colony Active Period (generally occurring between February 1 through August 31). If the removal of habitat must occur during the Colony Active Period, a Qualified Biologist shall conduct a pre-activity survey no more than 5 Impact Mitigation Measure Action Timing Responsibility three days prior to the initiation of construction activities to determine the presence or absence of CBB within the
proposed area of disturbance following CDFW’s Survey
Considerations for California Endangered Species Act
Candidate Bumble Bee Species (CDFW 2023) or the
latest guidance from CDFW no more than 10 days and no
less than 3 days prior.

Resumes shall be provided to CDFW for review.

• The pre-activity survey shall consist of non-lethal photo vouchers following California Department of Fish and
Wildlife (CDFW) guidance (CDFW 2023). he surveys shall
consist of passive methods unless a Memorandum of
Understanding is obtained. The Qualified Biologist shall send all photographic vouchers to a CDFW approved
taxonomist to confirm the identifications of the bumble bees encountered during surveys. If candidate bumble
bees will be captured or handled during surveys, then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific
Collecting Permit pursuant to CDFW guidance (CDFW
2023).

• If pre-activity surveys identify CBB individuals on-site, the Qualified Biologist shall notify and consult with CDFW to establish, monitor, and maintain no -work buffers around the associated floral/nest resources or identified nesting locations. The size and configuration of the no- work
buffer shall be based on the best professional judgment of the Qualified Biologist in consultation with CDFW.

Construction activities shall not occur within the no -work 6 Impact Mitigation Measure Action Timing Responsibility buffers until the bees appear are no longer active (i.e., associated floral resources appear desiccated and no
bees are seen flying for three consecutive days indicating dispersal from the area). Take of any endangered,
threatened, candidate species that results from the
project is pr ohibited, except as authorized by State law (Fish and Game Code section 86, 2062, 2067, 2068,
2080, 2085; California Code Regulations, Title 14,
section 786.9) under CESA.

• Survey data shall be submitted by the Qualified Biologist to the California Natural Diversity Database (CNDDB) in accordance with the Memorandum of Understanding with
CDFW, or Scientific Collecting Permit requirements, as
applicable.

Specifically, the Diegan coastal sage scrub mitigation shall include habitat compensation at a minimum 1:1 ratio or as negotiated through consultation with the CDFW for an Incidental Take Permit, to also benefit the CBB. This mitigation may be satisfied through off-site acquisition, in lieu fees, purchase of credits from an approved mitigation bank, or a combination thereof. If necessary, habitat enhancement or restoration also may be incorporated, to be described in a Habitat Management and Monitoring Plan (i.e. planting of native Diegan coastal sage scrub flowering plant species known to support bumble bee populations, removal of invasive species, etc.). If prepared, the HMMP or other plans for Crotch’s bumble bee habitat enhancement or restoration will be provided to CDFW for review and approval. Any land acquired as 7 Impact Mitigation Measure Action Timing Responsibility off-site mitigation to benefit CBB shall include a cost estimate for long-term management, an endowment, and a land protection mechanism such as a conservation easement. Mitigation lands for CBB must be occupied or include high quality suitable habitat.

This species shall also be included in the Worker Environmental Awareness Program educational program described in MM-BIO-3a and BMP’s implemented per MM-BIO-3c.

BIO-3: The proposed
project has the potential
to result in direct and
indirect impact to
special-status wildlife
species including Orange-
throated whiptail, coastal
whiptail, Southern
California rufous-crowned
sparrow, Cooper’s hawk,
Crotch’s bumble bee,
and Bryant’s woodrat.

MM-BIO-3a Worker Environmental Awareness Program (WEAP) The applicant shall implement a Worker Environmental
Awareness Program (WEAP) for the construction crew that will be developed by a qualified biologist. Each employee (including temporary, contractors, and subcontractors) will receive the WEAP presentation on the first day of project work. They will be advised of sensitive species in the area and avoidance measures being implemented to protect them at the site. At a minimum, the WEAP will include the following topics: occurrence of the listed and sensitive species in the area, their general ecology, sensitivity of the species to human activities, legal protection afforded these species, penalties for violations of federal and State laws, reporting requirements, and project features and conditions designed to reduce direct and indirect impacts to these species, role of the Biological Monitor, and worker responsibilities to maintain compliance with mitigation measures while working at the site.

Implement WEAP Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

Applicant/
Landowner, Project
Biologist,
Contractor.
8 Impact Mitigation Measure Action Timing Responsibility staging areas, and routes of travel. The biological monitor shall verify that the limits of construction have been properly staked and are readily identifiable. Intrusion by unauthorized vehicles outside of construction limits shall be prohibited, with control exercised by an on-site foreman. Access routes to the
construction area outside of work hours shall be blocked with physical barriers, such as concrete blocks or large equipment.

MM-BIO-3c Biological Monitory and Construction BMPs A City of San Marcos-approved, qualified biologist shall be present during all vegetation clearing and other activities with the potential to affect coastal California gnatcatcher (CAGN), orange throated whiptails, coastal whiptails, Bryant’s woodrat, Coopers hawks, and southern rufus-crowned sparrow, nesting birds, and any other sensitive plant or wildlife resource, and will monitor the project for avoidance of unanticipated impacts to the
aforementioned species and their habitats. Standard
construction Best Management Practices will be implemented by the contractor to minimize potential impacts to sensitive species.

The biologist shall have the authority to halt all associated project activities that may be in violation of the protective measures. Daily monitoring logs shall be maintained and a monthly report of compliance with biological resource measures will be provided to the City during construction. Standard Construction Best Management Practices shall include the following:

 Vehicle speeds will not exceed 10 miles per hour (mph) adjacent to CAGN habitat. Clear signage will be installed and maintained throughout the construction period.

Placement of drip pans under parked equipment and
vehicles.

 Regular inspection and maintenance of equipment to avoid spills and immediate containment of any spills.

 Chemicals and pesticides will not be used.

 Pets and firearms will not be allowed at the site.

Biological monitoring
and implementation
of BMPs during
construction.

Review/approve
landscape plans.

Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.
9 Impact Mitigation Measure Action Timing Responsibility

 Trash will be removed from the site daily or be stored in wildlife proof containers

 Stormwater protection (i.e., straw waddles, silt fence) will be employed to prevent spills, runoff, or sediment from entering nearby aquatic habitats. These materials will be weed free and no project debris or rubbish will be allowed to enter into or be placed where it may be washed by
rainfall or runoff in the wetlands.

 Staging/storage areas for equipment and materials will be located at least 100 feet away from the riparian areas.

Equipment will be checked and maintained daily to prevent leaks of pollutants into the wetlands.

 No equipment maintenance will be carried out within 100 feet of the riparian area.

 All pipes, culverts, or similar structures with a 4-inch diameter or greater that are stored on the construction site overnight shall be thoroughly inspected for wildlife or nesting birds before the pipe is subsequently curried,
capped, or otherwise used or moved in any way.

 To prevent inadvertent entrapment of wildlife during
construction, all excavated, wells, steep-walled holes, or trenches more than 2 feet deep shall be covered with
plywood or similar materials at the close of each working day.

 Any construction lighting will be directed toward the work area and away from adjacent habitats.

Applicant/
Landowner, Project
Biologist,
Contractor.
10 Impact Mitigation Measure Action Timing Responsibility disturbance, a pre-construction survey shall be conducted for woodrat middens. All occupied woodrat middens shall be
mapped and flagged for avoidance to the extent feasible, with a minimum of 10-feet surrounding the active midden. If avoidance is not feasible, middens will be disturbed “daylighted” by a qualified biologist one night before anticipated vegetation removal to allow for the rats to escape and passively relocate prior to disturbance of the area.
minimization
measures.

BIO-4: The proposed
project has the potential
to impact nesting birds
and raptors that are
afforded protection
under the California Fish
and Game Code and the
Migratory Bird Treaty Act.

MM-BIO-4 If site clearing activities are conducted between January 1 and August 31, a qualified biologist shall conduct a nesting bird survey no more than 3 days prior to the start of such activities to identify actively nesting birds within the project site and a 500-foot buffer around the project site. If any nests are found, their locations shall be flagged and an appropriate avoidance buffer, ranging in size from 25 to 50 feet for passerines, and up to 500 feet for raptors depending upon the species and the proposed work activity. The non-disturbance buffer zone shall be determined and demarcated by a qualified biologist with bright orange construction fencing or other suitable flagging materials. Active nests shall be monitored at a minimum of once per week until it has been determined that the nest is no longer being used by either the young or adults. No disturbance shall occur within this buffer until the qualified biologist confirms that breeding/nesting is completed, and all the young have fledged. If project activities must occur within the buffer, activities shall be conducted at the discretion of the qualified biologist and with monitoring and management to confirm that nesting birds and the nests are not disturbed. If no nesting birds are observed during the nesting survey or during other
monitoring activities, then no further actions shall be necessary.

A follow-up survey will be needed if site clearing does not occur within 3 days after the initial survey and/or a pause in construction activity occurs for more than 7 days.

If site clearing
activities occur
during breeding
season, conduct a
pre-construction
survey. If nesting
birds are present,
implement buffer
zone and avoidance
measures.

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

For construction
activities
proposed for the
period of
January 1
through August
31, conduct
survey within
three days prior
to the start of
construction
activities.

Applicant/
Landowner, Project
Biologist,
Contractor.

BIO-5: The proposed
project has the potential
to result in indirect
impacts to sensitive
species due to urban run-
Implementation of mitigation measures MM-BIO-3a through MM- BIO-3d, described above would reduce potential indirect impacts to sensitive species.

11 Impact Mitigation Measure Action Timing Responsibility off, introduction of meso-
predators (e.g., dogs and
cats), invasive plant
species, and noise and
lighting effects.

BIO-6: The proposed
project would impact

5.24 acres of Diegan
coastal sage scrub and

0.26 acre of disturbed
Diegan coastal sage
scrub for a total of 5.50
acres of impact.

MM-BIO-6 The permanent loss of 5.5 acres of Diegan Coastal Sage Scrub, and Disturbed Diegan Coastal Sage Scrub shall be mitigated at a minimum 1:1 ratio. Section 5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on-site mitigation, off-site acquisition, in-lieu fees, or mitigation credits. For mitigation purposes, the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub acreages on the project site that would be impacted have been combined as these two vegetation communities are considered to have similar sensitivity under the Multiple Habitat
Conservation Program. Thus, 5.5 acres of occupied coastal California gnatcatcher Diegan Coastal Sage Scrub will be preserved by the project applicant through off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City of San Marcos Planning Manager and the Wildlife Agencies prior to issuance of the grading permit.

If on site or off-site habitat mitigation will be completed by the Applicant to satisfy the compensatory mitigation requirements, it shall be carried out in accordance with a Habitat Mitigation and Monitoring Plan (HMMP) that outlines the strategy for
enhancement and maintenance of the habitat for locally
sensitive species occupying Diegan Coastal Sage Scrub. The HMMP will be provided to the Wildlife Agencies for review and approval. Any land acquired as off-site mitigation to benefit gnatcatcher shall include a cost estimate for long-term maintenance, and endowment, a land protection mechanism such as a conservation easement. Mitigation lands for
gnatcatcher must be occupied or include high quality suitable habitat.

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

Prior to issuance
of Grading
Permit.

Applicant/
Landowner, Project
Biologist.

CULTURAL RESOURCES
12 Impact Mitigation Measure Action Timing Responsibility CR-1 Due to grading
and ground disturbing
activities, the project has
the potential to impact
unidentified
archeological resources
on the project site.

MM-CR-1 Unanticipated Discovery Procedures. In the event of the unanticipated discovery of cultural resources, all ground disturbing activity at that location shall temporarily halt or be diverted. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. A Qualified Archaeologist shall be retained to assess the discovery. If the resource is determined to be associated with Native American culture, it will be considered a tribal cultural resource and subject to MM-TCR-8. Non-Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture, then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.

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

In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project construction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City If potential cultural
resources are found,
provide
documentation that
a qualified
archaeologist has
been retained, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

Applicant/
Landowner,
Archaeologist,
Tribal Monitor(s),
Contractor.
13 Impact Mitigation Measure Action Timing Responsibility written documentation from the curation facility that the curation has been completed.

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

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

During all earth
moving and
ground
disturbing
activity.

Archaeologist,
Tribal Monitor(s).
14 Impact Mitigation Measure Action Timing Responsibility site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public. According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and
disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a location free from future disturbance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

NOISE
N-1 Potential for
noise impacts due to
rock drilling and blasting.

MM-N-1 Prior to issuance of a blasting permit, the project applicant or contractor shall provide the final location of the construction equipment, topography and construction schedule to the Planning Division. If the rock drill is shown to be located within 160 feet from a sensitive land use’s property line, an acoustical engineer shall prepare a noise assessment to determine whether noise levels in excess of the 7
5 dBA standard
would occur during construction.

If the rock drilling and blasting noise assessment determines noise levels at the affected property lines would exceed 75 dBA, the acoustical engineer shall develop a mitigation plan to ensure during rock drilling and blasting would be below 75 dBA at the property line. Potential measures to reduce drilling and blasting noise levels could include: 1) construction of a temporary noise barrier of solid non-gaping material ranging from 8 to 12 feet in height along any property line where the impacts could occur; 2) limits on usage of the equipment (amount of time used and/or the location in respect to the property line) or other measures to ensure the levels would be below 75 dBA. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

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

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

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

Applicant/
Landowner,
Acoustical
Engineer,
Contractor, City
(Planning Division
Manager).
15 Impact Mitigation Measure Action Timing Responsibility N-2 Potential for
noise impacts due to
rock crushing.

MM-N-2 Prior to issuance of a Grading Permit for a rock crusher, the project applicant or contractor shall provide the final location and rock crusher type to the Planning Division. If the rock crusher is shown to be located within 400 feet of a single- family residential use without shielding, an acoustical engineer shall prepare a noise assessment to determine whether noise levels would be above the applied thresholds of 60 dBA at any existing single family residential use and 65 dBA for multi-family.

If the rock crushing noise assessment determines noise levels at the affected property lines would exceed the standards, the acoustical engineer shall develop a mitigation plan to reduce noise levels to 60 dBA at any existing single-family use and 65 dBA at any existing multi-family use. Mitigation may include sound barriers, sound absorbing materials, and/or operational limits on the crusher equipment’s usage. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

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

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

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

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

Tribal Cultural Resources
TCR-1 As a result of
tribal consultation, the
City has determined that
construction of the
proposed project has the
potential to cause a
substantial adverse
change to a tribal cultural
resource that is
determined by the City,
based on substantial
evidence to be a tribal
cultural resource.

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 accordance with the aforementioned proposal. In the event of a dispute between the parties in entering into the agreement for the ethnographic synthesis, and after a good faith and reasonable effort, the City shall serve as the final arbiter. The City will determine the scope and content of an ethnographic synthesis in that event.

Agreement to
prepare
synthesis within
30 days of
project approval.

Synthesis to be
prepared prior to
ground
disturbing
activities
Applicant/
Landowner, Rincon
Band of Luiseño
Indians
16 Impact Mitigation Measure Action Timing Responsibility 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 construction of the project while non-field-based data gathering, such as ethnographic interviews of informants and review of tribal documents, is being carried out. Upon completion, a public (redacted) version of the ethnographic synthesis shall be submitted to the California Historical Resources Information System and the City. The final non-redacted study shall belong to the Rincon Band of Luiseño Indians.

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.

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 Extend invitation and
if accepted, enter
into a Monitoring
Agreement between
Applicant/Owner and
Tribes.

Prior to issuance
of a Grading
Permit or
commencement
of
ground
disturbing
activities and
during all earth
moving and
ground
disturbing
activities.

Applicant/
Landowner, Tribal
Representative(s),
Tribal Monitor(s),
Archaeologist,
17 Impact Mitigation Measure Action Timing Responsibility release of ownership, and the recipient thereof, shall be reflected in the Monitoring Agreement. 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.

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

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

Applicant/
Landowner, Tribal
Monitor(s),
Archaeologist,
Contractor.
18 Impact Mitigation Measure Action Timing Responsibility original pre-project ground surface to identify any evidence of potential tribal cultural resources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non-commercial sources that have been determined to be absent of tribal cultural resources by the TCA Native 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 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.

Install exclusionary
fencing around
western cultural
feature.

Prior to
commencement
of clearing and
grubbing.

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

MM-TCR-5 Monitoring 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.

Tribal Monitoring
when construction-
related activity
reaches 1000 feet of
the eastern cultural
feature.

During non-
ground
disturbing
construction
activity.

Applicant/
Landowner, Tribal
Monitor(s),
Archaeologist,
Contractor.
19 Impact Mitigation Measure Action Timing Responsibility 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 a 10 foot by 10 foot area of
culturally sterile soil.

Cap eastern cultural
feature
Prior to the
commencement
of ground
disturbing
activities.

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

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.

Controlled grading
methods within 500
feet of easter and
western cultural
features identified
on grading plans and
conducted under
observation of tribal
monitor(s) and
archaeologist.

Prior to issuance
of grading permit
and during
grading/earth
disturbing
within
500 feet of
easter and
western cultural
features
Applicant/
Landowner, Tribal
Monitor(s),
Archaeologist,
Contractor.

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

20 Impact Mitigation Measure Action Timing Responsibility 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.

21 Impact Mitigation Measure Action Timing Responsibility 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 overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.

During all earth
moving and
ground
disturbing
activity.

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

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 materials encountered during monitoring, and to rebury existing collections from the previous data recovery effort. Following the completion of all ground disturbing activity and reburial of all materials and before the issuance of a Certificate of Occupancy, the Applicant shall: 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.

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

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

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

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

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

Prior to the
issuance of a
Certificate of
Occupancy.

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

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 Extend offer to
Tribe(s) and if
accepted prepare
access agreement
(s) for future visits to
the site’s reburial
location after
construction.

Prior to the
issuance of a
Certificate of
Occupancy.

Applicant/ Land
Owner, Tribal
Representative(s),
Tribal Monitor(s),
City (Planning
Division Director).
23 Impact Mitigation Measure Action Timing Responsibility 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.

Project Design Features
The project shall incorporate the following design features and shall adhere to specific regulatory requirements that would minimize potential environmental effects. These are summarized in the table below.

Woodward 46 Specific Plan Project Design Features
Aesthetics
• Implementation of the Landscape Plan to provide a cohesive and visually appealing planting scheme.
• Compliance with the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards.

Air Quality
• Compliance with SDACPD Rule 55 – Fugitive Dust.
• In accordance with SDAPCD Rule 67.0 (Architectural Coatings), the project would utilize low-volatile organic compound (VOC) paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces. • Heavy diesel construction equipment shall be rated Tier IV.

Energy
• Ensure proper maintenance of all construction equipment per manufacturer recommendations.
• Installation of rooftop solar consistent with Title 24.

Greenhouse Gas Emissions
• Installation of rooftop solar consistent with Title 24. • Compliance with the City’s Model Water Efficient Landscape Ordinance and Municipal Code, Title 20.
• None of the units would have fireplaces.
• Planting of shade trees.
• Each garage would be wired to accommodate an electric vehicle charger.

Geology and Soils
• Implement all recommendations from the preliminary geotechnical investigation (GeoTek 2019). These recommendations include general provisions related earthwork, and design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, and post-construction considerations. The detailed recommendations are included in Chapter 5 of the geotechnical report, which is included as Appendix G of this document. • Removal and replacement of netting along Woodward Street frontage to minimize potential for rock and debris fall on the roadway, as noted on the project grading plans.

Hazards
• Implementation of a zoned brush management plan which would provide a minimum of 150 feet of clearance from structures.
• Future residents shall be notified of potential annoyances commonly associated with proximity to airports (e.g., noise, vibrations, and overflights) through the recording of overflight notification documents as outlined in the McClellan-Palomar Airport Land Use Compatibility Plan and Chapter 20.265 of the City’s Municipal Code. 25 Hydrology and Water Quality

Source control BMPs include, but are not limited to:
• Preventing illicit discharges into the MS4
• Stenciling the future on-site public road storm drain inlets • Protecting trash storage areas from rainfall, run-on, runoff, and wind dispersal.

Site design BMPs include, but are not limited to:
• Conserving natural drainage pathways and hydrologic features • Conserving natural areas, soils, and vegetation
• Minimizing impervious areas
• Minimizing soil compaction
• Runoff collection through multiple private inlets
• Landscaping with native or drought tolerant species.

Permanent Structural BMPs, include, but are not limited to:
• Biofiltration basins and hydromodification facility including 100-year post-development detention
Noise/Vibration
• Grading, excavation, and other earth moving activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. No grading, excavation and other earth moving activities would occur on the weekends or holidays in accordance with the City’s Municipal Code, Section 17.32.180.
• The project would comply with all provisions identified in the City’s Municipal Code Section

17.60.06 as it relates to blasting and blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. Blasting also required issuance of a Blasting Permit from the San Marcos Fire Department.
• All construction equipment would be properly fitted with mufflers and all staging and maintenance would be conducted as far away from the existing residence as possible. • To ensure compliance with CCR Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).

Public Services – Fire Protection, Police Protection Schools, and Parks • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001-01 (Fire and Paramedic). • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 98-01 (Police). • The applicant shall pay the San Marcos Unified School District developer fees that are in effect at the time of building permit issuance. The current residential fee is $4.79 per square foot.
• Payment of Public Facility Fees, a portion of which go towards park development. 26 Transportation
• The applicant/developer/property owner shall construct an access point that provides adequate driveway sight distance.
• The applicant/developer/property owner shall construct a southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane.
• The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2011-01 (Congestion Management). • Payment of Public Facility Fees, a portion of which go towards improvements to circulation streets and State Route 78 interchanges.

Utilities and Service Systems
• The applicant would pay applicable Water and Wastewater Capital Facility Fees to Vallecitos Water District per Ordinances Nos. 175 and 176. Proof of payment would be provided to the City’s Planning Manager.
• Extend the existing 8-inch gravity sewer main located north of the project site in Woodward Street for approximately 490 feet.

Woodward 46 Specific Plan Project
Final Environmental Impact Report
SCH No. 2023080449
SP22-0005/SP22-0006/GPA22-0004/MFSD22-0005/TSM22-0004/CUP22--0005 P
repared for:

Cit
y of San Marcos
Planning Division
1 Civic Center Drive
San Marcos, CA 92069
Contact: Scott Nightingale, Principal Planner
P
repared by:

So
phia Mitchell & Associates
P.O. Box 1700
Gualala, CA 95445
Contact: Sophia Habl Mitchell
M
ay 2025

Woodward 46 Specific Plan May 2025
City of San Marcos Page 0.1-1

0.1 INTRODUCTION AND SUMMARY
The applicant, Cornerstone Communities, is proposing to develop 46 duplex residential units, associated infrastructure, and common and private open space on an approximately 8.57 gross acre site located on Woodward Road in the City of San Marcos.

The project applicant is requesting the following discretionary approvals from the City to allow for development of the proposed project:
• Specific Plan Amendment (SP22-0006) – A Specific Plan Amendment to modify the Heart of the City Specific Plan to remove the current Richmar Sub-Plan designation on the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan.
• Specific Plan (SP22 -0005) – The Woodward 46 Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan.
• General Plan Amendment (GPA22 -0004) – A General Plan Amendment to the Land Use Element for the purpose of amending land use maps and text related to changing the sub-plan designation of the subject property from Richmar Specific Plan to Woodward 46 Specific Plan. • Multi-Family Site Development Plan (MFSDP22 -0005) - Multi-Family Site Development Plan approval would be required to construct 46 multi -family residential units and address the details of the architectural style, building elevation, fencing, and landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM22-0004) - Tentative Subdivision Map approval would be required for formation of residential condominium units, private driveways, and open space areas.
• Conditional Use Permit (CUP22-0005) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

This Final Environmental Impact Report (EIR) (SCH No. 202 3080449) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.), CEQA Guidelines (California Administrative Code Section 15000 et seq.), and the City of San Marcos CEQA procedures. The City of San Marcos is the Lead Agency under CEQA.

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

Woodward 46 Specific Plan May 2025
City of San Marcos Page 0.1-2
In accordance with these requirements, the Woodward 46 Specific Plan EIR is comprised of the following:
• Draft Environmental Impact Report, Woodward 46 Specific Plan (March 2025)

• This Final EIR document, May 2025, that incorporates the information required by Section 15132
Format of the Final EIR
This document is organized as follows:

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

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

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

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

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

Woodward Specific Plan May 2025
City of San Marcos Page 0.2-1

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

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

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

Changes to the Draft EIR include the following:
• Change to biological resources mitigation measure s MM-BIO-2 and MM-BIO -6 to address comments from the California Department of Fish and Wildlife (CDFW).

• Change to a tribal cultural resources mitigation measure, MM -TCR-6, to refine the fill depths in order to be consistent with the proposed grading plan.

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

Woodward Specific Plan May 2025
City of San Marcos Page 0.2-2

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

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

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

Final EIR Section Page/Table/Figure Change
Biological Resources Pages 3.3-22 and 3.3-23 – revisions to mitigation measure MM-BIO-2 based upon CDFW comment.

Page 3 ends

based upon CDFW comment.

Tribal Cultural Resources Page 3.12-11 – revision to mitigation measure MM-TCR-6 to reflect the proposed grading plan.

Appendices Appendix D.1 – the biological resources report was updated to reflect revisions to the mitigation measures based upon CDFW comment.

Woodward Specific Plan May 2025
City of San Marcos Page 0.2-3

0.2.2 REVISED AND SUPPLEMENTAL MITIGATION

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

Revised Mitigation Measures
MM-BIO-2 Focused surveys found the Diegan Coastal Sage Scrub on site to be occupied by Crotch’s bumble bee (CBB). Thus, there is potential for take of CBB and adverse impacts may occur through the removal of occupied habitat. However, the project would incorporate the following CBB avoidance , minimization and mitigation measures to avoid take and reduce significant impacts to below a level of significance. should the species remain a candidate for state listing. If the State ultimately does not list Crotch’s bumble bee under the California Endangered Species Act and the species is removed from candidate status, the mitigation measures outlined below would no longer be applicable.

Incidental Take Permit:

• Crotch’s bumble bee has been detected onsite, and all suitable habitat is considered occupied. As avoidance of impacts is not feasible, the Project applicant shall consult with CDFW and obtain appropriate take authorization from CDFW (pursuant to Fish & Game Code, § 2080 et seq.).

If an Incidental Take Permit is issued, the Proj ect applicant shall comply with the mitigation measures detailed in the take authorization issued by CDFW. In addition, the terms and conditions of that permit shall supersede any conflicting measures contained in this document. The Project applicant shall provide a copy of a fully executed take authorization prior to the issuance of a grading permit and before any ground disturbance and vegetation removal. Should the State decline to list the species under the California Endangered Species Act and remove i ts candidate status, this measure shall no longer be applicable, and an Incidental Take Permit will not be required.

Pre-activity surveys:
• To avoid direct impacts on CBB , removal of habitat (i.e., defined as any habitat disturbance) in the proposed area of disturbance must occur outside of the Colony Active Period (generally occurring between February 1 April 1 through August 31). If the removal of habitat in the proposed area Woodward Specific Plan May 2025
City of San Marcos Page 0.2-4
of disturbance must occur during the Colony Active Period, a Qualified Biologist shall conduct a pre -activity (defined as any habitat disturbance) survey no more than three days prior to the initiation of construction activities to determine the presence or absence of CBB within the proposed area of disturbance following CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023) or the latest guidance from CDFW no more than 10 days and no less than 3 days prior.

• A Qualified Biologist must meet the qualifications discussed in the CDFW guidance (i.e., Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species, dated June 6, 2023). Resumes shall be provided to CDFW for review. demonstrate the following qualifications:
at least 40 hours of experience surveying for bee or other co -occurring aerial invertebrate species (such as Quino checkerspot butterfly) and have completed a CBB detection/identification training by an expert CBB entomologist; or the biologist must have at least 20 hours of experience directly observing CBB.

• The pre -activity survey shall consist of non-lethal photo vouchers photographic surveys following California Department of Fish and Wildlife (CDFW) guidance (CDFW 2023). (i.e., Survey Considerations for California Endangered Species Act [CESA] Candidate Bumble Bee Species, dated June 6, 2023). The surveys shall consist of passive methods unless a Memorandum of Understanding is obtained. The Qualified Biologist shall send all photographic vouchers to a CDFW approved taxonomist to confirm the identifications of the bumble bees encountered during surveys. If candidate bumble bees will be captured or handled during surveys, then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific Collecting Permit pursuant to CDFW guidance (CDFW 2023).

If additional activities (e.g., capture or handling) are deemed necessary to identify bumble bees of an unknown species that may be CBB , then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific Collecting Permit pursuant to CDFW Survey Considerations for CESA Candidate Bumble Bee Species (CDFW 2023). Survey methods that involve let hal take of species are not acceptable.
• If pre -activity surveys identify CBB individuals on -site, the Qualified Biologist shall notify and consult with CDFW to establish, monitor, and maintain no-work buffers around the associated floral/nest resources or identified nesting locations . The size and configuration of the no-work buffer shall be based on the best professional judgment of the Qualified Biologist in consultation with CDFW. Construction activities shall not occur within the no-work buffers until the bees appear are no longer active (i.e., associated floral resources appear desiccated and no bees are seen flying for three consecutive days indicating dispersal from the area). Take of any Woodward Specific Plan May 2025
City of San Marcos Page 0.2-5
endangered, threatened, candidate species that results from the project is prohibited, except as authorized by State law (Fish and Game Code section 86, 2062, 2067, 2068, 2080, 2085; California Code Regulations, Title 14, section 786.9) under CESA.
• Survey data shall be submitted by the Qualified Biologist to the California Natural Diversity Database (CNDDB) in accordance with the Memorandum of Understanding with CDFW, or Scientific Collecting Permit requirements, as applicable.

Compensatory Mitigation for Impacts to Crotch’s Bumble Bee Habitat Should the species be formally listed, or remain a candidate for listing, mitigation for the loss of CBB occupied Diegan Coastal Sage Scrub shall be conducted to reduce impacts to less than significant. This mitigation will be carried out in conjunction with the Diegan coastal sage scrub mitigation described in MM-BIO-6. Specifically, the Diegan coastal sage scrub mitigation shall include habitat compensation at a minimum 1:1 ratio or as negotiated through consultation with the CDFW for an Incidental Take P ermit, to also benefit the CBB. This mitigation may be satisfied through off -site acquisition, in lieu fees, purchase of credits from an approved mitigation bank, or a combination thereof. If necessary, habitat enhancement or restoration also may be incorporated, to be described in a Habitat Management and Monitoring Plan (i.e. planting of native Diegan coastal sage scrub flowering plant species known to support bumble bee populations, removal of invasive species, etc.).

If prepared, the HMMP or other plans for Crotch’s bumble bee habitat enhancement or restoration will be provided to CDFW for review and approval.

MM-BIO-6 The permanent loss of 5.5 acres of Diegan Coastal Sage Scrub, and Disturbed Diegan Coastal Sage Scrub shall be mitigated at a minimum 1:1 ratio. Section

5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on -site mitigation, off -site acquisition, in -lieu fees, or and mitigation credits. For mitigation purposes, the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub acreages on the project site that would be impacted have been combined as these two vegetation communities are considered to have similar sensitivity under the Multiple Habitat Conservation Program. Thus, 5.5 acres of occupied coastal California gnatcatcher Diegan Coastal Sage Scrub will be preserved by the project applicant th rough off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City of San Marcos Planning Manager and the Wildlife Agencies wildlife agencies prior to issuance of the grading permit. If on site or off-site habitat mitigation will be completed by the Applicant to satisfy the Woodward Specific Plan May 2025
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compensatory mitigation requirements, it shall be carried out in accordance with a Habitat Mitigation and Monitoring Plan (HMMP) that outlines the strategy for enhancement and maintenance of the habitat for locally sensitive species occupying Diegan Coastal Sage Scrub. The HMMP will be provided to the Wildlife Agencies for review and approval. Any land acquired as off -site mitigation to benefit gnatcatcher shall include a cost estimate for long -term maintenance, and endowment, a land protection mechanism such as a conservation easement. Mitigation lands for gnatcatcher must be occupied or include high quality suitable habitat.

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 a 10 foot by 10 foot area at least 10 feet of culturally sterile soil.

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0.3 RESPONSE TO WRITTEN COMMENTS
Section 3.0 contains responses to all comment letters received on the March 2025 Draft Environmental Impact Report (Draft EIR). A total of seven comment letters were received during the comment period, which ran from March 21, 2025 to May 5, 2025. A response to each comment letter follows this introduction. A copy of each letter with bracketed comment numbers on the right margin is followed by the response for each comment as indexed in the letter.

The responses to each comment on the Draft EIR represent a good-faith, reasoned effort to address the environmental issues identified by the comments. Pursuant to Section 15088(a) of the CEQA Guidelines, the City of San Marcos (City), as lead agency, is not required to respond to all comments on the Draft EIR, but only those comments that raise environmental issues. In accordance with CEQA Guidelines Sections 15088 and 15204, the City has independently evaluated the comments and prepared the attached written responses to any significant environmental issues raised.

Letter Number Commenter Date
Agencies
1 California Department of Fish and Wildlife 5/6/25
2 Public Utilities Commission 4/22/25
3 Vallecitos Water District 3/26/25
Organizations
4 San Diego County Archaeological Society 4/14/25
Individuals
5 Emily Gonzalez 5/4/25
6 Raquel Kasprzyk 5/2/25
7 Drew Kedra 5/1/25
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1-1 1-1
LETTER 1
1-2
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1-2
Cont.
1-3
1-4
1-4
Cont.

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1-4
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1-5
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1-7
1-8

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1-8
Cont.

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1-9
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1-10
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1-10
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1-10
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1-11
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1-12
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1-12
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1-13
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1-14
1-15
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1-17
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1-19
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Letter 1
California Department of Fish and Wildlife
1-1 This comment provides opening remarks . As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-2 This comment identifies California Department of Fish and Wildlife’s (CDFW) role as both a Trustee Agency and a Responsible Agency (as defined by the California Environmental Quality Act [CEQA]) for the project. Page 2 -13 of the draft environmental impacts report (D raft EIR) notes CDFW as a Trustee Agency. If an Incidental Take Permit is required, CDFW would also be a Responsible Agency for the project. This has been noted on page 2-13 of the EIR. 1-3 This comment discusses the Natural Community Conservation Planning program. As noted in this comment, the City of San Marcos has a draft Subarea Plan. As discussed on page 3.3-11 of the Draft EIR, the City began preparing a draft of the City Subarea Plan of the Multiple Habitat Conservation Program (MHCP) in December 1999 and although the City’s Draft Subarea Plan has not yet been approved by the United States Fish and Wildlife Service (USFWS) and CDFW, the plan is a component of the adopted MHCP, and is currently being used as a guide for open space design and preservation within the City. The Draft EIR impact analysis 1-4 This comment provides a summary of the project’s objective, location, biological setting and project history. It does not raise any specific environmental issues. 1 -5 This comment recaps the biological setting of the project site, as detailed in the biological resources report and the Draft EIR. It also summarizes the proposed project impacts and mitigation measures. It does not raise any specific environmental issues. 1-6 This comment recaps the Notice of Preparation (NOP) comment letter provided by CDFW for the project on September 20, 20205. All NOP comment letters were considered during the preparation of the EIR and included in Appendix B2 of the Draft EIR. 1-7 This comment provides an introduction to specific recommendation s and comments for the project. The recommendations are provided in detail in subsequent comments and responses are provided below.
1-8 This comment states that the avoidance measures proposed in the Draft EIR are not sufficient to fully mitigate the impact to Crotch’s bumble bee and that the Draft EIR does not propose adequate compensatory mitigation for the species.

The Draft EIR included mitigation measures for Crotch’s bumble bee and determined that implementation of the mitigation measures (MM -BIO-2) would reduce impact to this species to below a level of significance. However, based upon the comments from CDFW, the mitigation measures for Crotch’s bumble bee have been revised, per CDFW recommendation. Please see responses 1-9 and 1-10, below.
1-9 This comment recommends the addition of a new mitigation measure related to obtaining an Incidental Take Permit. This language has been added into mitigation measures MM-BIO-2.

Revised mitigation measures MM-BIO-2 is presented below in a track changes format:

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MM-BIO-2 Focused surveys found the Diegan Coastal Sage Scrub on site to be occupied by Crotch’s bumble bee (CBB). Thus, there is potential for take of CBB and adverse impacts may occur through the removal of occupied habitat. However, the project would incorporate the following CBB avoidance, minimization and mitigation measures to avoid take and reduce significant impacts to below a level of significance. should the species remain a candidate for state listing. If the State ultimately does not list Crotch ’s bumble bee under the California Endangered Species Act and the species is removed from candidate status, the mitigation measures outlined below would no longer be applicable.

Incidental Take Permit:

If an Incidental Take Permit is issued, the Project applicant shall comply with the mitigation measures detailed in the take authorization issued by CDFW. In addition, the terms and conditions of that permit shall supersede any conflicting measures contained in this document. The Project applicant shall provide a copy of a fully executed take authorization prior to the issuance of a grading permit and before any ground disturbance and vegetation removal. Should the State decline to list the species under the California Endangered Species Act and remove its candidate status, this measure shall no longer be applicable, and an Incidental Take Permit will not be required.

Pre-activity surveys:
• To avoid direct impacts on CBB , removal of habitat (i.e., defined as any habitat disturbance) in the proposed area of disturbance must occur outside of the Colony Active Period (generally occurring between February 1 April 1 through August 31). If the removal of habitat in the proposed area of disturbance must occur during the Colony Active Period, a Qualified Biologist shall conduct a pre -activity (defined as any habitat disturbance) survey no more than three days prior to the initiation of construction activities to determine the presence or absence of CBB within the proposed area of disturbance following CDFW’s Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023) or Woodward 46 Specific Plan May 2025
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the latest guidance from CDFW no more than 10 days and no less than 3 days prior.

If additional activities (e.g., capture or handling) are deemed necessary to identify bumble bees of an unknown species that may be CBB , then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific Collecting Permit pursuant to CDFW Survey Considerations for CESA Candidate Bumble Bee Species (CDFW 2023). Survey methods that involve lethal take of species are not acceptable.
• If pre -activity surveys identify CBB individuals on -site, the Qualified Biologist shall notify and consult with CDFW to establish, monitor, and maintain no-work buffers around the associated floral/nest resources or identified nesting locations . The size and configuration of the no-work buffer shall be based on the best professional judgment of the Qualified Biologist in consultation with CDFW. Construction activities shall not occur within the no-work buffers until the bees appear are no longer active (i.e., associated floral resources appear desiccated and no bees are seen flying for three consecutive days indicating dispersal from the area). Take of any endangered, threatened, candidate species that results from the project is prohibited, except as authorized by State law (Fish and Game Code section 86, 2062, 2067, 2068, 2080, 2085; California Code Regulations, Title 14, section 786.9) under CESA.

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• Survey data shall be submitted by the Qualified Biologist to the California Natural Diversity Database (CNDDB) in accordance with the Memorandum of Understanding with CDFW, or Scientific Collecting Permit requirements, as applicable.

If prepared, the HMMP or other plans for Crotch’s bumble bee habitat enhancement or restoration will be provided to CDFW for review and approval.

Any land acquired as off -site mitigation to benefit CBB shall include a cost estimate for long -term management, an endowment, and a land protectio n mechanism such as a conservation easement. Mitigation lands for CBB must be occupied or include high quality suitable habitat. This species shall also be included in the Worker Environmental Awareness Program educational program described in MM-BIO-3a and BMP’s implemented per MM-BIO-3c. 1-10 This comment recommends additional revisions to the CBB mitigation. Mitigation measure MM-BIO-2 was revised to incorporate the majority of CDFW recommendations. Please see response 1-9, above, for a track changes version of MM-BIO-2. 1-11 The comment raises concerns about the environmental impacts of a proposed project on the coastal California gnatcatcher (gnatcatcher or CAGN; Polioptila californica californica), a federally threatened species and California Species of Special Concern.

The project would result in the permanent loss of high-quality foraging and nesting habitat within Diegan coastal sage scrub (DCSS), a sensitive community under the Subregional Multiple Habitat Conservation Program (MHCP). Surveys have confirmed gnatcatche r presence on-site in recent years, and the species’ non- migratory, territorial nature underscores the importance of preserving occupied habitat. The Draft EIR’s mitigation measures are inadequate, with a 1:1 habitat compensation ratio that fails to reflect the site's ecological value or ensure long -term conservation. The absence of a finalized Subarea Plan (SAP) within the City of San Marcos, financial assurances, or land protection mechanisms further undermines the proposed mitigation. Under CEQA, impacts to special status species like the gnatcatcher are considered significant unless clearly mitigated.

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Without stronger avoidance and mitigation strategies, the project risks causing substantial direct and cumulative harm to the gnatcatcher population and its habitat. CDFW’s comment has been broken down into its distinct issues and associated concerns for the purposes of this response.

The project will impact suitable foraging, nesting, and breeding habitat for CAGN, an ESA- listed threatened species and a California Species of Special Concern.

This comment reiterates the information provided in the Draft EIR. Edits to the Draft EIR not necessary. The following summarize the Draft EIR as it pertains to this comment.

As stated on page 3.3-14 of the Draft EIR, the proposed project would result in the direct loss of 5.24 acres of intact DCSS and 0.26 acre of Disturbed DCSS —habitats that CAGN use for foraging, nesting, and other life history needs. These areas have been confirmed as occupied by CAGN during previous surveys. In addition to habitat removal, the project may cause indirect impacts such as increased noise, dust, lighting, human activity, predator presence, and invasive species, all of which could lead to nest failure or mortality.

These combined direct and indirect effects are considered potentially significant (Impact BIO-1), and mitigation is required to address them.

Mitigation Measures MM-BIO-1 and MM -BIO-3 in the Draft EIR are designed to address significant impacts to the CAGN and other sensitive wildlife species. Mitigation Measure MM-BIO-1a specifically targets the protection of CAGN by requiring updated protocol surveys within the project site and a 500-foot buffer. These surveys must be conducted by a qualified biologist holding a USFWS permit. If CAGN is detected, vegetation clearing must be restricted to outside the breeding season (February 15– August 31), or pre-construction nesting surveys and protective buffers must be implemented.

Additional measures include noise monitoring to ensure construction activities do not exceed 60 dBALeq near active nests, and if necessary, operational changes or noise barriers must be installed. A long-term open space management plan is also required to minimize post-construction impacts, including public education, restrictions on invasive landscaping, and lighting controls to protect adjacent CAGN habitat.

Mitigation Measure MM -BIO-3a complements these efforts by providing broader protections for sensitive species, including CAGN. It mandates a Worker Environmental Awareness Program (WEAP) to educate construction personnel on species protections and avoidance measures. As outline d in Mitigation Measure MM -BIO-3b, construction boundaries must be clearly marked to prevent encroachment into sensitive habitats.

Mitigation Measure MM-BIO-3c requires a biological monitor must be present during vegetation clearing a nd other sensitive activities to ensure compliance and implement Best Management Practices (BMPs), such as speed limits, spill prevention, and restrictions on pets and herbicides. These practices help reduce indirect impacts like noise, pollution, and habitat degradation. Additionally, woodrat middens, which may co- occur with CAGN habitat, must be identified and avoided or passively relocated (Mitigation Measure MM-BIO-3d). Together, these mitigation measures form a comprehensive Woodward 46 Specific Plan May 2025
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strategy to avoid or minimize harm to CAGN and other sensitive species during and after project development.

Clearing and grubbing of occupied habitat may cause direct mortality of gnatcatchers.

CDFW states there are no specific avoidance measures proposed to prevent harm to individual birds during construction.

Draft EIR Mitigation Measures MM-BIO-1 and MM-BIO-3 collectively provide a robust and multi-layered approach to reducing both direct and indirect impacts to the gnatcatcher.

Through a combination of updated protocol surveys, seasonal restrictions, noise controls, habitat management, construction monitoring, and worker education, these measures are designed to avoid nest disturbance, minimize habitat degradation, and ensure long -term protection of gnatcatcher populations. When fully implemented, these measures are expected to reduce project-related impacts to the gnatcatcher to a level that is less than significant under CEQA.

The Draft EIR proposes a 1:1 mitigation ratio for habitat loss. The ratio does not account for actual gnatcatcher occupancy and use. It relies on assumptions from a not -yet- finalized SAP. No financial assurances or land protection mechanisms are included. There is no in-lieu fee program available to support gnatcatcher conservation.

The Draft EIR proposes a 1:1 mitigation ratio for the permanent loss of 5.5 acres of DCSS, including disturbed DCSS. This ratio is consistent with the mitigation standards outlined in the MHCP for areas located outside of Focused Planning Areas (FPAs). As confirmed in both the D raft EIR (Section 3.3.6, Mitigation Measure MM-BIO-6) and the Full Biological Resources Report (Appendix D), the project site is not within an FPA, and therefore, the 1:1 ratio is appropriate per MHCP guidance (Table 3, Appendix D).

Although the City of San Marcos has not yet adopted a finalized SAP, the D raft EIR’s mitigation framework is based on the adopted MHCP and its habitat group classifications.

DCSS is designated as Habitat Group C, which carries a 1:1 mitigation requirement for impacts occurring outside FPAs. The D raft EIR and supporting biological reports acknowledge the presence of suitable and historically occupied CAGN habitat on -site.

Accordingly, mitigation measures have been designed to address both direct and indirect impacts to this federally threatened species.

To ensure the effectiveness of the proposed mitigation, Mitigation Measure MM-BIO-6 requires that the 5.5 acres of DCSS be preserved through one or more of the following mechanisms: off-site acquisition, payment of in-lieu fees, or purchase of credits from an approved mitigation bank, such as the Buena Creek Mitigation Bank. These options are subject to approval by the City’s Planning Manager and the relevant Wildlife Agencies (CDFW and USFWS) prior to grading permit issuance. Additionally, any off-site mitigation must be supported by a Habitat Mitigation and Monitoring Plan (HMMP), which will include long-term management strategies, funding mechanisms (e.g., endowments), and legal land protection instruments such as conservation easements.

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Although a formal in-lieu fee program specific to gnatcatcher conservation is not currently available, the D raft EIR provides flexibility for the applicant to use approved mitigation banks or other agency - approved mechanisms that meet the biological objectives of the MHCP and CEQA. Furthermore, Mitigation Measures BIO -1 and BIO -3 include robust avoidance, monitoring , and noise attenuation measures to protect CAGN during construction and ensure compliance with federal and state wildlife protection laws.

CDFW’s concern regarding the adequacy of the proposed 1:1 mitigation ratio for permanent impacts to DCSS habitat, particularly given the potential for CAGN occupancy is acknowledged. The D raft EIR relies on the MHCP’s guidance for areas outside FPAs, which supports a 1:1 ratio for Habitat Group C.

A Low -Effect HCP for the project is being processed with the USFWS. This HCP also references a 1:1 mitigation ratio, consistent with the Draft EIR. In summary, while the proposed 1:1 mitigation ratio aligns with regional conservation planning standards for non- FPA areas. The D raft EIR includes enforceable measures to ensure that mitigation lands are biologically meaningful, legally protected, and financially supported to promote the species’ long-term conservation.

The site is known to be occupied by gnatcatchers based on multiple surveys (2018, 2020).

CDFW’s concern is that despite negative results in 2023, the species’ territorial and non- migratory behavior suggests continued use of the site. The habitat supports at least two family groups and is part of a sensitive community (DCSS). CDFW is also concerned that habitat loss may reduce the local gnatcatcher population and adjacent natural lands.

The City acknowledges CDFW’s concerns regarding potential direct and indirect impacts to CAGN populations, including those occupying adjacent lands. As stated in the Draft EIR, although no CAGN individuals, pairs, or nests were observed during the 2023 USFWS protocol surveys, previous surveys conducted in 2018 and 2020 confirmed the presence of nesting pairs and family groups within the project site and surrounding areas. The site and adjacent lands support high -quality DCSS, a sensitive vegetation community and preferred habitat for CAGN. Notably, MHCP Hardline Reserve lands —designated for long- term conservation and known to support CAGN—are located directly adjacent to the project site on the north, east, and west. These areas are particularly vulnerable to indirect impacts from development, such as increased human activity, lighting, noise, domestic pets, and invasive species.

CAGN are non -migratory, territorial, and exhibit strong site fidelity, often remaining near their natal territories. As described in the San Marcos SAP and supported by regional ecological studies, CAGN populations also fluctuate in response to climatic variability, declining during dry years and rebounding in wetter periods. This cyclical occupancy pattern, combined with the species’ territorial
behavior, supports the likelihood of intermittent site use even in the absence of recent detections.

To address both direct and indirect impacts, the Draft EIR includes a comprehensive suite of mitigation measures. These include updated protocol surveys and seasonal restrictions on vegetation clearing (MM-BIO-1a), and a long-term open space management plan (MM- BIO-1b) that incorporates educational programs to reduce pet encroachment, restrictions Woodward 46 Specific Plan May 2025
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on invasive landscaping species, and directional lighting to minimize light spillover into sensitive habitats. Additional measures include a Worker Environmental Awareness Program (MM -BIO-3a), biological monitoring and construction BMPs (MM-BIO-3c), and clearly delineated work limits to prevent encroachment into adjacent habitat (MM-BIO-3b).

The project also includes compensatory mitigation for the 5.5 acres of impacted DCSS at a 1:1 ratio (MM-BIO-6), which may be fulfilled through off-site acquisition, in-lieu fees, or mitigation bank credits, subject to approval by the City and wildlife agencies. A HMMP will guide the long-term management and legal protection of these mitigation lands.

In summary, while no CAGN were detected in 2023, the City acknowledges the species’ historical presence and the potential for continued use of the site. The proposed mitigation measures are designed to reduce impacts to less-than-significant levels under CEQA while supporting the long-term conservation of CAGN and its habitat both on -site and in the surrounding landscape.

The proposed 1:1 mitigation ratio is based on the project’s location outside the FPA.

However, this standard may not be appropriate in the absence of an adopted SAP, and the DEIR does not provide sufficient assurances for long-term habitat conservation.

The 1:1 mitigation ratio proposed in the Draft EIR is consistent with the guidance provided in the MHCP for impacts to Habitat Group C (Diegan Coastal Sage Scrub) occurring outside of a FPA. While it is acknowledged that the City of San Marcos has not yet adopted a finalized SAP, the MHCP remains an approved regional conservation framework, and its mitigation standards are used as interim guidance for project-level compliance.

The Draft EIR recognizes the importance of ensuring long-term conservation outcomes and includes Mitigation Measure MM -BIO-6, which requires that the 5.5 acres of impacted Diegan Coastal Sage Scrub be preserved through off-site acquisition, in-lieu fees, or purchase of credits from an approved mitigation bank. These options are subject to approval by the City’s Planning Manager and the wildlife agencies (CDFW and USFWS) prior to grading permit issuance. Additionally, any off-site mitigation must be supported by a HMMP, which will include long-term management strategies, funding mechanisms (e.g., endowments), and legal land protection instruments such as conservation easements.

Although the City’s SAP is not yet adopted, the Draft EIR outlines enforceable mitigation measures that ensure habitat compensation is biologically meaningful, legally protected, and financially supported.

These measures are consistent with CEQA’s requirement to reduce impacts to a less-than- significant level and align with the intent of the MHCP to support regional conservation goals. A Low-Effect HCP under review by USFWS also supports a 1:1 mitigation ratio.

Impacts to Species of Special Concern (SSC) like the gnatcatcher meet CEQA’s definition of significant impact. Without clear mitigation, the project may substantially reduce the number or restrict the range of a threatened species.

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construction surveys and seasonal restrictions on vegetation clearing (MM -BIO-1a) to avoid disrupting the species during its breeding season. Additionally, compensatory mitigation (MM -BIO-6) is required for the 5.5 acres of impacted DCSS, with a 1:1 replacement ratio through off -site acquisition, in-lieu fees, or mitigation bank credits, all subject to approval by the City and relevant wildlife agencies. Long-term habitat protection will be ensured through conservation easements and ongoing management under a HMMP. Although no CAGN were observed in 2023, the City recognizes the species’ historical presence and cyclical patterns, and the proposed measures aim to reduce environmental impacts to less -than-significant levels under CEQA while contributing to broader conservation efforts.

CDFW recommends revisions to Mitigation Measure BIO-6 in the DEIR to more effectively address impacts to the gnatcatcher and its sensitive habitat. Specifically, CDFW proposes increasing the mitigation ratio for the permanent loss of 5.5 acres of DCSS and Disturbed DCSS from 1:1 to a minimum of 3:1. This recommendation aligns with the Draft Subarea Plan for San Marcos, which prioritizes on -site mitigation, followed by off -site acquisition and mitigation credits. CDFW asserts that no in-lieu fees programs are available for CAGN and has stricken the wording from the measure. The revised measure would require the applicant to preserve 5.5 acres of occupied DCSS through approved off-site mechanisms such as mitigation banks, subject to approval by the City and Wildlife Agencies. If on -site or off-site habitat restoration is pursued, it must follow a HMMP reviewed by the Wildlife Agencies. Additionally, any off -site mitigation must include long -term management funding, legal land protection (e.g., conservation easement), and must support occupied or high-quality suitable habitat for the gnatcatcher.

This comment has been noted. As previously described, the 1:1 mitigation ratio proposed in the Draft EIR aligns with the guidance provided in the MHCP for impacts to Habitat Group C (Diegan Coastal Sage Scrub) occurring outside a FPA. While it is acknowledged that the City of San Marcos has not yet adopted a finalized SAP, the MHCP remains an approved regional conservation framework, and its mitigation standards serve as interim guidance for project-level compliance. When considered alongside the precedent set by the 13th Street Bridge Project and coordination with the USFWS for this project, the proposed 1:1 ratio remains appropriate.

Additionally, although a formal in-lieu fee program specifically for gnatcatcher conservation is not currently available, the Draft EIR allows flexibility for the applicant to use approved mitigation banks or
other agency-sanctioned mechanisms that meet the biological objectives of both the MHCP and CEQA. Nevertheless, in response to this comment, MM BIO -6 has been revised as follows:

MM-BIO-6 The permanent loss of 5.5 acres of Diegan Coastal Sage Scrub, and Disturbed Diegan Coastal Sage Scrub shall be mitigated at a minimum 1:1 ratio.

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Section 5.2.1 of the Draft Subarea Plan for San Marcos references the preferred order of mitigation to be on -site mitigation, off -site acquisition, in-lieu fees, and or mitigation credits. For mitigation purposes, the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub acreages on the project site that would be impacted have been combined as these two vegetation communities are considered to have similar sensitivity under the Multiple Habitat Conservation Program. Thus, 5.5 acres of occupied coastal California gnatcatcher Diegan Coastal Sage Scrub will be preserved by the project applicant through off-site acquisition, in lieu fees, a purchase of credits from Buena Creek Mitigation Bank or another approved mitigation bank, or a combination thereof as approved by the City of San Marcos Planning Manager and the wildlife agencies prior to issuance of the grading permit. If on site or off -site habitat mitigation will be completed by the Applicant to satisfy the compensatory mitigation requirements, it shall be carried out in accordance with a Habitat Mitigation and Monitoring Plan (HMMP) that outlines the strategy for enhancement and maintenance of the habitat for locally sensitive species occupying Diegan Coastal Sage Scrub. The HMMP will be provided to Wildlife Agencies for review and approval. Any land acquired as off -site mitigation to benefit gnatcatcher shall include a cost estimate for long-term management, an endowment, and land protection mechanism such as a conservation easement. Mitigation lands for gnatcatcher must be occupied or include high quality suitable habitat.

1-13 This comment addresses the proposed species selection for the project’s landscape plan and consistency with the planting recommendation on the Draft EIR mitigation measures and the biological resources report for the project. The project’s conditions of approval indicate the plants that are prohibited are plants in the IPC lists A and B and the project’s planting palette has been adjusted accordingly.
1-14 This comment addresses the CDFW recommended mitigation identified in the letter and the preparation of a mitigation monitoring and reporting program (MMRP). The MMRP is included in the Final EIR in Section 0.4. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-15 T his comment addresses contribution of environmental data to the California Natural Diversity Database (CNDDB). The project biologist will be responsible for submitting any required field survey results to the CNDDB. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-16 This comment addresses the CDFW filing fees. The project applicant will pay the applicable filing fee at the time the Notice of Determination is filed with the County of San Diego Recorder’s Office. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-17 This comment provides closing remarks. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted.

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1-18 This comment provides a list of references. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 1-19 This comment provides a sample mitigation monitoring and reporting program (MMRP). The MMRP for the proposed project, which includes any update to mitigation measures, is included as Section 0.4 of the Final EIR.

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2-1

2-2
LETTER 2
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Letter 2
California Public Utilities Commission
2-1 This comment provides opening remarks and describes the project and its location near an active at-grade railroad crossing and the San Marcos Civic Center SPRINTER Railway Station.

As this comment does not identify a specific environmental concern, this comment is noted and no additional response is warranted.
2-2 This comment provides background on past improvements on San Marcos Boulevard near the at-grade crossing. This comment also suggests that pedestrian and traffic improvements may be needed at San Marcos Boulevard to provide for greater safety benefits for future increases in pedestrian and vehicular activity. CPUC recommends that the city review the existing conditions and implement any needed improvement through a capital project led by the City or a condition of approval for the developments adjacent to the crossing.

A traffic study was prepared for the project (LLG 2023) and was included as Appendix J of the Draft EIR and summarized in Section 3.11 (Transportation) of the Draft EIR. The traffic study included an analysis of the intersection of Mission Road/Woodward S treet (San Marcos Boulevard) and considered existing intersection operations, the near-term (interim year 2026) scenario and the long-tern (horizon year 2050) condition. The proposed project would not have a substantial effect on this intersection as the p roject adds less than 2 second of average vehicle delay. Therefore no improvements are required at the intersection.

Additionally, based upon the traffic analysis, the project would generate approximately 276 trips crossing the tracks on San Marcos Boulevard on a typical weekday, with 21 trips during the AM peak our and 27 trips during the PM peak hour (LLG 2023). This i s not a significant amount in terms of the overall volume experienced at the crossing.

Pedestrian connectivity is already provided between the project site and the SPRINTER San Marcos Civic Center Station and nearby bus stops. A sidewalk already exists along the project frontage and there is a crosswalks at E. Mission Road and Woodward Street for pedestrians to safely cross to the SPRINTER San Marcos Civic Center Station. The project design includes pedestrian pathways internal to the project that will connect to the existing sidewalk on Woodward Street. All proposed pedestrian facilities as part of this project will be sized and constructed to current standards.(see Section 3.11, Transportation, of the EIR).

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LETTER 3

3-1
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Letter 3
Vallecitos Water District
3-1 This comment references the VWD Water and Sewer Study prepared for the project. The referenced study was included as Appendix N of the Draft EIR and summarized in Section 3.13 (Utilities and Service Systems) of the Draft EIR. All utilities impacts, including water and sewer, were determined to be less than significant.

As noted in this comment, the applicant will submit improvement and grading plans for plan check review by VWD. The project has been designed so that new trees will be installed over public water or sewer mains.

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LETTER 4

4-1
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Letter 4
San Diego County Archaeological Society
4-1 This comment addresses the archeological resources report prepared for the project. Due to the resources on the project site and the confidential nature of the archaeological resources was not included in the technical appendices. Based upon this comment, the City provided the San Diego County Archaeological Society (SDCAS) a copy of the report with the confidential information removed and/or redacted.

4-2 This comment addresses the proposed mitigation measures, specifically ensuring there is a unified set of measures for the treatment of non-Tribal cultural resources. Mitigation measure MM-CR-1 details the procedures for unanticipated discoveries and would apply to both tribal cultural resources and non-Tribal cultural resources.

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LETTER 5

5-1

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Letter 5
Emily Gonzalez
5-1 This comment provides opening remarks and does not raise any specific environmental comments. Therefore, no further response is warranted.
5-2 This comment addresses concerns that the proposed project will have on the adjacent Mission Villas development that is located immediately south of the project site. The position of the existing off -site retaining walls and the length of the tiebacks were fully considered in the design of the proposed project. The project footprint , at its closest relation to the offsite retaining wall, is 67 feet. The wall in this location is approx imately 62 feet from the adjacent property line. Where the soils anchors for the adjacent project cross property line an easement exists for those anchors and this is shown on the project plans. The proposed project would not impact the existing retaining wall or anchors.

This comment also expresses concern about the proposed blasting associated with the proposed project and the potential for impact to adjacent properties. A geotechnical study was prepared for the project site and determined that there is Cretaceous age plutonic bedrock on the site. Due to these bedrock conditions, blasting will be required. A project -specific noise study was prepared for the project and included as Appendix K and summarized in Section 3.9 (Noise) of the Draft EIR. The noise study was prepared by Ldn Consulting, which is a qualified subconsultant on the City’s Pre -Screened California Environmental Quality Act (CEQA) Consultant List.

Potentially significant construction-related noise impacts were identified related to rock drilling and blasting (Impact N-1) and rock crushing (Impact N-2). Mitigation measures (MM-N-1 and MM-N-2) were identified to reduce these impacts to below a level of significance. In addition, the proposed project would be required to comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and blasting would only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. Blasting also requires issuance of a Blasting Permit from the San Marcos Fire Department.

The noise study also analyzed the potential for vibration impacts from proposed grading and blasting. As detailed in Table 3.9 -15 (Vibration Levels from General Construction Activities at Residential Receptors), the construction-related vibration levels would be less than significant.

Vibration from blasting on nearby residential structures (non-engineered timber and masonry buildings) was determined to be less than significant (page 3.9-20 of the Draft EIR). If blasting is required within 250 feet of exis ting residences, the potential annoyance may not be completely avoided, but it can be minimized by following the City’s blasting procedures , including proper notice to residences. Short term blasting vibration impacts would be less than significant.
5-3 This comment addresses biological resources, including potential impacts to hawks, squirrels and coyotes. A biological resources report and specific surveys for rare plants, coastal California gnatcatcher and Crotch’s bumble bee were prepared for the project and included as Woodward 46 Specific Plan May 2025
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Appendices D.1, D.2, D.3 and D.4 and summarized in Section 3.3 (Biological Resources) of the Draft EIR. The report was prepared by Rincon Consultants, which is a qualified subconsultant on the City’s Pre-Screened CEQA Consultant List.

As disclosed on page 3.3 -16 of the Draft EIR, t he project could impact raptors and other nesting birds, including Cooper ’s hawk and Southern California rufous -crowned sparrow, respectively, if construction occurs while they are actively nesting on or adjacent to the project site (January-August). Impacts could occur through direct mortality with vegetation removal and grading or indirectly by nest abandonment, due to construction activities associated with the project such as noise, dust, nighttime lighting, human presence/disturbance, and an increase in predators (Impact BIO-4). The project will implement mitigation measure MM-BIO- 4, detailed below, which will minimize impacts to nesting birds and raptors.

MM-BIO-4 If site clearing activities are conducted between January 1 and August 31, a qualified biologist shall conduct a nesting bird survey no more than 3 days prior to the start of such activities to identify actively nesting birds within the project site and a 500-foot buffer around the project site. If any nests are found, their locations shall be flagged and an appropriate avoidance buffer, ranging in size from 25 to 50 feet for passerines, and up to 500 feet for raptors depending upon the species and the proposed work activity. The non -disturbance buffer zone shall be determined and demarcated by a qualified biologist with bright orange construction fencing or other suitable flagging materials. Active nests shall be monitored at a minimum of once per week until it has been determined that the nest is no longer being used by either the young or adults. No disturbance shall occur within this buffer until the qualified biologist confirms that breeding/nesting is completed, and all the young have fledged. If project activities must occur within the buffer, activities shall be conducted at the discretion of the qualified biologist and with monitoring and management to confirm that nesting birds and the nests are not disturbed. If no nesting birds are observed during the nesting survey or during other monitoring activities, then no further actions shall be necessary. A follow-up survey will be needed if site clearing does not occur within 3 days after the initial survey and/or a pause in construction activity occurs for more than 7 days.

During the biological resources site survey, coyote ( Canis latrans) scat was observed on the project site. This species is not have any protected status from the state or federal government.

Similarly, ground squirrels do not have any special status.

In summary, the project’s biological resources impacts would be mitigated to below a level of significance.
5-4 This comment provides closing remarks and does not raise any additional environmental concerns. The environmental topics raised in the commenter’s letter were already analyzed in the EIR and all impacts were determined to be less than significant or mitig ated to below a level of significance.

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LETTER 6

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Cont.
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Cont.
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Letter 6
Raquel Kasprzyk

6-1 This comment provides opening remarks and raises a general concern about impacts to current and future residents and to wildlife. More detailed comments on these topics are presented in the letter and detailed responses are provided below. 6-2 This comment expresses concern about air pollution, water runoff and flooding, and water quality. Each of these topics were analyzed in the Draft EIR and impacts were determined to be less than significant.

A project-specific air quality analysis was prepared for the project and included as Appendix C of the Draft EIR and summarized in Section 3.2 (Air Quality) of the Draft EIR. The air quality report was prepared by Ldn Consulting, which is a qualified subconsultant on the City’s Pre - Screened California Environmental Quality Act (CEQA) Consultant List. The air quality analysis considered all phases of project construction, including blasting and grading. The analysis also considered the operational emissions of the project. Construction emissions would be below all screening level thresholds for criteria pollutants, as detailed in Table 3.2 -6 (Construction Emissions). Similarly, operational emissions were also determined to be less than significant, as detaile d in Table 3.2- 7 (Operational Emissions) of the Draft EIR. Regarding community health, the air quality analysis also analyzed if the project would expose sensitive receptor, such as adjacent residents, to substantial pollutant concentrations, and impacts w ere determined to be less than significant (pages 3.2-18 and 3.2-19 of the Draft EIR).

This comment also addresses water runoff and flooding. A project -specific hydrology report and storm water quality management plan were prepared for the project and included in Appendix H and Appendix I of the Draft EIR and summarized in Section 3.7 (Hydro logy/Water Quality) in the Draft EIR. The analyses considered the site -specific hydrology and drainage characteristics both in the existing condition and proposed condition. The analysis concluded that hydrology and water quality impacts would be less than significant. The proposed project would construct two biofiltration basins (BMP -A and BMP -B) for storm water quality and hydromodification, which would be located at the northeast corner and northwest edge of the project site. These features would collect storm water from the buildings and street and direct the storm water through storm water drainage pipes to existing points of confluence , in conformance with the 2023 City of San Marcos BMP Design Manual. As such, stormwater flows from the project site would be managed to ensure that runoff rates and quantities in the post condition do not exceed the rate and quantities in the current condition. Graded areas would be replanted per the conceptual landscape plan.
6-3 This comment addresses the existing retaining wall associated with the Mission Villas development that is located immediately south of the project site. The position of the existing off-site retaining walls and the length of the tiebacks were fully considered in the design of the proposed project. The project footprint, at its closest relation to the offsite retaining wall, is 67 feet. The wall in this location is approximately 62 feet from the adjacent property line. Where Woodward 46 Specific Plan May 2025
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the soils anchors for the adjacent project cross property line an easement exists for those anchors and this is shown on the project plans. The proposed project would not impact the existing retaining wall or anchors.
6-4 This comment addresses light pollution. Lighting and light pollution was a nalyzed in Section

3.1 (Aesthetics) of the Draft EIR and the Conceptual Lighting Plan was included in Appendix A4 (Landscape Plan) of the Draft EIR. The project’s lighting design includes pole lights, accent lighting for monuments and trees, building lights and a back -lit fire directory. Lighting regulations are included in Section 3.4.1 of the Woodward 46 Specific Plan (included as Appendix A1 of the Draft EIR) and require that lighting fixture are directed and shielded so as to not illuminate surrounding properties. The lighting and glare analysis in the Draft EIR determined the project impacts related to lighting and glare would be less than significant (page 3.1-7 of the Draft EIR) . Finally, lighting would be required to conform with the City’s lighting ordinance and standards, (San Marcos Municipal Code Title 20, Section 20.300.080). 6-5 This comment addresses potential noise impacts associated with project construction including blasting. A project-specific noise study was prepared for the project and included as Appendix K and summarized in Section 3.9 (Noise) of the Draft EIR. The noise study was prepared by Ldn Consulting, which is a qualified subconsultant on the City’s Pre -Screened CEQA Consultant List. Potentially significant construction-related noise impacts were identified related to rock drilling and blasting (Impact N -1) and rock crushing (Impact N-2). Mitigation measures (MM-N-1 and MM-N-2) were identified to reduce t hese impacts to below a level of significance. In addition, the proposed project would be required to comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and blasting would only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday.

Blasting also requires issuance of a Blasting Permit from the San Marcos Fire Department.

This comment also addresses potential noise from future occupants of the proposed project.

Residents of the future project, as with all residents in San Marcos, would be subject to noise requirements of the City’s Municipal which addresses nuisance noise. 6-6 This comment suggests that the proposed project would make the environment hotter for adjacent development by blocking off air flow. The proposed project will develop approximately

2.7 acres of the 8.57 acres project site. The proposed development is not of a size or height that would result in a change of wind flow patterns. Further, there will be open space between the future homes on the project site and the adjacent Mission Villa community, which will allow for the movement of air. Additionally, the project will implement a landscape plan (see Appendix A4 of the Draft EIR), which include planting approximately 240 trees, plus shrubs, vines and ground cover. These trees and plants will provide for a cooling effect. 6-7 This comment addresses traffic and pedestrian movement on Woodward Street. Pedestrian connectivity is already provided between the project site and the SPRINTER San Marcos Civic Center Station and nearby bus stops. A sidewalk already exists along the project frontage and there is a crosswalks at E. Mission Road and Woodward Street for pedestrians to safely cross to the SPRINTER San Marcos Civic Center Station. The project design includes pedestrian pathways internal to the project that will connect to the existing sidewalk on Woodward Street.

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All pedestrian facilities proposed as part of this project will be sized and constructed to current standards (see Section 3.11, Transportation, of the EIR).

A local transportation analysis was prepared for the project and was included in Appendix J and summarized in Section 3.7 (Land Use and Planning) in the Draft EIR. A vehicle miles traveled assessment was also prepared for the project and included as Appendix M and summarized in Section 3.11 (Transportation) of the Draft EIR. These reports were prepared by Linscott, Law and Greenspan, which is a qualified subconsultant on the City’s Pre -Screened California Environmental Quality Act (CEQA) Consultant List. Traffic impacts were determined to be less than significant.
6-8 This comment addresses housing affordability and parking. The project proposes a total of 108 on-site parking spaces. This includes two -car garages for each residential unit and 16 open parking spaces. The open parking spaces would be located throughout the project area. 6-9 This comment addresses noise including noise from roadways, the SPRINTER, and planes. As part of the noise analysis, ambient noise measurements were take on the project site. The noise analysis prepared for the project (see Section 3.9, Noise) considered noise from area roadways and the SPRINTER. Impacts were determined to be less than significant.

This comment also addresses light pollution. Please see response 6-4, above, for a response on light pollution.
6-10 This comment addresses biological resources, including wildlife species, wildlife movement, noise and light impacts wildlife.

A biological resources report and specific surveys for rare plants, coastal California gnatcatcher and Crotch’s bumble bee were prepared for the project and included as Appendices D.1, D.2, D.3 and D.4 and summarized in Section 3.3 (Biological Resources) of the Draft EIR. The report was prepared by Rincon Consultants, which is a qualified subconsultant on the City’s Pre - Screened CEQA Consultant List.

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The potential for the project to impact wildlife movement and wildlife corridors was analyzed in Section 5.3 of the Draft EIR. 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. 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. The project area is also not within or adjacent to a Biological Core and Linkage Area as illustrated in Figure 2-3 of the Final Multiple Habitat Conservation Program (MHCP) Plan . Impact to wildlife movement and wildlife corridors was determined to be less than significant (page 5-4 of the Draft EIR).

Regarding the potential for noise impacts to wildlife, the project incorporate s biological resources mitigation measures (MM-BIO-1a and MM-BIO-4) to ensure that impacts to sensitive species are minimized. These measures require preconstruction surveys if vegetation removal is proposed during the nesting season for coastal California gnatcatcher (CAGN), nesting birds and raptors. If nests are found, no- disturbance buffers will be identified (MM -BIO-4) and for CAGN, noise monitoring would be required (MM-BIO-1a).

Consistent with mitigation measure MM -BI-O-1b, the project would implement a long -term open space management plant. The plan would require that permanent residential lighting be directed away from the open space.

In summary, all of the project’s biological resources impacts would be mitigated to below a level of significance.
6-11 This comment addresses pesticide use. Biological resources mitigation measure MM -BIO-3c addresses standard construction best management practices, which includes no use of herbicide and pesticides during project construction. During project operation, pesticides and herbicides may be used by future homeowners or by the home owners association (HOA).

California Civil Code Section 4777(b) regulates what an HOA must do to use certain herbicides or pesticides, which includes providing advance notice in writing to homeowners if they are spreading chemicals over more than two square feet.
6-12 This comment addresses air flow in the project vicinity. Please see response 6-6, above. 6-13 This comment addresses vegetation removal on the project site. The project will remove vegetation during project grading and to prepare the site for development. As detailed in the Section 3.3. (Biological Resources), the project will result in the permanent loss of 5.5 acres of Diegan coastal sage scrub. However, th e project will mitigate this loss at a minimum 1:1 ratio through either on-site mitigation, off-site acquisition, in-lieu fees, and mitigation credits.

Additionally, the project will implem ent a landscape plan (see Appendix A4 of the Draft EIR) , which include planting approximately 240 trees, plus shrubs, vines and ground cover. Finally, a Climate Action Plan Consistency Review Checklist was prepared for the project and included Woodward 46 Specific Plan May 2025
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in Appendix F of the Draft EIR. A greenhouse gas (GHG) analysis was included in Section 5.6 of the Draft EIR. The analysis concluded that the GHG impacts would be less than significant (page 5-5 of the Draft EIR).
6-14 This comment suggests an alternative project at an alternative location. Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for an alternative location 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 proponent 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 transportation 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 (See Section 4.4.1 of the Draft EIR).

The commenter suggests developing affordable housing at 528 E. Mission Road instead of developing the project site. The E. Mission Road parcel is located in the Transitional L-I/NC (Light Industrial/Neighborhood Commercial) zone and there is a pending development application associated with a Site Development Permit for an industrial development. That project is still under review.

Finally, it should be noted that the Draft EIR included an analysis of alternative in Chapter 4.

Alternatives considered included:
• 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)
6-15 This comment provides closing remarks and does not raise any new environmental comments.

Therefore, no further response is warranted.

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7-1

7-2
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LETTER 7
7-7

7-8

7-9

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7-9
Cont.

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Letter 7
Drew Kedra
7-1 This comment provides opening remarks. As this comment does not identify a specific environmental concern, this comment is noted, and no additional response is warranted. 7-2 This comment addresses impacts to the natural environment, scenery, wildlife, green spaces and habitat. A biological resources report and specific surveys for rare plants, coastal California gnatcatcher and Crotch’s bumble bee w ere prepared for the project and included as Appendices D.1, D.2, D.3 and D.4 and summarized in Section 3.3 (Biological Resources) of the Draft EIR. The report was prepared by Rincon Consultants, which is a qualified subconsultant on the City’s Pre -Screened C alifornia Environment al Quality Act (CEQA) Consultant List.

The Draft EIR discloses the impacts to habitat and the potential impacts to sensitive species and identifies mitigation measures to reduce all biological resources impacts to below a level of significance. The project site was contemplated as a residential use in the Heart of the City Specific Plan, which was the guiding land use document at the time the project was proposed.

The project would develop residential uses at a similar density as the current designation, but implements a design that clusters the development, which allows for a larger area of open space.

This comment also addresses proposed blasting for the project. A geotechnical study was prepared for the project site and determined that there is Cretaceous age plutonic bedrock on the site. Due to these bedrock conditions, blasting will be required. Pote ntial noise impacts related to blasting were identified and mitigation measures were identified to reduce impacts to below a level of significance. T he proposed project would comply with all provisions identified in the City’s Municipal Code Section 17.60 .06 as it relates to blasting and blasting would only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday.

Blasting also requires issuance of a Blasting Permit from the San Marcos Fire Department. The proposed project ’s requested approvals include a Conditional Use Permit (CUP22 --0005), which would allow for the use of the temporary rock crusher. The rock crusher would be located in the central portion of the site to provide the most distance from adjacent residential uses.

The crusher would be approximately 329 feet from the residential use to the east, 667 feet from the closest residential use to the north and 531 feet from the closest residential use to the south.
7-3 This comment addresses the existing retaining wall associated with the Mission Villas development that is located immediately south of the project site. The position of the existing off-site retaining walls and the length of the tiebacks were fully considered in the design of the proposed project. The project footprint at its closest relation to the offsite retaining wall is 67 feet. The wall in this location is approximately 62 feet from the adjacent property line. Where the soils anchors for the adjacent project cross property line an easement exists for those anchors and this is shown on the project plans. The proposed project would not impact the existing retaining wall or anchors.

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7-4 This comment addresses the potential for the project to impact drainage and flooding due to the remov al of vegetation. A project -specific hydrology report and storm water quality management plan were prepared for the project and included in Appendix H and Appendix I of the Draft EIR and summarized in Section 3.7 (Hydrology/Water Quality) in the Draft EIR. The analyses considered the site -specific hydrology and drainage characteristics both in the existing condition and proposed condition. The analysis concluded that hydrology and water quality impacts would be less than significant. T he proposed project would construct two biofiltration basins (BMP-A and BMP-B) for storm water quality and hydromodification, which would be located at the northeast corner and northwest edge of the project site. These features would collect storm water fr om the buildings and street and direct the storm water through storm water drainage pipes to existing points of confluence , in conformance with the 2023 City of San Marcos BMP Design Manual. As such, stormwater flows from the project site would be managed to ensure that runoff rates and quantities in the post condition do not exceed the rate and quantities in the current condition. Graded areas would be replanted per the conceptual landscape plan.
7-5 This comment addresses pollution during and after construction , including equipment emission, waste from work crews, dust and debris from blasting, noise pollution and light pollution.

Similarly, operational emissions were also determined to be less than significant, as detailed in Table 3.2-7 (Operational Emissions) of the Draft EIR.

A project-specific noise study was prepared for the project and included as Appendix K and summarized in Section 3.9 (Noise) of the Draft EIR. The noise study was prepared by Ldn Consulting, which is a qualified subconsultant on the City’s Pre-Screened CEQA Consultant List.

Regarding the potential for waste f rom work crews, biological resources mitigation measure MM-BIO-3c addresses standard construction best management practices, which include s removing trash from the site daily or having it be stored in a wildlife-proof container.

Lighting was addressed in Section 3.1 (Aesthetics) of the Draft EIR and the Conceptual Lighting Plan was included in Appendix A4 (Landscape Plan) of the Draft EIR. The project design includes pole lights, accent lighting for monuments and trees, building lights and a back-lit fire directory. Lighting regulations are included in Section 3.4.1 of the Woodward 46 Specific Plan (included as Appendix A1 of the Draft EIR) and require that lighting fixture be directed and Woodward 46 Specific Plan May 2025
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shielded so as to not illuminate surrounding properties. The lighting and glare analysis in the Draft EIR determined the project impacts related to lighting and glare would be less than significant. Finally, lighting would be required to conform with the City’s lighting ordinance and standards, (San Marcos Municipal Code Title 20, Section 20.300.080). 7-6 This comment addresses the timing of other development in the project vicinity. The proposed project will require permits from wildlife agencies. Grading will not start until those permits are secured. Once grading starts, the project would be constructed in one phase. Delays are not anticipated.
7-7 This comment addresses the type of residen ces to be constructed, affordability and home sales. T his comment does not identify a specific environmental concern , The comment is noted, and no additional response is warranted.
7-8 This comment addresses noise, including noise from roadways, the SPRINTER, and planes. As part of the noise analysis, ambient noise measurements were take on the project site. The noise analysis prepared for the project (see Section 3.9, Noise) considered noise from area roadways and the SPRINTER. Impacts were determined to be less than significant.

Per Exhibit III-1 (Compatibility Policy Map: Noise) of the McClellan-Palomar Airport Land Use Compatibility Plan, 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). According to the McClellan-Palomar ALUCP, the project site partially lies within Review Area 2 of the airport influence area. The influence area is regulated by the Airport Land Use Commission (ALUC), which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over -flight factors through review of development proposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain. Resi dential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights. The location of the project within Review Area 2 would be disclosed to future buyers/residents. 7-9 This comment addresses quality of life aspects of adjacent neighbors, including loss of views and noise. CEQA does not require an analysis of private views. Section 3.1 (Aesthetics) of the Draft EIR provided photo simulations of the proposed development from area roadways (see Figure 3.1-1 through 3.1-7) to show the level of visual change from public areas. The project would not conflict with any applicable zoning or other regulations governing scenic quality and impacts were determined to be less than significant.

Regarding noise from parties or other disturbance, r esidents of the future project would be subject to noise requirements of the City’s Municipal which addresses nuisance noise. 7-10 This comment addresses seismic issues. A geotechnical report was prepared for the project and included as Appendix G of the Draft EIR and summarized in Section 3.7 (Geology and Soils) of the Draft EIR. As detailed in Table 2 -2 (Project Design Features) of the Draft EIR the project will implement all recommendations from the preliminary geotechnical investigation (GeoTek 2019). These recommendations include general provisions related to earthwork, and Woodward 46 Specific Plan May 2025
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design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, and post -construction considerations. The detailed recommendations are included in Chapter 5 of the geotechnical report, which is included as Appendix G of the Draft EIR. 7-11 This comment addresses the visual landscape of the project vicinity and recommends not developing on the project site. The project site has long been contemplated as a residential use, as detailed in the Heart of the City Specific Plan (HOCSP). The project proposes a developed density that is similar to what was identified in the HOCSP, however the project design clusters the development, which allows for a larger area of open space. The Draft EIR included an aesthetics analysis (Section 3.1, Aesthetics) and impacts were determined to be less than significant.
7-12 This comment does not identify a specific environmental concern, this comment is noted, and no additional is warranted.

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0.4 MITIGATION MONITORING AND REPORTING

PROGRAM

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

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

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

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

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Table 0.4-1. Mitigation Measures
Woodward 46 Specific Plan Mitigation Monitoring and Reporting Program

Impact Mitigation Measure Action Timing Responsibility

BIOLOGICAL RESOURCES
BIO-1: The proposed
project has the potential
to result in direct and
indirect impacts to
coastal California
gnatcatcher.

MM-BIO-1a An updated presence/absence protocol survey of the project site and a 500-foot buffer around the project site shall be conducted by a qualified biologist with a valid United States Fish and Wildlife Service 10(a)(1)(A) permit to further evaluate the coastal California gnatcatcher (CAGN) territories that could be affected by short term project construction activities, including vegetation clearance, and long term habitat loss and indirect impacts. In accordance with the USFWS survey protocol, a minimum of six breeding season surveys shall be conducted at least 1 week apart from March 15, through June 30, pending the anticipated construction timeline for the project.

The results of the survey shall be submitted to the City and USFWS upon completion.

Vegetation clearance may continue with regular biological monitoring if there is no indication of disturbance to the nest(s).

If the vegetation clearance is potentially disruptive to active nests a larger buffer may be implemented as determined by the qualified biologist. If CAGN are observed moving through the area during vegetation clearing activities, the project biologist Conduct CAGN
protocol surveys and
submit results to City
and USFWS.

Protocol surveys
to occur
between March
15 and June 30
prior to
construction.

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may delay the removal of vegetation and/or grading until CAGN has left the area of their own volition.

All active nests
will be reported
within 24 hours
to the USFWS
upon detection.

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between the nesting coastal CAGN and the activities,
and working in other areas until the young have fledged.

All active nests will be reported within 24 hours to the USFWS upon detection.

MM-BIO-1b Long-Term Open Space Management
A long-term open space management plan shall be developed to minimize impacts of the residential development on the adjacent coastal California gnatcatcher (CAGN) and Diegan Coastal Sage scrub habitat. The adjacent area falls within a Multiple Habitat Conservation Program Hardline Reserve, occupied by CAGN, and additional mitigation measures are necessary to minimize impacts associated with increased human and domestic pet presence from the project. The plan shall include a program of education to reduce domestic and feral cat encroachment (using the program developed by the American Society for the
Prevention of Cruelty to Animals). Use of invasive exotic plant species in landscaped areas adjacent to or near sensitive vegetation communities shall be restricted. The applicant shall encourage the use of native species in the landscaping plan and shall avoid the use of species listed in Lists A & B of the California Invasive Plant Council's list of Exotic Pest Plants of Greatest Ecological Concern in California as of October 1999.

Develop long-term
open space
management plan.

Prior to issuance
of Grading
Permit.

Applicant/
Landowner, Project
Biologist.

BIO-2: Focused surveys
found the Diegan Coastal
MM-BIO-2 Focused surveys found the Diegan Coastal Sage
Scrub on site to be occupied by Crotch’s bumble bee (CBB).

Consultation with
CDFW regarding
Prior to notice to
proceed for any
Applicant/
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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.

Avoidance, Minimization, and Mitigation Measure for Crotch’s Bumble Bee
Prior to the Notice to Proceed (NTP) for any construction permits, including but not limited to, the first Grading Permit, The City shall verify the following project requirements regarding the CBB are shown on the construction plans. Should this species no longer be a potential candidate for listing at the time of the preconstruction meeting, then no avoidance measures shall be required.

Implement
avoidance measures
for CBB

Implement MM-BIO-6
and MM-BIO-3a and
3c.
construction
permits,
including
issuance of
Grading Permit.

Landowner, Project
Biologist.

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a grading permit and before any ground disturbance and
vegetation removal. Should the State decline to list the species under the California Endangered Species Act and remove its candidate status, this measure shall no longer be applicable, and an Incident al Take Permit will not be required.

Pre-activity surveys:
• To avoid direct impacts on CBB , removal of habitat (i.e., defined as any habitat disturbance) must occur outside
of the Colony Active Period (generally occurring between February 1 through August 31). If the removal of habitat must occur during the Colony Active Period, a Qualified Biologist shall conduct a pre-activity survey no more than three days prior to the initiation of construction activities to determine the presence or absence of CBB within the
proposed area of disturbance following CDFW’s Survey
Considerations for California Endangered Species Act
Candidate Bumble Bee Species (CDFW 2023) or the
latest guidance from CDFW no more than 10 days and no
less than 3 days prior.

Resumes shall be provided to CDFW for review.

• The pre-activity survey shall consist of non-lethal photo vouchers following California Department of Fish and
Wildlife (CDFW) guidance (CDFW 2023). he surveys shall
consist of passive methods unless a Memorandum of
Understanding is obtained. The Qualified Biologist shall Woodward Specific Plan May 2025
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send all photographic vouchers to a CDFW approved
taxonomist to confirm the identifications of the bumble bees encountered during surveys. If candidate bumble
bees will be captured or handled during surveys, then the Qualified Biologist shall obtain the required authorization via a Memorandum of Understanding or Scientific
Collecting Permit pursuant to CDFW guidance (CDFW
2023).

Construction activities shall not occur within the no- work buffers until the bees appear are no longer active (i.e ., associated floral resources appear desiccated and no
bees are seen flying for three consecutive days indicating dispersal from the area). Take of any endangered,
threatened, candidate species that results from the
project is prohibited, except as author ized by State law (Fish and Game Code section 86, 2062, 2067, 2068,
2080, 2085; California Code Regulations, Title 14,
section 786.9) under CESA.

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Compensatory Mitigation for Impacts to Crotch’s Bumble Bee Habitat
Should the species be formally listed, or remain a candidate for listing, mitigation for the loss of CBB occupied Diegan Coastal Sage Scrub shall be conducted to reduce impacts to less than significant. This mitigation will be carried out in conjunction with the Diegan coastal sage scrub mitigation described in MM -BIO-6.

Specifically, the Diegan coastal sage scrub mitigation shall include habitat compensation at a minimum 1:1 ratio or as negotiated through consultation with the CDFW for an Incidental Take Permit, to also benefit the CBB. This mitigation may be satisfied through off-site acquisition, in lieu fees, purchase of credits from an approved mitigation bank, or a combination thereof. If necessary, habitat enhancement or restoration also may be incorporated, to be described in a Habitat Management and Monitoring Plan (i.e. planting of native Diegan coastal sage scrub flowering plant species known to support bumble bee populations, removal of invasive species, etc.). If prepared, the HMMP or other plans for Crotch’s bumble bee habitat enhancement or restoration will be provided to CDFW for review and approval. Any land acquired as off-site mitigation to benefit CBB shall include a cost estimate for long-term management, an endowment, and a land protectio n mechanism such as a conservation easement. Mitigation lands for CBB must be occupied or include high quality suitable habitat.

This species shall also be included in the Worker Environmental Awareness Program educational program described in MM-BIO-3a and BMP’s implemented per MM-BIO-3c.

BIO-3: The proposed
project has the potential
to result in direct and
indirect impact to
special-status wildlife
species including Orange-
MM-BIO-3a Worker Environmental Awareness Program (WEAP) The applicant shall implement a Worker Environmental
Awareness Program (WEAP) for the construction crew that will be developed by a qualified biologist. Each employee (including temporary, contractors, and subcontractors) will receive the WEAP presentation on the first day of project work. They will be Implement WEAP Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

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throated whiptail, coastal
whiptail, Southern
California rufous-crowned
sparrow, Cooper’s hawk,
Crotch’s bumble bee,
and Bryant’s woodrat.

advised of sensitive species in the area and avoidance measures being implemented to protect them at the site. At a minimum, the WEAP will include the following topics: occurrence of the listed and sensitive species in the area, their general ecology, sensitivity of the species to human activities, legal protection afforded these species, penalties for violations of federal and State laws, reporting requirements, and project features and conditions designed to reduce direct and indirect impacts to these species, role of the Biological Monitor, and worker responsibilities to maintain compliance with mitigation measures while working at the site.

MM-BIO-3b Work Limit Delineations Approved construction work area limits shall be delineated and marked clearly, by flagging or temporary orange construction fencing, in the field prior to vegetation removal. The marked boundaries shall be maintained and clearly visible to personnel on foot and by heavy equipment operators. Fencing shall be placed on the impact side of the work area to reduce the potential for encroachment and
additional vegetation loss within adjacent open space. Fencing shall be put in place by a qualified surveyor per the project applicant’s approved construction and grading plans. All temporary fencing shall be removed only after the conclusion of all grading, clearing, and construction. Employees shall strictly limit their activities and vehicles to the designated project areas, staging areas, and routes of travel. The biological monitor shall verify that the limits of construction have been properly staked and are readily identifiable. Intrusion by unauthorized vehicles outside of construction limits shall be prohibited, with control exercised by an on-site foreman. Access routes to the
construction area outside of work hours shall be blocked with physical barriers, such as concrete blocks or large equipment.

Delineate work area
limits
Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

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whiptails, coastal whiptails, Bryant’s woodrat, Coopers hawks, and southern rufus-crowned sparrow, nesting birds, and any other sensitive plant or wildlife resource, and will monitor the project for avoidance of unanticipated impacts to the
aforementioned species and their habitats. Standard
construction Best Management Practices will be implemented by the contractor to minimize potential impacts to sensitive species.

 Vehicle speeds will not exceed 10 miles per hour (mph) adjacent to CAGN habitat. Clear signage will be installed and maintained throughout the construction period.

Placement of drip pans under parked equipment and
vehicles.

 Regular inspection and maintenance of equipment to avoid spills and immediate containment of any spills.

 Chemicals and pesticides will not be used.

 Pets and firearms will not be allowed at the site.

 Trash will be removed from the site daily or be stored in wildlife proof containers

Review/approve
landscape plans.

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 Staging/storage areas for equipment and materials will be located at least 100 feet away from the riparian areas.

Equipment will be checked and maintained daily to prevent leaks of pollutants into the wetlands.

 No equipment maintenance will be carried out within 100 feet of the riparian area.

 Any construction lighting will be directed toward the work area and away from adjacent habitats.

MM-BIO-3d Woodrat Middens Woodrat middens (nests) are
large nests or dens made of woody debris, such as sticks, dead cacti, and bark. Middens were observed throughout the project site and within the project impact area. The project may contain both big-eared woodrat Bryant’s woodrat and all middens will be treated as potentially sensitive. Within 30 days of initial site disturbance, a pre-construction survey shall be conducted for woodrat middens. All occupied woodrat middens shall be
mapped and flagged for avoidance to the extent feasible, with a minimum of 10-feet surrounding the active midden. If avoidance is not feasible, middens will be disturbed “daylighted” by a qualified biologist one night before anticipated vegetation removal to allow for the rats to escape and passively relocate prior to disturbance of the area.

Conduct Pre-
Construction survey
for woodrat middens;
if present, follow
avoidance and
minimization
measures.

Within 30 days
of initial site
disturbance and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

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BIO-4: The proposed
project has the potential
to impact nesting birds
and raptors that are
afforded protection
under the California Fish
and Game Code and the
Migratory Bird Treaty Act.

MM-BIO-4 If site clearing activities are conducted between January 1 and August 31, a qualified biologist shall conduct a nesting bird survey no more than 3 days prior to the start of such activities to identify actively nesting birds within the project site and a 500-foot buffer around the project site. If any nests are found, their locations shall be flagged and an appropriate avoidance buffer, ranging in size from 25 to 50 feet for passerines, and up to 500 feet for raptors depending upon the species and the proposed work activity. The non-disturbance buffer zone shall be determined and demarcated by a qualified biologist with bright orange construction fencing or other suitable flagging materials. Active nests shall be monitored at a minimum of once per week until it has been determined that the nest is no longer being used by either the young or adults. No disturbance shall occur within this buffer until the qualified biologist confirms that breeding/nesting is completed, and all the young have fledged. If project activities must occur within the buffer, activities shall be conducted at the discretion of the qualified biologist and with monitoring and management to confirm that nesting birds and the nests are not disturbed. If no nesting birds are observed during the nesting survey or during other
monitoring activities, then no further actions shall be necessary.

A follow-up survey will be needed if site clearing does not occur within 3 days after the initial survey and/or a pause in construction activity occurs for more than 7 days.

If site clearing
activities occur
during breeding
season, conduct a
pre-construction
survey. If nesting
birds are present,
implement buffer
zone and avoidance
measures.

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

For construction
activities
proposed for the
period of
January 1
through August
31, conduct
survey within
three days prior
to the start of
construction
activities.

Applicant/
Landowner, Project
Biologist,
Contractor.

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.

Implementation of mitigation measures MM-BIO-3a through MM- BIO-3d, described above would reduce potential indirect impacts to sensitive species.

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BIO-6: The proposed
project would impact

5.24 acres of Diegan
coastal sage scrub and

0.26 acre of disturbed
Diegan coastal sage
scrub for a total of 5.50
acres of impact.

If on site or off-site habitat mitigation will be completed by the Applicant to satisfy the compensatory mitigation requirements, it shall be carried out in accordance with a Habitat Mitigation and Monitoring Plan (HMMP) that outlines the strategy for
enhancement and maintenance of the habitat for locally
sensitive species occupying Diegan Coastal Sage Scrub. The HMMP will be provided to the Wildlife Agencies for review and approval. Any land acquired as off-site mitigation to benefit gnatcatcher shall include a cost estimate for long-term maintenance, and endowment, a land protection mechanism such as a conservation easement. Mitigation lands for
gnatcatcher must be occupied or include high quality suitable habitat.

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

Prior to issuance
of Grading
Permit.

Applicant/
Landowner, Project
Biologist.

CULTURAL RESOURCES
CR-1 Due to grading
and ground disturbing
activities, the project has
the potential to impact
MM-CR-1 Unanticipated Discovery Procedures. In the event of the unanticipated discovery of cultural resources, all ground disturbing activity at that location shall temporarily halt or be diverted. Ground disturbing activities shall be temporarily If potential cultural
resources are found,
provide
documentation that
During all earth
moving and
ground
Applicant/
Landowner,
Archaeologist,
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Impact Mitigation Measure Action Timing Responsibility
unidentified
archeological resources
on the project site.

directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. A Qualified Archaeologist shall be retained to assess the discovery. If the resource is determined to be associated with Native American culture, it will be considered a tribal cultural resource and subject to MM-TCR-8. Non-Native American resources discovered during construction shall follow the procedures below. If a discovery of a previously unknown resource is determined to be both a tribal cultural resource and a potentially significant archaeological resource that is associated with Native American culture, then the Qualified Archaeologist, Tribes, Native American monitors, and City shall coordinate on appropriate treatment.

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

In the event that curation of archaeological resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final curation language and guidance on the project grading plans prior to issuance of the grading permit, if applicable, during project construction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the curation facility that the curation has been completed.

a qualified
archaeologist has
been retained, halt
ground disturbance
and follow
procedures listed for
discovery.

disturbing
activity.

Tribal Monitor(s),
Contractor.

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

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

During all earth
moving and
ground
disturbing
activity.

Archaeologist,
Tribal Monitor(s).

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

NOISE
N-1 Potential for
noise impacts due to
rock drilling and blasting.

If the rock drilling and blasting noise assessment determines noise levels at the affected property lines would exceed 75 dBA, the acoustical engineer shall develop a mitigation plan to ensure during rock drilling and blasting would be below 75 dBA at the property line. Potential measures to reduce drilling and blasting noise levels could include: 1) construction of a temporary noise barrier of solid non-gaping material ranging from 8 to 12 feet in height along any property line where the impacts could occur; 2) limits on usage of the equipment (amount of time used and/or the location in respect to the property line) or other measures to ensure the levels would be below 75 dBA. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

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

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

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

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

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N-2 Potential for
noise impacts due to
rock crushing.

If the rock crushing noise assessment determines noise levels at the affected property lines would exceed the standards, the acoustical engineer shall develop a mitigation plan to reduce noise levels to 60 dBA at any existing single-family use and 65 dBA at any existing multi-family use. Mitigation may include sound barriers, sound absorbing materials, and/or operational limits on the crusher equipment’s usage. The mitigation plan shall be submitted to the Planning Division and implemented by the contractor.

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

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

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

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

Extend written offer
and if accepted
prepare
ethnographic
synthesis. Submit
public (redacted)
version of the
ethnographic
synthesis to the
California Historical
Resources
Information System
and the City.

Agreement to
prepare
synthesis within
30 days of
project approval.

Synthesis to be
prepared prior to
ground
disturbing
activities
Applicant/
Landowner, Rincon
Band of Luiseño
Indians
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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 construction of the project while non-field-based data gathering, such as ethnographic interviews of informants and review of tribal documents, is being carried out. Upon completion, a public (redacted) version of the ethnographic synthesis shall be submitted to the California Historical Resources Information System and the City. The final non-redacted study shall belong to the Rincon Band of Luiseño Indians.

Extend invitation and
if accepted, enter
into a Monitoring
Agreement between
Applicant/Owner and
Tribes.

Prior to issuance
of a Grading
Permit or
commencement
of
ground
disturbing
activities and
during all earth
moving and
ground
disturbing
activities.

Applicant/
Landowner, Tribal
Representative(s),
Tribal Monitor(s),
Archaeologist,
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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 Agreement. 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 Rinco
n 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.

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

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

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

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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 surface to identify any evidence of potential tribal cultural resources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non-commercial sources that have been determined to be absent of tribal cultural resources by the TCA Native 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 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.

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 Install exclusionary
fencing around
western cultural
feature.

Prior to
commencement
of clearing and
grubbing.

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

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Impact Mitigation Measure Action Timing Responsibility
designated as an Environmentally Sensitive Area on grading plans.

Monitoring of non-ground disturbing activity shall not be required beyond 100 feet of the eastern cultural feature.

Tribal Monitoring
when construction-
related activity
reaches 1000 feet of
the eastern cultural
feature.

During non-
ground
disturbing
construction
activity.

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

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 a 10 foot by 10 foot area of culturally sterile soil.

Cap eastern cultural
feature
Prior to the
commencement
of ground
disturbing
activities.

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

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 Controlled grading
methods within 500
feet of easter and
western cultural
features identified
on grading plans and
conducted under
observation of tribal
monitor(s) and
archaeologist.

Prior to issuance
of grading permit
and during
grading/earth
disturbing
within
500 feet of
easter and
western cultural
features
Applicant/
Landowner, Tribal
Monitor(s),
Archaeologist,
Contractor.

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-22
Impact Mitigation Measure Action Timing Responsibility
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 be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. If the resource is determined to be not associated with Native 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 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 If potential tribal
cultural resources
are found, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

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

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-23
Impact Mitigation Measure Action Timing Responsibility
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 overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.

If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American
monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two working days of being notified if the remains are subject to his or her authority. If the Medical Examiner recognizes the remains to be Native American, and not under his or her jurisdiction, then he or she shall contact the If human remains
are found, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

Native American
Monitor(s),
Archaeologist,
Woodward Specific Plan May 2025
City of San Marcos Page 0.4-24
Impact Mitigation Measure Action Timing Responsibility
Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

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

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 materials encountered during monitoring, and to rebury existing collections from the previous data recovery effort. Following the completion of all ground disturbing activity and reburial of all materials and before the issuance of a Certificate of Occupancy, the Applicant shall: 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 Designate a reburial
location on grading
plan to be excluded
from construction-
related activities.

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

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

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

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-25
Impact Mitigation Measure Action Timing Responsibility
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.

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

Prior to the
issuance of a
Certificate of
Occupancy.

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

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.

Extend offer to
Tribe(s) and if
accepted prepare
access agreement
(s) for future visits to
the site’s reburial
location after
construction.

Prior to the
issuance of a
Certificate of
Occupancy.

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

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-26
Table 0.4-2. Design Considerations for the Project

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

Energy
• Ensure proper maintenance of all construction equipment per manufacturer recommendations.
• Installation of rooftop solar consistent with Title 24.

Hydrology and Water Quality

Source control BMPs include, but are not limited to:
• Preventing illicit discharges into the MS4
• Stenciling the future on-site public road storm drain inlets Woodward Specific Plan May 2025
City of San Marcos Page 0.4-27
• Protecting trash storage areas from rainfall, run-on, runoff, and wind dispersal.

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-28
Transportation
• The applicant/developer/property owner shall construct an access point that provides adequate driveway sight distance.
• The applicant/developer/property owner shall construct a southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane.
• The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2011-01 (Congestion Management). • Payment of Public Facility Fees, a portion of which go towards improvements to circulation streets and State Route 78 interchanges.

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-29

0.5 CEQANET POSTING

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-30

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-31

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-32

Woodward Specific Plan May 2025
City of San Marcos Page 0.4-33

Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page i
Table of Contents
Table of Contents ................................ ................................ ................................ ................................ .... i Technical Appendices (included on CD in back pocket) ...................................................................... v List of Tables ........................................................................................................................................... v List of Figures ......................................................................................................................................... vi Acronyms .......................................................................................................................................... viii

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

1.1 Project Summary .......................................................................................................................1-1

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

1.3 Areas of Controversy .................................................................................................................1-3

1.4 Issues to be Resolved ...............................................................................................................1-4

1.5 Project Alternatives ...................................................................................................................1-4

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

1.5.2 No Project/Existing Plan Alternative ........................................................................................... 1-5

1.5.3 Reduced Density Alternative ....................................................................................................... 1-6

1.5.4 Environmentally Superior Alternative ......................................................................................... 1-6

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

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

2.2 Project Description ....................................................................................................................2-1

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

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

2.3 Environmental Setting ............................................................................................................ 2-12

2.3.1 Existing Land Use and Setting .................................................................................................. 2-12

2.3.2 Existing General Plan and Zoning ............................................................................................. 2-12

2.3.3 Regional Setting ......................................................................................................................... 2-13

2.4 Intended Uses of EIR .............................................................................................................. 2-15

2.4.1 Scope of the EIR ......................................................................................................................... 2-16

2.4.2 Notice of Preparation and Scoping ........................................................................................... 2-16

2.4.3 Draft EIR and Public Review ...................................................................................................... 2-17

2.4.4 Final EIR Publication and Certification ..................................................................................... 2-17

2.5 Matrix of Project Approvals .................................................................................................... 2-18

2.6 Project Inconsistencies with Applicable Regional and General Plans ................................ 2-19

2.7 List of Past, Present and Reasonably Anticipated Future Projects in the Project Area ..... 2-19

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

3.1 Aesthetics .............................................................................................................................. 3.1-1

3.1.1 Existing Conditions .................................................................................................................... 3.1-1

3.1.2 Regulatory Setting .................................................................................................................... 3.1-2

3.1.3 Thresholds of Significance ....................................................................................................... 3.1-4

3.1.4 Project Impact Analysis ............................................................................................................ 3.1-4

3.1.5 Cumulative Impact Analysis ..................................................................................................... 3.1-7

3.1.6 Mitigation Measures ................................................................................................................. 3.1-8

3.1.7 Conclusion ................................................................................................................................. 3.1-8 Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page ii

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

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

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

3.2.3 Thresholds of Significance .....................................................................................................3.2 -12

3.2.4 Project Impact Analysis ..........................................................................................................3.2 -14

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

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

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

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

3.3.1 Existing Conditions .................................................................................................................... 3.3-2

3.3.2 Regulatory Setting ..................................................................................................................3.3 -10

3.3.3 Thresholds of Significance .....................................................................................................3.3 -12

3.3.4 Project Impact Analysis ..........................................................................................................3.3 -13

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

3.3.6 Mitigation Measures ...............................................................................................................3.3 -19

3.3.7 Conclusion ...............................................................................................................................3.3 -26

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

3.4.1 Existing Conditions .................................................................................................................... 3.4-2

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

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

3.4.4 Project Impact Analysis ..........................................................................................................3.4 -13

3.4.5 Cumulative Impact Analysis ...................................................................................................3.4 -15

3.4.6 Mitigation Measures ...............................................................................................................3.4 -16

3.4.7 Conclusion ...............................................................................................................................3.4 -17

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

3.5.1 Existing Conditions .................................................................................................................... 3.5-2

3.5.2 Regulatory Setting .................................................................................................................... 3.5-5

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

3.5.4 Project Impact Analysis ..........................................................................................................3.5 -15

3.5.5 Cumulative Impact Analysis ...................................................................................................3.5 -19

3.5.6 Mitigation Measures ...............................................................................................................3.5 -19

3.5.7 Conclusion ...............................................................................................................................3.5 -19

3.6 Geology and Soils .................................................................................................................. 3.6-1

3.6.1 Existing Conditions .................................................................................................................... 3.6-2

3.6.2 Regulatory Setting .................................................................................................................... 3.6-5

3.6.3 Thresholds of Significance ....................................................................................................... 3.6-8

3.6.4 Project Impact Analysis ............................................................................................................ 3.6-9

3.6.5 Cumulative Impact Analysis ...................................................................................................3.6 -12

3.6.6 Mitigation Measures ...............................................................................................................3.6 -12

3.6.7 Conclusion ...............................................................................................................................3.6 -13

3.7 Hydrology and Water Quality ................................................................................................. 3.7-1

3.7.1 Existing Conditions .................................................................................................................... 3.7-3

3.7.2 Regulatory Setting .................................................................................................................... 3.7-5

3.7.3 Thresholds of Significance .....................................................................................................3.7 -11

3.7.4 Project Impact Analysis ..........................................................................................................3.7 -12

3.7.5 Cumulative Impact Analysis ...................................................................................................3.7 -21 Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page iii

3.7.6 Mitigation Measures ...............................................................................................................3.7 -21

3.7.7 Conclusion ...............................................................................................................................3.7 -22

3.8 Land Use and Planning ......................................................................................................... 3.8-1

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

3.8.2 Regulatory Setting .................................................................................................................... 3.8-7

3.8.3 Thresholds of Significance .....................................................................................................3.8 -13

3.8.4 Project Impact Analysis ..........................................................................................................3.8 -13

3.8.5 Cumulative Impact Analysis ...................................................................................................3.8 -21

3.8.6 Mitigation Measures ...............................................................................................................3.8 -22

3.8.7 Conclusion ...............................................................................................................................3.8 -22

3.9 Noise ..................................................................................................................................... 3.9-1

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

3.9.2 Regulatory Setting .................................................................................................................... 3.9-3

3.9.3 Thresholds of Significance ....................................................................................................... 3.9-9

3.9.4 Project Impact Analysis ..........................................................................................................3.9 -11

3.9.5 Cumulative Impact Analysis ...................................................................................................3.9 -21

3.9.6 Mitigation Measures ...............................................................................................................3.9 -22

3.9.7 Conclusion ...............................................................................................................................3.9 -22

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

3.10.1 Existing Conditions ..................................................................................................................3.10- 2

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

3.10.3 Thresholds of Significance .....................................................................................................3.10- 7

3.10.4 Project Impact Analysis ..........................................................................................................3.10- 7

3.10.5 Cumulative Impact Analysis ................................................................................................ 3.10-10

3.10.6 Mitigation Measures ............................................................................................................ 3.10-12

3.10.7 Conclusion ............................................................................................................................ 3.10-12

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

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

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

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

3.11.4 Project Impact Analysis ....................................................................................................... 3.11-10

3.11.5 Cumulative Impact Analysis ................................................................................................ 3.11-14

3.11.6 Mitigation Measures ............................................................................................................ 3.11-15

3.11.7 Conclusion ............................................................................................................................ 3.11-15

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

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

3.12.2 Regulatory Setting ..................................................................................................................3.12- 5

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

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

3.12.5 Cumulative Impact Analysis ...................................................................................................3.12- 8

3.12.6 Mitigation Measures ...............................................................................................................3.12- 9

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

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

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

3.13.2 Regulatory Setting ..................................................................................................................3.13- 7

3.13.3 Thresholds of Significance .................................................................................................. 3.13-12 Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page iv

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

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

3.13.6 Mitigation Measures ............................................................................................................ 3.13-23

3.13.7 Conclusion ............................................................................................................................ 3.13-23

4.0 Alternatives ................................ ................................ ................................ ........................... 4—1

4.1 Introduction to Alternatives .................................................................................................... 4—1

4.2 Project Objectives .................................................................................................................... 4—1

4.3 Project Alternatives Considered in This EIR ........................................................................... 4—2

4.3.1 Description of Alternative ...........................................................................................................4 —2

4.3.2 Summary of Impacts ...................................................................................................................4 —2

4.3.3 No Project/Existing Plan Alternative ..........................................................................................4 —6

4.3.4 Reduced Density Alternative ................................................................................................... 4—11

4.4 Alternatives Considered But Rejected .................................................................................4—15

4.4.1 Alternative Location ................................................................................................................. 4—16

4.5 Environmentally Superior Alternative ...................................................................................4—16

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

5.1 Aesthetics ..................................................................................................................................5-1

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

5.3 Biological Resources .................................................................................................................5-3

5.4 Cultural Resources ....................................................................................................................5-4

5.5 Geology and Soils ......................................................................................................................5-4

5.6 Greenhouse Gas Emissions ......................................................................................................5-5

5.5 Hazards and Hazardous Materials ...........................................................................................5-5

5.7 Hydrology and Water Quality .....................................................................................................5-8

5.8 Land Use and Planning .............................................................................................................5-8

5.9 Mineral Resources ....................................................................................................................5-8

5.10 Noise .........................................................................................................................................5-9

5.11 Population and Housing ............................................................................................................5-9

5.12 Recreation............................................................................................................................... 5-10

5.13 Wildfire .................................................................................................................................... 5-10

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

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

6.2 Growth Inducement ...................................................................................................................6-1

6.3 Significant Irreversible Environmental Changes .....................................................................6-3

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

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

Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page v
Technical Appendices (included on USB drive in back pocket) Appendix A.1 Woodward Specific Plan
Appendix A.2 Heart of the City Specific Plan Amendment Appendix A.3 Project Plans
Appendix A.4 Landscape Plan
Appendix B.1 Initial Study Checklist
Appendix B.2 Notice of Preparation
Appendix B.3 NOP Comment Letters
Appendix C Air Quality Assessment
Appendix D.1 Biological Resources Report
Appendix D.2 Rare Plant Survey
Appendix D.3 CAGN Memorandum
Appendix D.4 Bee Survey
Appendix E Energy Report
Appendix F Climate Action Plan Consistency Review Checklist Appendix G Geotechnical Investigation
Appendix H Hydrology Study
Appendix I Stormwater Quality Management Plan
Appendix J Local Transportation Analysis
Appendix K Noise Report
Appendix L SMUSD Letter
Appendix M Vehicle Miles Traveled Report
Appendix N VWD Water and Sewer Study

List of Tables
Table 2-1. Open Space Summary ........................................................................................................... 2-3 Table 2-2. Project Design Features ......................................................................................................... 2-9 Table 2-4. Cumulative Projects ............................................................................................................. 2-20 Table 3.1-1. Aesthetics Summary of Impacts ..................................................................................... 3.1-1 Table 3.2-1. Air Quality Summary of Impacts ...................................................................................... 3.2-1 Table 3.2-2. San Diego County Air Basin Attainment Status by Pollutant ......................................... 3.2-3 Table 3.2-3. Two Year Ambient Air Quality Summary Near the Project Site (Camp Pendleton or Carmel Mountain Ranch Stations) ............................................................................................................ 3.2-4 Table 3.2-4. Ambient Air Quality Standards ........................................................................................ 3.2-7 Table 3.2-5. Screening-Level Criteria for Air Quality Impacts ........................................................... 3.2-13 Table 3.2-6. Construction Emissions (pounds/day) ......................................................................... 3.2-17 Table 3.2-7. Operational Emissions (pounds/day) ........................................................................... 3.2-17 Table 3.3-1. Biological Resources Summary of Impacts .................................................................... 3.3-1 Table 3.3-2. Vegetation Community/Land Cover Types with Project Impact Area ........................ 3.3-13 Table 3.4-1. Cultural Resources Summary of Impacts ....................................................................... 3.4-1 Table 3.4-2. Historical Aerial Photograph Review ............................................................................... 3.4-3 Table 3.5-1. Energy Summary of Impacts ........................................................................................... 3.5-1 Table 3.5-2 Proposed Construction Phase and Duration Equipment.............................................. 3.5-16 Table 3.6-1. Geology and Soils Summary of Impacts ......................................................................... 3.6-1 Table 3.7-1. Hydrology/Water Quality Summary of Impacts .............................................................. 3.7-1 Table 3.8-1. Land Use Summary of Impacts ....................................................................................... 3.8-1 Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page vi
Table 3.8-2. Signalized Intersection LOS Operational Analysis Method ........................................... 3.8-4 Table 3.8-3. LOS Criteria for Stop-Controlled Unsignalized Intersections ......................................... 3.8-4 Table 3.8-4. Roadway Segment Daily Capacity and LOS Standards ................................................. 3.8-5 Table 3.8-5. Peak Hour Intersection LOS – Existing Conditions ........................................................ 3.8-6 Table 3.8-6. Roadway Segment LOS Results – Existing Conditions .................................................. 3.8-6 Table 3.8-7. Project Trip Generation .................................................................................................. 3.8-16 Table 3.8-8. Near-Term Year 2026 - Intersection Operations Without and With Project ............... 3.8-17 Table 3.8-9. Near-Term Year 2026 Roadway Segment Operations Without and With Project...... 3.8-18 Table 3.8-10. Horizon Year (2050) Intersection Operations Without and With Project ................. 3.8-19 Table 3.8-11. Horizon Year 2050 Roadway Segment Operations Without and With Project ........ 3.8-20 Table 3.8-12. Project Consistency with Applicable San Marcos General Plan Goals and Policies 3.8-25 Table 3.9-1. Noise Summary of Impacts ............................................................................................. 3.9-1 Table 3.9-2. Measured Ambient Noise Levels .................................................................................... 3.9-3 Table 3.9-3. Exterior Noise Standards by Zone .................................................................................. 3.9-8 Table 3.9-4. Permitted Increase in Noise Levels ................................................................................ 3.9-8 Table 3.9-5. Permitted Increase in Interior Noise Levels ................................................................... 3.9-9 Table 3.9-6. Groundborne Vibration and Noise Impact Criteria (Human Annoyance).................... 3.9-10 Table 3.9-7. Groundborne Vibration Impact Criteria (Structural Damage) ..................................... 3.9-10 Table 3.9-8. Construction Noise Levels ............................................................................................. 3.9-13 Table 3.9-9. Construction Noise Levels from Rock Drill ................................................................... 3.9-14 Table 3.9-10. Rock Crushing Noise Levels (East) ............................................................................. 3.9-16 Table 3.9-11. Rock Crushing Noise Levels (South) .......................................................................... 3.9-16 Table 3.9-12. Future Traffic Parameters ........................................................................................... 3.9-17 Table 3.9-13. Combined Future Exterior Noise Levels (Roadway and Railway) ............................. 3.9-18 Table 3.9-14.Existing vs. Existing Plus Project Noise Levels............................................................ 3.9-19 Table 3.9-15. Vibration Levels from General Construction Activities at Residential Receptors .... 3.9-20 Table 3.9-16. Existing vs. Existing Plus Project Plus Cumulative Noise Levels .............................. 3.9-21 Table 3.10-1 Public Services Summary of Impacts .......................................................................... 3.10-1 Table 3.10-2. Student Generation ..................................................................................................... 3.10-9 Table 3.11-1. Transportation/Traffic Summary of Impacts ............................................................. 3.11-1 Table 3.12-1. Tribal Cultural Resources Summary of Impacts ........................................................ 3.12-2 Table 3.13-1. Utilities and Service Systems Summary of Impacts .................................................. 3.13-1 Table 3.13-2. Metropolitan Water District Total Water Demands in Acre Feet Per Year ............... 3.13-3 Table 3.13-3. Projected Wastewater Flows within VWD Service Area ............................................. 3.13-4 Table 3.13-4 Estimated Water Demands for Proposed Project .................................................... 3.13-14 Table 3.13-5 Existing Reservoir Storage Capacity and Requirements ......................................... 3.13-15 Table 3.13-6 Estimated Wastewater Flows for Proposed Project ................................................ 3.13-16 Table 4-1. Summary of Alternatives and Project Objectives ............................................................... 4-17 Table 4-2. Comparison of Impacts of Proposed Project and Alternatives .......................................... 4-18

List of Figures
Figure 3.1-1 Photo Simulation Overview ................................................................................. 3.1-3.1-9 Figure 3.1-2 Photo Simulation 1 (Southbound Woodward Street at Vineyard Road) ......... 3.1-3.1-10 Figure 3.1-3 Photo Simulation 2 (Southbound Woodward Street) ...................................... 3.1-3.1-11 Figure 3.1-4 Photo Simulation 3 (From Twin Oaks Valley Road Bridge Looking at Project Site) ......... ............................................................................................................................ 3.1-3.1-12 Figure 3.1-5 Photo Simulation 4 (Northbound Woodward Street at Mission Road) ........... 3.1-3.1-13 Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page vii
Figure 3.1-6 Photo Simulation 5 (Rendering of Project Entrance at Woodward Street) .... 3.1-3.1-14 Figure 3.1-7 Photo Simulation 6 (Rendering of Project from the Entrance to Mission 316 West) ...... ............................................................................................................................ 3.1-3.1-14 Figure 3.3-1. MHCP Conservation Areas in Project Vicinity ....................................................... 3.3-3.3-28 Figure 3.3-2. Vegetation Communities and Land Cover Types within Project Site and Study Area ......... .............................................................................................................................................. 3.3-3.3-29 Figure 3.3-3. Biological Resources Map ..................................................................................... 3.3-3.3-30 Figure 3.3-4. Vegetation Communities and Land Cover within Project Impact Area ............... 3.3-3.3-31 Figure 3.8-1. Existing Roadway Conditions ............................................................................ 3.8-3.8-23 Figure 3.8-2. Existing Traffic Volumes .................................................................................... 3.8-3.8-24 Figure 3.9-1. Ambient Monitoring Locations .............................................................................. 3.9-3.9-24 Figure 3.9-2. Modeled Receptor Locations ................................................................................ 3.9-3.9-25 Figure 3.9-3. Temporary Rock Crusher Proposed Location ...................................................... 3.9-3.9-26

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Acronyms
μg/m3 Micrograms Per Cubic Meter
AB Assembly Bill
AC Acre
AD Anno Domini
ADA Americans with Disabilities Act
ACC Advanced Clean Cars
ADT Average Daily Traffic
AF Acre Feet
AFY Acre Feet Per Year
AIA Airport Influence Area
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plan
AMI Area Median Income
AMSL Above Mean Sea Level
ANFO Ammonia Nitrate and Fuel Oil
ANSI American National Standards Institute
APN Assessor’s Parcel Number
AQIA Air Quality Impact Assessment
AQMD Air Quality Management District
ASTM American Society for Testing and Materials
BAU Business-As-Usual
BCLA Biological Core and Linkage Area
BMP Best Management Practices
BP Before Present
BTA Bicycle Transportation Account
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAGN Coastal California Gnatcatcher
CalARP California Accidental Release Program
CalEEMod California Emissions Estimator Model
Cal/EPA California Environmental Protection Agency
CAL FIRE California Department of Forestry and Fire Protection CALGreen California Green Building Standards Code
Cal/OSHA State of California Occupational Safety and Health Administration CaRFG California Reformulated Gasoline
CalRecycle Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAS California Approved Samplers
CBC California Building Code
CC&R Covenants, Conditions, and Restrictions
CCA Community Choice Aggregation
CCAA California Clean Air Act
CCR California Code of Regulations
CCSYA Critical Coarse Sediment Yield Areas
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City of San Marcos Page ix
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLIS Compensation and Liability Information System
CESA California Endangered Species Act
CFC California Fire Code
CFD Community Facility District
CFGC California Fish and Game Code
CFR Code of Federal Regulations
CFS Cubic Feet Per Second
CGS California Geological Survey
CH4 Methane
CHP California Highway Patrol
CHRIS California Historical Resources Information System CIP Capital Improvement Program
CIWBM California Integrated Waste Management Board
CM Centimeter
CMP Congestion Management Plan
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO Carbon Monoxide
CO2 Carbon Dioxide
CO2e CO2 Equivalent
COPPS Community Oriented Police and Problem Solving
CORRACTS Corrective Action Sites
COS Conservation and Open Space Element
CPTED Crime Prevention Through Environmental Design
CPUC California Public Utilities Commission
CRPR California Rare Plant Rank
CRHR California Register of Historic Resources
CSUSM California State University San Marcos
CUP Conditional Use Permit
CWA Clean Water Act
CWC California Water Code
CWPP Community Wildfire Protection Plan
CY Cubic Yard
dB Decibel
dBA A-weighted Decibel
DDE Dichlorodiphenyldichloroethylene
DEH Department of Environmental Health
DEIR Draft Environmental Impact Report
DOF Department of Finance
DOT Department of Transportation
DPM Diesel Particulate Matter
DPR Department of Parks and Recreation
DTSC Department of Toxic Substances Control
DU Dwelling Unit
Du/ac Dwelling Units per Acre
Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page x
DWR Department of Water Resources
E East
EDCO EDCO Waste and Recycling
EIR Environmental Impact Report
EISA Energy Independence and Security Act
EJ Environmental Justice Element
EO Executive Order
EPA Environmental Protection Agency
ERNS Emergency Response Notification System
ESA Endangered Species Act
ESA Environmental Site Assessment
EV Electric Vehicle
EWPCF Encina Water Pollution Control Facilities
FAA Federal Aviation Administration
FAR Federal Aviation Regulations
FAR Floor Area Ratio
FEIR Final Environmental Impact Report
FEMA Federal Emergency Management Agency
FERC Federal Energy Regulatory Commission
FHWA Federal Highway Administration
FPA Focused Planning Area
FRA Federal Rail Administration
FT Feet
FTA Federal Transit Administration
FT/S Feet per Second
GHG Greenhouse gas
GO-Biz Governor’s Office of Business and Economic Development GPA General Plan Amendment
GPD Gallons Per Day
GPNE General Plan Noise Element
GW Gigawatt
GWP Global Warming Potential
H2S Hydrogen Sulfide
HA Hydrologic Area
HAPs Hazardous Air Pollutants
HCFC Hydrochlorofluorocarbons
HCM Highway Capacity Manual
HFC Hydrofluorocarbons
HFRA Health Forests Restoration Act
HMBP Hazardous Material Business Plan
HMP Hydromodification Plan
HOA Home Owner’s Association
HOCSP Heart of the City Specific Plan
HP Horsepower
HP-h Horsepower Hour
HRA Hazards Risk Assessment
HREC Historical Recognized Environmental Condition
HVAC Heating, Ventilation, and Air Conditioning
H&SC Health and Safety Code
Woodward Specific Plan Draft EIR March 2025
City of San Marcos Page xi
IBC International Building Code
IC/EC Institutional Controls/ Engineering Controls
IEPR Integrated Energy Policy Report
IFC International Fire Code
IIRP Individual Integrated Resource Plan
IN Inch
in/sec inch per second
IPCC Intergovernmental Panel on Climate Change
IRP Integrated Resource Plan
IWMP Integrated Waste Management Plan
JRMP Jurisdictional Runoff Management Program
KBtu One Thousand British Thermal Units
kV Kilovolt
kWh Kilowatt-hour
Lbs Pounds
Lbs/Day Pounds per Day
LED Light Emitting Diode
Leq Equivalent Sound Level
LI Light Industrial
LID Low Impact Development
LOS Level of Service
LTA Local Transportation Analysis
LTS Less than Significant
LTSM Less than Significant with Mitigation
M Meter
MBTA Migratory Bird Treaty Act
MEP Maximum Extent Possible
MFR Multi-family Residential
MFSD Multifamily Site Development Permit
MG Million Gallon
MG/M3 Milligrams per Cubic Meter
MGD Million Gallons Per Day
MHCP Multiple Habitat Conservation Plan
MM Mitigation Measure
MMT Million Metric Tons
MPH Miles Per Hour
MRF Meadowlark Reclamation Facility
MRZ Mineral Resource Zone
MS4s Separate Storm Sewer Systems
MSSC Minor Street Stop Controlled Intersection
MT Metric Ton
MU2 Mixed Use 2
MU3 Mixed Use 3
MW Megawatt
MWD Metropolitan Water District
N2 Nitrogen
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NBL Northbound Lane
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City of San Marcos Page xii
NCCP Natural Community Conservation Planning
NCTD North County Transit District
NEVs Neighborhood Electric Vehicles
NFRAP No Further Remedial Action Planned
NHPA National Historic Preservation Act
NHTSA National Highway Traffic Safety Administration
NO2 Nitrogen Dioxide
NOP Notice of Preparation
NOx Nitrogen Oxides
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
NRHP National Register of Historic Places
NSLU Noise Sensitive Land Use
NTA Northern Tributary Area
O2 Oxygen
O3 Ozone
OEHHA Office of Environmental Health Hazards Assessment OPR Office of Planning and Research
Pb Lead
PDP Priority Development Project
PFCs Perfluorocarbons
PFF Public Facility Fee
PG&E Pacific Gas & Electric
PM2.5 Fine Particulate Matter
PM10 Respirable Particulate Matter
POC Point of Confluence
PPB Parts Per Billion
PPHM Parts Per Hundred Million
PPM Parts Per Million
PPV Peak Particle Velocity
PRC Public Resources Code
PV Photovoltaic
PVC Polyvinyl Chloride
RAQS Regional Air Quality Strategies
RCRA Resource Conservation and Recovery Act
REC Recognized Environmental Conditions
REL Reference Exposure Levels
RFS Renewable Fuel Standard
RHNA Regional Housing Needs Allocation
RMP Risk Management Plan
RMS Root Mean Square
ROG Reactive Organic Gas
ROZ Ridgeline Overlay Zone
RPS Renewable Portfolio Standard
RTIP Regional Transportation Improvement Program
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SANDAG San Diego Association of Governments
SB Senate Bill
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City of San Marcos Page xiii
SCAQMD South Coast Air Quality Management District
SCIC South Coastal Information Center
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCWA San Diego County Water Authority
SDG&E San Diego Gas & Electric
SDNR San Diego Northern Railroad
SDP Site Development Plan
S.F. Square Feet
SF6 Sulfur Hexafluoride
SHMA Seismic Hazards Mapping Act
SIP State Implementation Plans
SLCP Short-Lived Climate Pollutants
SLF Sacred Lands File
SMFD San Marcos Fire Department
SMUSD San Marcos Unified School District
SO2 Sulfur Dioxide
SP Specific Plan
SPA Specific Plan Area
SRA State Responsibility Areas
SR-78 State Route 78
SSC Species of Special Concern
STP Shovel Test Pit
SUSMP Standard Urban Stormwater Mitigation Plan
SWDA Solid Waste Disposal Act
SWRCB State Water Resources Control Board
SWPPP Stormwater Pollution Prevention Plan
SWQMP Stormwater Quality Management Plan
TACs Toxic Air Contaminants
T-BACT Toxics Best Available Control Technology
TCA Traditionally and Culturally Affiliated
TCP Traditional Cultural Properties
TDM Transportation Demand Management
THPO Tribal Historic Preservation Officer
TIA Transportation Impact Analysis
TIAG Transportation Impact Analysis Guidelines
TK Transitional Kindergarten
TMDL Total Maximum Daily Load
TSD Treatment, Storage and Disposal
TSM Tentative Subdivision Map
TWSC Two-way stop controlled intersection
UBC Uniform Building Code
USACE U.S. Army Corps of Engineers
USDOT U.S. Department of Transportation
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UST Underground Storage Tank
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UWMP Urban Water Management Plan
V/C Volume-To-Capacity
Vdb Vibration Velocity
VHFHSZ Very High Fire Hazard Severity Zone
VMT Vehicle Miles Traveled
VOCs Volatile Organic Compounds
VWD Vallecitos Water District
WB Westbound
WEAP Worker Environmental Awareness Program
WELO Water Efficiency Landscape Ordinance
WMA Watershed Management Area
WoS Waters of the State
WoUS Waters of the US
WQIP Water Quality Improvement Plan
WUI Wildland Urban Interface
ZEB Zero Emission Bus
ZEV Zero Emission Vehicle

Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 1-1

1.0 Summary

1.1 Project Summary
The applicant is proposing to develop 46 duplex residential units, associated infrastructure, and common and private open space on an approximately 8.57 gross acre site located on Woodward Road in the City of San Marcos.

The project applicant is requesting the following discretionary approvals from the City to allow for development of the proposed project:
• Specific Plan Amendment (SP22-0006) – A Specific Plan Amendment to modify the Heart of the City Specific Plan to remove the current Richmar Sub-Plan designation on the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan..
• Specific Plan (SP22 -0005) – The Woodward 46 Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan.
• General Plan Amendment (GPA22 -0004) – A General Plan Amendment to the Land Use Element for the purpose of amending land use maps and text related to changing the sub-plan designation of the subject property from Richmar Specific Plan to Woodward 46 Specific Plan. • Multi-Family Site Development Plan (MFSDP22 -0005) - Multi-Family Site Development Plan approval would be required to construct 46 multi -family residential units and address the details of the architectural style, building elevation, fencing, and landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM22-0004) - Tentative Subdivision Map approval would be required for formation of residential condominium units, private driveways, and open space areas.
• Conditional Use Permit (CUP22-0005) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

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

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

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

1.0 Executive Summary
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 1-2
The mitigation measures listed in Table 1-1 will reduce impacts related to biological resources, cultural resources, noise. and tribal cultural resources. As shown in Table 1 -1, all impacts would be reduced to below a level of significance.

Table 1-1. Summary of Significant Environmental Impacts Impact Mitigation Measures Level of Significance After
Mitigation
Biological Resources
BIO-1: The proposed project has the
potential to result in direct and indirect
impacts to coastal California
gnatcatcher
Implementation of MM-BIO-
1a and MM-BIO1b, refer to
Section 3.3.6
Less than significant
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.

Implementation of MM-BIO-
2, refer to Section 3.3.6
Less than significant
BIO-3: The proposed project has the
potential to result in direct and indirect
impact to special-status wildlife
species including Orange-throated
whiptail, coastal whiptail, Southern
California rufous-crowned sparrow,
Cooper’s hawk, Crotch’s bumble bee,
and Bryant’s woodrat.

Implementation of MM-BIO-
3a through MM-BIO-3d,
refer to Section 3.3.6
Less than significant
BIO-4: The proposed project has the
potential to impact nesting birds and
raptors that are afforded protection
under the California Fish and Game
Code and the Migratory Bird Treaty Act.

Implementation of MM-BIO-
4, refer to Section 3.3.6
Less than significant
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.

Implementation of MM-BIO-
3a through MM-BIO-3d,
refer to Section 3.3.6
Less than significant
BIO-6: The proposed project would
impact 5.24 acres of Diegan coastal
sage scrub and 0.26 acre of disturbed
Diegan coastal sage scrub for a total of

5.50 acres of impact.

Implementation of MM-BIO-
6, refer to Section 3.3.6
Less than significant

1.0 Executive Summary
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 1-3
Impact Mitigation Measures Level of Significance After
Mitigation
Cultural Resources
CR-1: Due to grading and ground
disturbing activities, the project has
the potential to impact unidentified
archeological resources on the project
site.

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

Implementation of MM-CR-
2, refer to Section 3.4.6
Less than significant
Noise
N-1: Potential for noise impacts due to
rock drilling and blasting.

Implementation of MM-N-1,
refer to Section 3.9.6
Less than significant
N-2: Potential for noise impacts due to
rock crushing.

Implementation of MM-N-2,
refer to Section 3.9.6
Less than significant
Tribal Cultural Resources
TCR-1: As a result of tribal
consultation, the City has determined
that construction of the proposed
project has the potential to cause a
substantial adverse change to a tribal
cultural resource that is determined,
by the City, based on substantial
evidence, to be a tribal cultural
resource.

Implementation of MM-TCR-
1 through MM-TCR-12, refer
to Section 3.12.6
Less than significant

1.3 Areas of Controversy
A Notice of Preparation (NOP) was distributed on August 21, 2023 for a 30 -day public review and comment period. Additionally, a public scoping meeting was held on August 30, 2023.

Comments received during the NOP public scoping period were considered part of the preparation of this EIR. The NOP and written comments are included in Appendices B.2 and B.3 to this EIR. Topics raised during the NOP comment period and scoping meeting include:
• Aesthetics: views from adjacent private homes
• Biological Resources: Multiple Habitat Conservation Program plan consistency, sensitive species, sensitive habitat, and biological resources mitigation • Cultural and Tribal Cultural Resources: compliance with Assembly Bill 52 and Senate Bill 18 • Land Use: provision of low-income or senior housing
• Noise: construction and vehicular noise, vibration from blasting

1.0 Executive Summary
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 1-4
• Public Services (police): City should consider having their own police department • Transportation (pedestrian): pedestrian safety
• Transportation (vehicular): congestion
• Utilities and Service Systems: water use
These concerns are addressed in Chapter 3 of the EIR.

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

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

Issues to be resolved that are directly related to the proposed project include the choice among the alternatives and whether or how to mitigate the significant effects. In particular, the decision makers must decide if the significant impacts to biological resources, cultural resources, resources, noise, and tribal cultural resources have been mitigated to less than significant. Lastly, the decision makers must determine whether any of the project alternatives would substantially reduce significant effects while still meeting key objectives of the project.

1.5 Project Alternatives
Three alternatives are proposed to provide an understanding of how environmental effects could be reduced by varying the design and scope of the project. Table 1-2 provides a comparison of the impacts of project alternatives to the impacts of the proposed project.

1.5.1 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).

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 Fee (PFF), which goes toward supporting a variety of services and improvements in the City, including but not limited to Circulation Streets, State Route78 Interchanges, National Pollutant Discharge Elimination System, Tech Improvements, Parks, and Habitat Conservat ion. Payment of these fees provide improvements that benefit all residents of the city. Similarly, this alternative would not

1.0 Executive Summary
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 1-5
contribute any school fees. Finally, this alternative would not meet any of the project objectives (Table 1-3).

1.5.2 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 He art 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 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 th is 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 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 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 proportiona l increase in air pollutants and noise from vehicles compared to the proposed project. Construction -related air pollutants 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 biol ogical 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 Unif ied 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 1-3.

1.0 Executive Summary
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 1-6

1.5.3 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 the 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 S treet. Grading, blasting and rock crushing as well as fire fuel modification would be required for this alternative.

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 pollutants 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 1-3, but would not provide multi- family housing in the 4.1-8.0 dwelling unit range.

1.5.4 Environmentally Superior Alternative
Table 1 -2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project. As shown in Table 1-2, 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 (see Table 1-3). Additionally, there is no certainty that the project site would remain undeveloped in perpetuity. The California Environmental Quality Act 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.

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City of San Marcos Page 1-7
Table 1-2. Comparison of Impacts of Proposed Project and Alternatives Environmental Topic Proposed
Project
No Project/No
Development
Alternative
No Project/
Existing Plan
Alternative
Reduced
Density
Alternative
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)
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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City of San Marcos Page 1-8
Table 1-3. Summary of Alternatives and Project Objectives Objective Proposed
Project
No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Density
Alternative
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
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

1.0 Executive Summary
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City of San Marcos Page 1-9
Objective Proposed
Project
No Project/No
Development
No
Project/Existing
Plan Alternative
Reduced
Density
Alternative
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

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2.0 Project Description, Location, and Environmental Setting Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 2-1

2.0 Project Description, Location and Environmental Setting This Draft Environmental Impact Report (EIR) has been prepared by the City of San Marcos to evaluate the potential effects associated with the construction and implementation of the proposed Woodward 46 Specific Plan Project (proposed project) as described in Section 2.2 of this EIR. The EIR is intended to provide information to the San Marcos City Council, public agencies, stakeholders and organizations, and the general public regarding the potential environmental impacts, mitigation measures, and alternatives to the proposed project

2.1 Project Objectives
The following objectives describe the underlying purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in the EIR. • 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 greenhous e 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 surrounding neighborhood while providing a desirable living environment for reside nts 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.

2.2 Project Description
The approximate 8.57-acre project site is located on the east side of Woodward Street, generally between E. Mission Road to the south and Vineyard Road to the north in the Richland neighborhood in City of San Marcos (City) in North County San Diego, California ( Figure 2-1a). The project site is
approximately 0.5 mile north of State Route 78 (SR -78) and 0.1 mile north from the Civic Center SPRINTER rail station (Figure 2-1b). The assessor parcel number (APN) is 220-210-49-00.

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The project applicant is requesting approval of a Specific Plan Amendment to the Heart of the City Specific Plan (HOCSP) (SP22 -0006), adoption of a new Woodward 46 Specific Plan (SP22-0005), General Plan Amendment (GPA22-0004), Multi -Family Site Development Plan (MFSD22 -0005), Tentative Subdivision Map (TSM22 -0004), and Conditional Use Permit (CUP22--0005). If approved, these entitlements would allow for the development of the proposed 46-unit condominium development on the project site. The conceptual site plan is presented in Figure 2-2.

2.2.1 Discretionary Actions
As mentioned above, the requested project entitlements/discretionary actions, and permits by the City include a Specific Plan Amendment, a Specific Plan, General Plan Amendment, Multi -Family Site Development Plan, Tentative Subdivision Map, and a Conditional Use Permit. Each of these actions is described in more detail below. The Specific Plan is included as Appendix A.1, the amendment to the
HOCSP is included as Appendix A.2, and the project plans are included as Appendix A.3. • Specific Plan Amendment (SP22-0006) – A Specific Plan Amendment to modify the Heart of the City Specific Plan to remove the current Richmar Sub-Plan designation on the project site in order to establish its own development criteria under the proposed Woodward 46 Specific Plan.
• Specific Plan (SP22 -0005) – The Woodward 46 Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan.
• General Plan Amendment (GPA22 -0004) – A General Plan Amendment to the Land Use Element for the purpose of amending land use maps and text related to changing the sub-plan designation of the subject property from Richmar Specific Plan to Woodward 46 Specific Plan. • Multi-Family Site Development Plan (MFSD22-0005) )- A Multi-Family Site Development Plan approval would be required to construct 46 multi -family residential units and address the details of the architectural style, building elevation, fencing, and landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM22-0004) - Tentative Subdivision Map approval would be required for formation of residential condominium units, private driveways, and open space areas.
• Conditional Use Permit (CUP22-0005) - Conditional Use Permit approval would be required for potential use of a temporary rock crusher.

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

2.2.2.1 Land Use
Residential Land Use
The project proposes 46 duplex residential units in 23 buildings situated on approximately 8.57 gross acres for a project density of 5.37 du/acre. The proposed residential units would all be three bedroom and 3.5 baths and range from 1,585 square feet (s.f.) to 1,900 s.f. The units would be three stories

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and approximately 35 feet in height. Each unit would have a two -car garage. The Specific Plan’s development standards require a minimum of 0.75 floor area ratio.

Open Space
There are three main categories of open space proposed for the project: private open space, common open space with grades of 10% or greater, and common open space with grades less than 10%.

Recreational open space is sub-categorized under the common open space with grades less than 10%.

Private open space is associated with private patio/yard areas for each of the residential units. Table 2-1 presents the open space summary as detailed in the Specific Plan. Figure 2-3 presents the open space concept plan as proposed for the project.

Table 2-1. Open Space Summary
Type of Open Space Total (Acres)
Common Open Space – Grades of 10% and Greater 5.18 acres Common Open Space – Grades less than 10% 0.86 acres
Private Open Space(1) 38.375 s.f.

Recreation Areas(2) 0.2 acres
Common Open Space Total 6.04 acres
Notes: Private open space square footages are not included in the total.

Recreation area calculations included within the Common Open Space with Grades Less than 10%.

Common Open Space
Common Open Space – Grades 10 Percent or Greater
Open space with grades of 10 percent or above typically constitute landscape slope areas that are not usable open space. The project site contains steep slopes on the south, west, and north, however inclusion of strategically placed walls around the site would produce a level area for residential development to occur. Graded areas of development containing slopes over 10 percent shall be landscaped to prevent erosion of slopes. Landscaping and water quality basins may fall into this category of open space supporting the functionality of drainage systems as well as enhancing and beautifying the Specific Plan area. Portions of the common open space area within Lot A may be preserved as biological habitat and subject to an open space easement. The project inclu des 5.18 acres of common open space – grades 10 percent and greater.

Common Open Space – Grades Less than 10 Percent
This category of open space would be included within the developed footprint of the residential land uses within the Specific Plan. Recreation areas within the Specific Plan shall provide at least three major amenities for each residential planning area. A list of comparable recreation amenities can be found in Section 3.3.3 of the Woodward 46 Specific Plan. Landscaping and water quali ty basins may fall into this category of open space supporting the functionality of drainage systems as well as enhancing and beautifying the Specific Plan area. The project includes 0.86 acres of common open space – grades less than 10 percent, including the recreation area discussed below.

Recreation Areas

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The project includes a 7,480 s.f. (0.2 acre) community recreation area which would be located in the southcentral portion of the site. The recreational amenities would include a tot lot with fall -safe surfacing, turf play areas, shaded picnic table, looped trike track, and a sensory play area. The homeowners association would be responsible for the maintenance of the common open space areas, including the recreation area.

Private Open Space
Private open space within the proposed project consists of private patio space and private balcony/deck space. The City requires that each unit with ground floor living must provide 250 s.f. of private open space. Units with living space on the second floor and above must provide 50 s.f. of private open space in the form of decks or balconies. E ach dwelling unit included within the Specific Plan area would be provided with private open space. Each unit with ground floor living would include a minimum of 250 square feet of private open space which would be provided as a private rear yard area. For units located on the second story and above a minimum of 50 square feet of private open space would be provided. The project includes a total of 38,375 s.f. (0.88 acres) of private open space.

Landscape Plan
The proposed landscape plan includes a mix of trees, shrubs, and groundcover and the plant selection emphasizes low and moderate water use species and species that are suitable for rocky slope conditions. Proposed tree species include: evergreen elm, Marina strawberry tree, Chitalpa pink dawn, Australian willow, Tuscarora crape myrtle, Chinese pistache, African sumac, eastern redbud, bronze loquat, sweetshade, shrubby yew podocarpus, Torrey pine, coast live oak, southern live oak, Brisbane box, and little g em magnolia. The proposed project would also comply with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20. The landscape concept plan is included as
Figure 2-4 and the complete landscape plan and planting palette is included in Appendix A.4.

2.2.2.2 Architectural Design
The proposed project would be developed with two building types (Elevation A and Elevation B). Each building type would provide a variation of contemporary/modern style architecture. For each elevation type, some of the units have been identified for enhanced elevation treatments.

Figures 2-5a, 2-5b, 2-
6a and 2-6b present conceptual building elevations for each elevation type and Figure 2-7 presents the rendered building elevations.

The proposed architectural style takes inspiration from contemporary/modern style architecture.

Elements and materials traditionally used for this style include angular pitched roofs using concrete roof tiles, simple forms with stucco or stone veneer walls, metal and stucco railings, and awnings. The architecture was chosen to complement existing architecture adjacent to the project site. The architectural style would be complemented with a color scheme which incorporates neutral wall colors to complement the project with nearby development within the area. The Specific Plan identifies design concepts to minimize the bulk and scale of the project. This includes: using building -form elements such as place breaks, roof forms, and changes in materials to define individual units; articulating the front and rear elevations both vertically and horizontally; and avoiding long unbroken surfaces on front and rear elevations by providing a change in plane at least every 25 feet.

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2.2.2.3 Walls, Fencing and Lighting
Fencing and Walls
Generally, walls and fences within the proposed development are designed to function in five ways; (1) as aesthetic boundaries for open space, (2) sound attenuation, (3) retaining barriers along roadways or lots, (4) safety fencing around recreational areas, and (5) privacy fencing between private open space for multi-family dwelling units. Fence and wall types allowed within the Specific Plan Area may include geogrid retaining walls, soil nail retaining walls, tan block retaining wall, tubular steel fencing, tubular steel on retaining wall, and vinyl privacy fencing. Wall and fencing materials may be substituted with other wall and fence types and materials upon review and approval by the Development Services Department. Figure 2-8 presents the conceptual fence and wall plan and Figure 2-9 presents examples of the proposed wall and fencing materials.

Lighting
Lighting for the proposed project would be used to accent landscaping and provide safety and accent lighting for duplex buildings. All lighting fixtures for the proposed project would be energy efficient, architecturally appropriate, and designed to minimize glare, conflict, and light pollution, while providing illumination levels that create a safe environment for both vehicles and pedestrians. Street area lights would be full cut-off fixtures and would utilize house-side shields to reduce light trespass and prevent light pollution. Common area lighting would be used to enhance and complement the character of the development. Conceptual lighting fixtures and locations are illustrated on Figure 2-10. Lighting would be required to conform with the City’s lighting ordinance and standards, (San Marcos Municipal Code Title 20, Section 20.300.080).

2.2.2.4 Access, Circulation and Parking
Project 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.

Circulation
The project site would have one internal circulation system. The conceptual circulation plan is included as Figure 2-11. The driveway in the Specific Plan Area 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 Americans with Disability Act (ADA) 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 connect units to the common recreation area. A concrete sidewalk would be constructed along the west side of the main project driveway to connect the project to Woodward Street. A 6-inch curb and gutter would be constructed to either side of the driveway and each travel lane would be a minimum of 12 feet from center line.

Emergency Access
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

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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 northe ast 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.

Parking
The project proposes a total of 108 on -site parking spaces. This includes two -car garages for each residential unit and 16 open parking spaces. Each garage would be wired to accommodate an electric vehicle charter. The open parking spaces would be located throughout the project area.

2.2.2.5 Grading and Construction Phase
The proposed project is expected to start construction in 2025 and full occupancy is anticipated in 2027.

Grading
Earthwork activities include 41,989 cubic yards (CY) of cut volume. With over-excavation and bulking, the total fill volume would be 50,270 CY, for a difference of 8,281 CY. If suitable, the excess material would be used as wall backfill and the site would balance. If it is not suitable, it would be exported from the site. To be conservative, the environmental analysis assumes the materials would be exported. Assuming 15 cy truck trips, that would equate to 553 trips. These trips would be spread over approximately 23 working days for 24 trips per day associated with export.

The project design incorporates retaining walls to manage the topography of the site and create areas for the access driveway and building pads. The proposed retaining walls include slump block, geogrid, and soil nail styles, depending on the location with in the project. The retaining walls would be earth - tone color and textured to blend in with the surrounding terrain.

There is existing netting along the Woodward Street frontage to minimize the potential for rock and debris fall onto the roadway. As noted on the proposed grading plans for the project, a portion of this netting would be removed to accommodate the project grading. The netting would be re -anchored to the new top of slope or as recommended by the soils engineer during project construction.

The import and export of earth material is guided by Section 17.32.080 of the City’s Municipal Code and prior to any export of soils, a haul route would be submitted for review and approval by the City Engineer. Additionally, grading and other earth moving activities are restricted to the hours of 7:00 AM and 4:30 PM, Monday through Friday, per Section 17.32.180 of the City’s Municipal Code.

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

Blasting and Rock Crushing
Due to bedrock conditions, blasting would be required on the project site. The proposed project would comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and blasting would only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. Blasting also requires issuance of a Blasting Permit from the San Marcos Fire Department.

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The proposed project’s requested approvals include a Conditional Use Permit (CUP22--0005), which would allow for the use of the temporary rock crusher. The rock crusher, a Thunderbird Hazemag impact crusher, would be located in the central portion of the site to provide the most distance from adjacent residential uses. The crusher would be app roximately 329 feet from the residential use to the east, 667 feet from the closest residential use to the north and 531 feet from the closest residential use to the south.

2.2.2.6 Public Utilities and Services
Water Facilities
The project site lies within the service area of Vallecitos Water District (VWD) for water service and sewer service. The project would connect to the existing 8-inch water main in 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.

Wastewater Facilities
The project site is also in the VWD service area for sewer service. For sewer service, the proposed project would extend the existing 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.

Site Drainage and Stormwater Management
Storm drain systems and connections would be designed to accommodate the proposed future development. The proposed project would construct two biofiltration basins (BMP -A and BMP -B) for storm water quality and hydromodification, which would be located at t he northeast corner and northwest edge of the project site. These features would collect storm water from the buildings and street and direct the storm water through storm water drainage pipes to existing points of confluence (POC). In conformance with the 2023 City of San Marcos BMP Design Manual.

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

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

Fire Protection
The San Marcos Fire Department (SMFD) would provide fire protection for urban and wildland fires and emergency services to the project site. SMFD services San Marcos with four stations, the closest

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of which is Fire Station No. 1 located at 180 W. Mission Road, approximately 0.25 miles west of the project site. There are two easements on the project site associated with vegetation management for fire fuel reduction. One is located along a portion of the project site’s eastern boundary and the other is located along a portion of the project site’s southern boundary. These are associated with fire buffer maintenance requirements of adjacent development.

The proposed project would also implement a zoned brush management plan which would provide a minimum of 150 feet of clearance. The brush management plan would follow the California Department of Forestry and Fire Protection’s (CAL FIRE) guidance for defen sible space (CAL FIRE 2023) which includes three zones of defensible space. The preliminary brush management plan is included as
Figure 2-12. The brush management plan and implementation would be the responsibility of the Home Owners Association. The brush management zones include:
• Zone 1 (Structures) – This zone covers 50 feet around structures and is measured from the structure outward to 50 feet or to the property line. Zone 1 landscaping shall be permanently irrigated and landscaped with fire resistive, low fuel plant material lower than 18 inches high.

At maturity, trees shall be located so crowns are a minimum 10 feet from structures at maturity and spaced with a minimum of 10 feet between crowns at maturity. No combustible fencing shall be allowed. No bark mulch shall be allowed within 5 feet of structure walls. • Zone 1 (Roadway Adjacent) – This zone measures 30 feet outwards from the roadway curb to 30 feet each side of the roadway. Landscaping shall be permanently irrigated and landscaped with fire-resistive, low-fuel plant material.
• Zone 2 – This zone is measured from the outside edge of Zone 1 outward to 100 feet from the structure. This zone has a reduced fuel, non -irrigated area and shall be maintained, thinned, and trimmed. A maximum of 50 percent of native vegetation shall be retained with single specimen shrubs 20 feet off center maximum. Groundcover shall be maintained at 6 inches height. Trees shall be maintained with a minimum 20 feet between canopies. • Zone 3 – This zone measures from the outside of edge of Zone 2 outward to 150 feet from the structure. This zone is a reduced fuel, non-irrigated area and shall be maintained, thinned, and trimmed. A maximum of 30 percent of native vegetation shall be retained with single specimen shrubs 20 feet off center maximum. Groundcover shall be maintained at 6 inches height. Trees shall be maintained with a minimum 20 feet between canopies.

2.2.2.7 Vacation of Easement
As part of the project, an existing easement for drainage, slope and public street, and utility is recorded in favor of the City (recoded March 26, 2002, Document No. 2002- 0251944). As part of the project all drainage rights will be vacated on the final map and portions of the slope rights will be vacated on the Final Map. The City will reserve the public street and utility rights associated with this existing easement.

2.2.2.8 Offsite Improvements
Wastewater Infrastructure
As discussed in Section 2.2.2.6, prior to project occupancy, the proposed project would implement the following improvement:

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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.

Transportation Infrastructure Improvements
The proposed project would 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.

2.2.2.9 Economic Characteristics
As discussed in Chapter 8 of the Woodward 64 Specific Plan (Appendix A.1), the proposed project would include a Facilities Financing Plan to ensure improvements are implemented in a timely and successful manner. The financing mechanisms for each improvemen t would be timed with development of the project site, the City’s conditions of approval, and site plan/design review approval.

Refer to Chapter 8 of Appendix A.1 for additional details regarding the methods of financing of construction and operation of public improvements and services.

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

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

Air Quality
• Compliance with SDACPD Rule 55 – Fugitive Dust.
• In accordance with SDAPCD Rule 67.0 (Architectural Coatings), the project would utilize low- volatile organic compound (VOC) paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces. • Heavy diesel construction equipment shall be rated Tier IV.

Energy
• Ensure proper maintenance of all construction equipment per manufacturer recommendations.
• Installation of rooftop solar consistent with Title 24.

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Geology and Soils
• Implement all recommendations from the preliminary geotechnical investigation (GeoTek 2019). These recommendations include general provisions related earthwork, and design recommendations related to stormwater infiltration, foundation design, seismic design parameters, corrosion, retaining all design and construction, and post-construction considerations. The detailed recommendations are included in Chapter 5 of the geotechnical report, which is included as Appendix G of this document. • Removal and replacement of netting along Woodward Street frontage to minimize potential for rock and debris fall on the roadway, as noted on the project grading plans.

Hydrology and Water Quality

Permanent Structural BMPs, include, but are not limited to:
• Biofiltration basins and hydromodification facility including 100-year post-development detention

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Noise/Vibration
• Grading, excavation, and other earth moving activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. No grading, excavation and other earth moving activities would occur on the weekends or holidays in accordance with the City’s Municipal Code, Section

17.32.180.
• The project would comply with all provisions identified in the City’s Municipal Code Section

Transportation
• The applicant/developer/property owner shall construct an access point that provides adequate driveway sight distance.
• The applicant/developer/property owner shall construct a southbound left-turn pocket on Woodward Street for left-turn access to the project site outside of the southbound through lane. • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2011-01 (Congestion Management). • Payment of Public Facility Fees, a portion of which go towards improvements to circulation streets and State Route 78 interchanges.

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2.3 Environmental Setting

2.3.1 Existing Land Use and Setting
On-Site
The project site is currently undeveloped, steeply -sloped vacant land. The earliest -available aerial images of the project site, dating to 1928, appear to show two graded areas with a dirt road connecting the two. By 1938, at least one of the dirt roads appears to have been abandoned. Between 1953 and 1964, another episode of disturbance is visible on the aerial imagery, with grading over a portion of the project area and possibly the widening of Woodward Street. By 1980, a four-sided feature is visible in these graded areas. By 1987, this feature is no longer visible. Post-1987, activity in the project site appears to be sporadic and included clearing of some of the previously cut roadways . In the most - recent google earth images dating to 2021, a small approximately 7-x- 10-ft feature is visible in the southern portion of the project area. During the cultural resources site survey, it was determined that this feature was an abandoned asphalt -related machine (ASM 2024). There is existing netting along the Woodward Street frontage to minimize the potential for rock and debris fall onto the roadway.

Surroundings
The project site is in a developed portion of the City . The project vicinity includes single -family residential neighborhoods to the north and east, multi -family residential developments to the south, and undeveloped land to the west across Woodward Street. Directly north of the project site is an area designated as Open Space in the City’s General Plan. The City of San Marcos Civic Center is located south of the project site across E. Mission Road and contains a mix of institutional, office, and medical office uses as well as adjacent commercial land uses which offer a variety of retail space, restaurants, service uses, and shopping. The Civic Center SPRINTER rail station is located approximately 0.1 miles from the project site at the intersection of E. Mission Road and San Marcos Boulevard.

2.3.2 Existing General Plan and Zoning
Existing General Plan Land Use Designation
The project site has a General Plan Designation of SPA (Specific Plan Area) and is associated with the HOCSP. The HOCSP comprises approximately 1,528 acres in the geographic center of the City. In the HOCSP, certain properties along the Mission Road corrid or, 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.

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Existing Zoning Designation
The project site is located within the HOCSP Specific Plan Area and zoned SPA. No change in zoning is proposed as part of the project.

2.3.3 Regional Setting
The following provides a general description of various aspects of the proposed project’s environmental setting. Additional descriptions of the project’s environmental setting as it relates to environmental issue areas can be found in Chapter 3.

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

2.3.3.2 Air Basin
The City and project site is within the San Diego Air Basin (SDAB) and is under the jurisdiction of the San Diego Air Pollution Control District (SDAPCD). The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB lies in the southwest corner of California and comprises the entire San Diego region, covering 4,260 square miles, and it is an area of high air pollution potential.

The SDAB experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The SDAB is currently classified as a federal nonattainment area for ozone (O 3) and a state
nonattainment area for particulate matter less than or equal to 10 microns of coarse particulate matter (PM10), particulate matter less than or equal to 2.5 microns (fine particulate matter (PM 2.5)), and ozone (O3).

2.3.3.3 Soils
The earth materials present at the project site consist of sporadic undocumented fill materials, colluvium, and Cretaceous age plutonic bedrock (GeoTek 2019). 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.

2.3.3.4 Terrain and Topography
The project site is located within the 7.5 -minute San Marcos Quadrangle map. The project site is undeveloped and steeply sloped. Elevation ranges from 754 feet above mean sea level (amsl) in the eastern portion of the project site down to 615 feet in the southwestern portion of the project site.

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2.3.3.5 Watershed and Hydrology
The project site is located within the jurisdiction of the San Diego Regional Water Quality Control Board (RWQCB). The San Diego Region is divided into eleven hydrologic units. The project site is located in the Richland Hydrologic Subarea (904.52) within the San Marcos Hydrologic Area (904.5) of the Carlsbad Watershed Hydrologic Unit (904). The existing drainage conveyance is natural and fronts Woodward Street and E. Mission Road.. The upper east side of the project site drains westerly to the existing 18-inch and 24-inch storm drain pipes, then to POC-1 which is located at the southeast corner of the project site. The lower east side of the project site drains southerly to the existing 18 -inch and 24-inch storm drain pipes then to POC-2, which is located a t the southeast corner of the project site.

At the most northern portion of the project site, surface runoff drains northerly to POC-3, which is located at the northwest edge of the project site.

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

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

Directly north of the project site is an area designated as Open Space in the City’s General Plan.

Based upon the biological resources study prepared for the project (Rincon 202 5), the project site supports Diegan coastal sage scrub, disturbed Diegan coastal sage scrub, disturbed habitat, and urban/developed areas. No drainages or wetlands occur on the project site. Focused surveys for costal California gnatcatcher (CAGN) were conducted in 2023 and no CAGN were observed on the project site. Rare plant surveys were conducted in June and Sep tember 2023 and no rare plants were observed on the project site. (Rincon 2024).

2.3.3.7 Public Services
Police Protection
Police protection for the proposed project would be provided by the County of San Diego Sheriff’s Department. The County Sheriff provides contract law enforcement services to the City of San Marcos through the station located at 182 Santar Place, approximately 0.75 miles east of the project site.

Schools
The project site is within the San Marcos Unified School District (SMUSD) boundary. SMUSD is 49 square miles in size and encompasses most of the City of San Marcos and portions of the Cities of Vista, Escondido, and Carlsbad, as well as unincorporated areas of the County of San Diego between these cities. Students generated by the project would attend Richland Elementary School, Woodland Park Middle School, and Mission Hills High School.

Parks
There are 24 community parks, 13 neighborhood parks and three recreation centers in the City. The parks closest to the project site are Richmar Park and Hollandia Park. Richmar Park is located 0.25 mile west of the project site at 110 Richmar Avenue. Richmar Park is developed with adapted play

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equipment, a performance plaza, permanent restrooms, a picnic shelter, picnic tables, play equipment and turf play areas. Hollandia Park is located 0.8 miles east of the project site at 12 Mission Hills Court. Hollandia Park is developed with an amphitheater, lighted ballfield, barbeque area, dog park, horseshoe court, lighted multi-purpose fields, park space, permanent restrooms, a picnic shelter, play equipment, skate plaza and turf play areas.

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

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

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

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

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

Responsible Agencies
As defined by CEQA Guidelines Section 15381, a “Responsible Agency” includes all public agencies other than the lead agency which have discretionary approval power over the project. Subsequent to certification of the Final EIR, agencies with permitting aut hority over all or portions of the proposed project would use the Final EIR as the basis for their evaluation of environmental effects related to the proposed project that would culminate with the approval or denial of applicable permits. The California Department of Fish and Wildlife would be a Responsible Agency under CEQA if an Incidental Take Permit is required for the proposed project.

Trustee Agencies
As defined by CEQA Guidelines Section 15381, a “Trustee Agency” means a state agency having jurisdiction by law over natural resources affected by a project which are held in trust for the people of the State of California. The CDFW is a Trustee Agency with regard to the fish and wildlife of the state,

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to designate rare and endangered native plants, and to game refuges, ecological reserves, and other areas administered by the department. CDFW is a Trustee Agency for the project.

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

The EIR evaluates all subject areas listed in Appendix G to the CEQA Guidelines, with the exception of those subject areas determined not to have a potentially significant impact on the environment, as determined during preparation of the Initial Study (refer to Chapter 5 of the EIR). Chapter 3 of the EIR evaluates in detail, the following subject areas: aesthetics, air quality, biological resources, cultural resources, energy, geology and soils, hydrology and water quality, land use and planning, noise, public services, transportation, tribal cultural resources, utilities and service systems, and cumulative impacts. growth-inducing impacts are analyzed in Chapter 6.

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

2.4.2 Notice of Preparation and Scoping
CEQA establishes mechanisms to inform the public and decision makers about the nature of the proposed project and the extent and types of impacts that the proposed project and alternatives to the proposed project would have on the environment should the pr oposed project or alternatives be implemented. Pursuant to Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated August 21, 2023, to interested agencies, organizations, and parties. The NOP was also posted to the State Clearinghouse CEQANet portal. State Clearinghouse assigned a state identification number (SCH No 2023080449) to the EIR.

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

A public scoping meeting was held on August 30, 2023 in the Valley of Discovery Room at San Marcos City Hall and two community members attended. The 30-day public scoping period ended on September 20, 2023. A total of five NOP comment letters were received.

Comments received during the NOP public scoping period were considered part of the preparation of the EIR. The NOP and written comments are included in Appendices B.2 and B.3 to the EIR.

Environmental-related topics raised during the NOP comment period and scoping meeting include:
• Aesthetics: views from adjacent private homes;
• Biological Resources: MHCP, sensitive species, sensitive habitat, and biological resources mitigation

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• Cultural and Tribal Cultural Resources: compliance with Assembly Bill 52 and Senate Bill 18; • Land Use: provision of low-income or senior housing
• Noise: construction and vehicular noise, vibration from blasting • Public Services (police): City should consider having their own police department • Transportation (pedestrian): pedestrian safety
• Transportation (vehicular): congestion
• Utilities and Service Systems: water use
Public scoping comments regarding the proposed project’s potential impact on the environment have been incorporated in the analysis in the EIR in Sections 3.1 (Aesthetics), 3.3 (Biological Resources),

3.4 (Cultural Resources), 3.8 (Land Use – level of service analysis for traffic), 3.9 (Noise), 3.10 (Public Services), 3.11 (Transportation), 3.12 (Tribal Cultural Resources), and 4.0 (Alternatives).

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

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

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

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

Interested agencies and members of the public may submit written comments on the adequacy of the Draft EIR to the City’s Development Services Department at the address above, addressed to Scott Nightingale, Principal Planner or emailed at: [email protected] Comments on the Draft EIR must be received by the close of business on the last day of the 45 - day review period.

2.4.4 Final EIR Publication and Certification
Once the 45-day public review period has concluded, the City will review all public comments on the Draft EIR and provide a written response to all written comments pertaining to environmental issues

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as part of the Final EIR. The Final EIR will include all written comments received during the public review period; responses to comments; and, if applicable, edits and errata made to the Draft EIR. The City will then consider certification of the Final EIR (14 CCR 15090). If the EIR is certified, the City may consider project approval (14 CCR 15092).

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

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

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

The requested entitlements include a Specific Plan Amendme nt, Specific Plan, General Plan Amendment, Multi-Family Site Development Plan, Tentative Subdivision Map, Conditional Use Permit, among others listed and described in
Table 2-3. These entitlements would govern the development of the project site.

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

Table 2-3. Required Actions and Approvals
Agency Required Action/Approval
City of San Marcos – Lead Agency
• Specific Plan Amendment
• Specific Plan
• General Plan Amendment
• Multi-Family Site Development Plan
• Tentative Subdivision Map
• Conditional Use Permit
• Grading Plan/Permit
• Public Improvement Plan/Permit
• Landscape Plan/Permit
• Building Permits
• Blasting Permit

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Agency Required Action/Approval
San Diego Regional Water Quality
Control Board
National Pollutant Discharge Elimination System
Construction General Permit (State Water Resources
Control Board Order 2009-09-DWQ)
Vallecitos Water District Approval for water and sewer service

2.6 Project Inconsistencies with Applicable Regional and General Plans Throughout Chapter 3 of this EIR, the proposed project has been evaluated in relation to the applicable goals, policies, and objectives of: the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20 (Section 3.8, Land Use); Regional Air Quality Strategy (Section 3.2, Air Quality); San Diego Air Pollution Control District policies (Section 3.2, Air Quality); Regional Water Quality Control Board permits (Section 3.7, Hydrology and Water Quality); the Multiple Habitat Conservation Program (Section 3.3, Biological Resources); A irport Land Use Compatibility Plans (3.8, Land Use, 3.9, Noise, and 5.7, Hazards and Hazardous Material); the City’s Climate Action Plan (Section 5.6, Greenhouse Gas Emissions) and various other applicable regional and local plans and policies.

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

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

With the exception of the impact analyses of air quality, the cumulative list approach has been used in this cumulative analysis, as discussed below. The cumulative impacts of air quality has been

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evaluated using the summary of projections method because the geographic scope of such impacts tends to be broad and area wide.

An inventory of past, present, and reasonably foreseeable future projects within the vicinity of the project site is presented in
Table 2-4.

Table 2-4. Cumulative Projects
No. Project Location Description(1)
1 Armorlite Lofts 225 N. Las Posas Road 119 apartments and 5,600 s.f. of commercial
2 Breakers Real
Estate
Southeast corner of Twin
Oaks Valley Road and
Richmar Avenue
174 bed assisted living facility
3 CRP III Mission, LLC 528 W. Mission Road Redevelop existing 10.83 acre industrial park with 3 new industrial
buildings.
4 Hollandia Dairy CUP 620 E. Mission Road CUP to demolish and reconstruct a 100,000 s.f. portion of an existing
dairy.
5 Hollandia Farms
SDP
641 E. Mission Road Develop and establish a screened
outdoor construction contractor yard
on 12.45 acres. storage
6 Karl Strauss
Brewery & Tasting
Room
Northeast corner of Las
Posas Road and Vallecitos
Road
10,528 s.f. of commercial
7 Lanikai Senior
Residential
Northwest corner of E.

Mission Road and Woodward
Street
115 multi-family residential (MFR)
units (age-restricted for 55+)
8 Lonnie Tabbaa Southwest corner of W.

Mission Road and N. Las
Posas Road
Gas station, car wash, commercial
drive thru and convenience store
9 Mariposa II/Phase
1 Richmar Avenue and Los
Olivos Drive
100 MFR affordable units to replace
40 existing MFR units (net increase
of 60 units)
10 Mariposa II/Phase
2 Richmar Avenue and Los
Olivos Drive
96 MFR affordable units to replace
30 existing MFR units (net increase
of 66 units)
11 Meritage Homes
(Grand Vista Multi-
Family)

West of Las Posas Road and
Palm Road intersection
120 MFR units

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No. Project Location Description(1)
12 Pico Investments 236 Pico Avenue 16 MFR units
13 Twin Oaks Fuel Twin Oaks Valley Road and
Borden Road
Fuel station, 4,083 s.f. convenience
store, and car wash.
14 University District
Specific Plan and
Discovery Villages
Twin Oaks Valley Road, south
of SR-78, Discovery, and
Barham Street areas
Various projects within the University
District Specific Plan (North City) and
adjacent area:
• Block 3 student housing
• Discovery Village North -
Office/Commercial/Residential
• Discovery Village South - Single-
Family Residential
• SH North City, LLC - Condo Units,
Master Association Community
Rec Center, Public And Private
Trail Systems
• Univ District SPA – North City
Phase A&B - Mixed-Use
Development comprised of
20,000 s.f. retail, 100,00 s.f.
office, and 537 multi-family units
15 Villa Serena Northwest corner of Richmar
Avenue and Marcos Street
Demolish 136 MFR units and
construct 148 MFR units (net
increase of 12 units)
16 Woodmont Land
Company
Northeast corner of Twin
Oaks Valley Road and Windy
Way
11,430 s.f. preschool
Notes: (1) SFR = Single-Family Residential, MFR= Multi-Family Residential

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Figure 2-1a. Regional Location

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Figure 2-1b. Vicinity Map

SPRINTER
Station

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Figure 2-2-Conceptual Site Plan

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Figure 2-3. Conceptual Open Space Plan

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Figure 2-4. Conceptual Landscape Plan

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Figure 2-5a. Building A Elevations

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Figure 2-5b. Building A Enhanced Elevations

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Figure 2-6a. Building B Elevations

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Figure 2-6b. Building B Enhanced Elevations

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Figure 2-7. Conceptual Building Renderings

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Figure 2-8. Conceptual Wall and Fencing Plan

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Figure 2-9. Wall and Fencing Materials Examples

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Figure 2-10. Conceptual Lighting Plan

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Figure 2-11. Conceptual Circulation Plan

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Figure 2-12. Preliminary Brush Management Plan

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

After preparation of the Initial Study for the proposed project (Appendix B.1), it was concluded that impacts to agriculture/forestry resources, greenhouse gas emissions, hazards/hazardous materials, mineral resources, population and housing, recreation, a nd wildfire would be less than significant.

However, it was also concluded that the following issue areas could possibly result in significant impacts: aesthetics, air quality, biological resources, cultural resources, energy, geology and soils, hydrology and water quality, land use and planning, noise, public services, transportation, tribal cultural resources, and utilities and services systems. Therefore, this Environmental Impact Report (EIR) evaluates the potential for impacts related to these issue areas The 13 environmental topics analyzed in Sections 3.1 through 3.13 are organized as follows:
• Introduction – provides a brief overview to each section. • Existing Conditions – describes the existing environmental conditions on the project site as it relates to the specific environmental topic being addressed in the subchapter. • Regulatory Setting – describes the federal, state, regional, and local regulatory requirements applicable to the proposed project.
• Thresholds of Significance – describes the thresholds by which the significance of project impacts are determined. A “no impact” conclusion means the project will not have any impacts for a given threshold. A “less than significant impact” conclusion means the project may have an impact; however, the impact is not to a level that would be deemed significant per the given threshold. A “significant impact” means the project has an impact that meets or exceeds a threshold and mitigation is required to reduce the impact. • Project Impact Analysis – analyzes the project-level impacts, by threshold. • Cumulative Impact Analysis – analyzes the cumulative-level impacts of the project. Cumulative projects considered in this analysis are listed in Table 2-4 in Chapter 2.0, Project Description. • Mitigation Measures – identifies the mitigation measures to reduce project - and/or cumulative-level impacts to below a level of significance. • Conclusion – briefly summarizes the analysis of each section.

The focus of the environmental analysis in each of the following sections 3.1 through 3.13 is the suite of proposed actions as described in Chapter 2.0, Project Description.

3.0 Environmental Analysis
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3.1 Aesthetics
Introduction
This section addresses the aesthetic resources of the proposed project area and the potential effects that implementation of the proposed project may have related to aesthetics, including impacts to degradation of visual character and lighting/glare. The 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 website.1 In the Initial Study prepared for the proposed project ( Appendix B.1), it was determined that there would be no potential for the project to have an adverse impact on a scenic vista, nor would the project damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. Therefore, these issues will not be discussed further in the Environmental Impact Report (EIR). Section 5.1, Environmental Effects Found Not to be Significant – Aesthetics, of the EIR provides additional information on this topic.

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

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

Less Than
Significant
Less Than
Significant
Less Than
Significant
Without
Mitigation

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

The City of San Marcos (City) is in the northern portion of San Diego County. The majority of the City is located on the valley floor, with State Route 78 (SR -78) running through the center of the City.

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

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Landforms such as the mountain ranges to the north and south of San Marcos contribute to its scenic corridors.

The project site is located on the east side of Woodward Street, generally between E. Mission Road to the south and Vineyard Road to the north in the Richland neighborhood in the City. The project site is undeveloped and steeply slopped. Elevation ranges from 754 feet above mean sea level (amsl) 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). No drainages or wetlands occur on the project site. The project vicinity includes single-family residential neighborhoods to the north and east, multi- family residential development to the south, and undeveloped land to the west across Woodward Street. Directly north of the project site is an area designated as Open Space in the City’s General Plan.

The City of San Marcos Civic Center is located south of the project site and contains a mix of institutional, office, and medical office uses as well as adjacent commercial land uses which offer a variety of retail space, restaurants, service uses, and shopping. The Civic Center SPRINTER rail station is located approximately 0.1-mile from the project site at the intersection of E. Mission Road and San Marcos Boulevard.

Figure 3.1-1 provides an overview of the locations for photos simulations prepared for the project.

Figures 3.1-2 through 3.1-5 provide current and future views of the project site from area roadways.

Existing Light and Glare Conditions
The project site is currently undeveloped and thus does not contain any existing sources of light or glare. Additionally, the project site does not contain any reflective surfaces that would function as sources for glare. The project vicinity contains sources of nighttime lighting typical of residential uses.

The project site is adjacent to developed areas and typical lighting sources in the project vicinity would include outdoor lighting fixtures on structures, in parking areas, and street lights on poles. Additionally, the project site is adjacent to Woodward Street and near E. Mission Road and vehicular headlights are visible at night. There are no sources of substantial glare present in this area.

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

Local
San Marcos General Plan – Conservation and Open Space Element The following goal and policies from the City of San Marcos General Plan, Conservation and Open Space Element pertain to aesthetics and visual quality:
• Goal COS-3: Protect natural topography to preserve and enhance the natural beauty of San Marcos.
o Policy COS-3.1: Preserve scenic resources, including prominent landforms such as Double Peak, Owens Peak, San Marcos Mountains, Merriam Mountains, Cerro de Las Posas, Franks Peak, and canyon areas through conservation and management policies.

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o Policy COS -3.2: Encourage and maintain high -quality architectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character in San Marcos.
o Policy COS -3.3: Continue to work with new development and redevelopment project applicants in designing land use plans that respect the topography, landforms, view corridors, wildlife corridors, and open space that exists. o Policy COS-3.4: Evaluate potential impacts to visual and aesthetic resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, Land Use and Planning. As detailed in Table 3.8-12 in Section 3.8, the project is consistent with all the applicable goals and policies.

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

The San Marcos Municipal Code Zoning Ordinance Title 20 is the primary implementation tool for the policies of the General Plan. The Zoning Ordinance provides more detailed direction related to design and development standards; permitted, conditionally permitted, and prohibited uses; and other regulations such as lighting and sign regulations. The land uses specified in the Zoning Ordinance are based upon and consistent with the land use policies set forth in the General Plan. Specifically, building design, setbacks, lighting, and signage standards as well as open space requirements for development to protect open space and ambient light levels in the city. T he lighting standards of the Ordinance require energy -efficient lighting that limits light and glare for private projects, with exceptions for specialized streetscape lighting. Private developments are required to submit lighting plans to ensure consistency with dark sky needs of the region (City of San Marcos 2023a).

Title 20, Section 20.300.080, Site Planning and General Development Standards The City of San Marcos Street Lighting Standards and Specifications describes the lighting and glare standards for the city. These standards require lighting to be directed downward and limit the type and spacing of lighting to maintain reasonable lighting levels that do not contribute to light pollution. The City uses International Dark Sky Association thresholds to inform its own testing, leading to a policy that allows for the use of energy -efficient lighting sources that include, but are not limited to, light- emitting diode (LED) and induction lighting technologies (City of San Marcos 2023b).

Title 20, Chapter 20.260, Ridgeline Protection and Management Overlay Zone The City of San Marcos adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008-1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, mi nimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, and Ridgeline Overlay Zones (ROZ), surrounding these ridgelines (City of San Marcos 2023b). No primary or secondary ridgelines are located within or adjacent to the project site. The nearest primary ridgeline is within the North City Area #1 map and includes Owens Peak and “P” Mountain. This primary ridgeline is located approximately 1.25 miles northwest of the project site.

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3.1.3 Thresholds of Significance
According to Appendix G of the California Environmental Quality Act (CEQA) Guidelines , visual quality and aesthetics impacts are considered potentially significant if the project would:
• Threshold #1: In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanize d area, would the project conflict with applicable zoning and other regulations governing scenic quality.
• Threshold #2: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

3.1.4 Project Impact Analysis
Construction
Project construction involves grading and site preparation activities to prepare the site for future buildings and infrastructure improvements. The project design incorporates retaining walls to manage the topography of the site and create areas for the access driveway and building pads. The proposed retaining walls include slump block, geogrid, and soil nail styles, depending on the location within the project. The retaining wall would be earth -tone color and textured to blend in with the surrounding terrain. Construction would require staging areas with construction equipment and supplies, and portable trailers to serve as temporary office space or storage. Grading on the site would change or alter the existing topography on the project site to prepare the site for development. The project plans are included in Appendix A.3.

Operations
The project proposes 46 duplex residential units on 8.57 gross acres. The conceptual site plan is included as Figure 2-2 in Chapter 2. The proposed project would be developed with two building types (Elevation A and Elevation B). Each building type would provide a variation of contemporary/modern style architecture. Figure 2-5 and Figure 2-6 present conceptual building elevations for each elevation type and Figure 2-7 presents the rendered building elevations. The proposed residential units would all be thr ee bedroom and 3.5 baths and range from 1,585 square feet ( s.f.) to 1,900 s .f. The units would be three stories and approximately 35 feet in height. Each unit would have a two-car garage.

Figures 3.1-2 through 3.1 -7 provide visual simulations of the proposed development from offsite locations, including Woodward Street, Mission Road, and the bridge on Twin Oaks Valley Road.

The proposed landscape plan includes a mix of trees, shrubs, and groundcover and the plant selection emphasizes low and moderate water use species and would be suitable for rocky slope conditions .

Proposed tree species include: evergreen elm, Marina strawberry tree, Chitalpa pink dawn, Australian willow, Tuscarora crape myrtle, Chinese pistache, African suman, eastern redbud, bronze loquat, sweetshade, shrubby yew podocarpus, Torrey pine, coast li ve oak, southern live oak, Brisbane box, and little gem magno lia. The plant palette for the manufactured slopes would blend in with the surrounding native vegetation. The proposed project would also comply with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20. The landscape concept plan is included as Figure 2-4 and the complete landscape plan and planting palette is included in Appendix A.4.

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

While this is less than 100,000 persons, the City of San Marcos is contiguous with the City of Escondido, which has an estimated population of 151,074 persons as of July 1, 2022 (USCB 2023).

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

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

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

The project site has a General Plan and zoning d esignation 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.

The City of San Marcos adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008-1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, mi nimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, or ROZ surrounding these ridgelines (City of San Marcos 2023b).

No primary or secondary ridgelines are located within or adjacent to the project site. The nearest primary ridgeline is within the North City Area #1 map and includes Owens Peak and “P” Mountain.

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This primary ridgeline is located approximately 1.25 miles northwest of the project site. The project would not result in any visual impact to primary and secondary ridgelines. Therefore, the project would not conflict with the ordinance.

Figures 3.1-2 through 3.1-5 provide a comparison of the existing view and a visual simulation of the future view with implementation of the project from offsite locations, including Woodward Street, E.

Mission Road, and the bridge on Twin Oaks Valley Road. The greatest level of visual change would be from the Twin Oaks Valley Road bridge, as shown in Figure 3.1-4. In the current view, the project area is undeveloped and covered in vegetation. The existing trees and h omes on Silk Mill Place, which sit at a higher elevation than the project site, are visible. With construction of the proposed project, the project site would change to a graded site with retaining walls and residential development. The future development would sit, visually, below the existing homes on Silk Mill place. The use neutral colors on the retaining walls and the future homes, as well as the implementation of the landscape plan and plant palette for the manufactured slopes that would blend in with the surrounding native vegetation would soften the look of the development from offsite views.

The project’s consistency with the General Plan goals and policies related to scenic views and aesthetics is presented in Table 3.8 -12 in Section 3.8, Land Use and Planning. No conflicts were identified.

The proposed architectural style takes inspiration from contemporary/modern style architecture.

Elements and materials traditionally used for this style include angular pitched roofs using concrete roof tiles, simple forms with stucco or stone veneer walls, metal and stucco railings, and awnings. The architecture was chosen to complement existing architecture adjacent to the project site. The architectural style would be complemented with a color scheme that incorporates neutral wall colors to complement th e project with nearby development within the area and minimize the potential for visual impacts due to the highly visible nature of the project site. The project would also use low - reflective window glass. The Specific Plan identifies design concepts to minimize the bulk and scale of the project including using building-form elements such as place breaks, roof forms, and changes in materials to define individual units; articulating the front and rear elevations both vertically and horizontally; and avoiding long unbroken surfaces on front and rear elevations by providing a change in plane at least every 25 feet. Figures 3.1 -2 through 3.1-7 show renderings of the proposed development from offsite locations.

The proposed landscape plan would further enhance the project site through implementation of a comprehensive and aesthetically pleasing landscape design, which would be maintained by the Homeowners Association. The landscape plan is included as Appendix A.4 of the EIR. The project would not conflict with applicable zoning and other regulations governing scenic quality and impacts would be
less than significant.

Threshold #2: Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Excessive, poorly designed, or unshielded lighting can be detrimental to astronomical observations.

Two observatories are located in San Diego County: Palomar Observatory, located over 20 miles northeast of the proposed project site, and Mount Laguna Obser vatory - located approximately 50 miles southeast of the proposed project site.

Lighting in the project vicinity is associated with roadway lighting along E. Mission Road and lighting associated with existing residential uses in the area and immediately adjacent to the project site.

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Development of the proposed project would introduce permanent lighting to a site that is currently undeveloped and does not have lighting.

Exterior lighting for the proposed project would be used to accent landscaping and provide safety and accent lighting for duplex buildings. The project’s lighting plan is included in Figure 2-10 in Chapter 2.

As proposed, the project’s exterior lighting would include street and parking area lighting on poles, building lighting, monument and tree accent lighting and a backlit fire directory. All lighting fixtures for the proposed project would be energy efficient, architecturally appropriate, and designed to minimize glare, conflict, and light pollution, while providing illumination levels that create a safe environment for both vehicles and pedestrians. Street area lights w ould be full cut -off fixtures and w ould utilize house-side shields to reduce light trespass and prevent light pollution. Common area lighting w ould be used to enhance and complement the character of the development. Section 4.2.6 of the Specific Plan (Appendix A.1 of the EIR) details the guidelines related to proposed lighting. Lighting wou ld be required to conform with the City’s lighting ordinance and standards, (San Marcos Municipal Code Title 20, Section 20.300.080).

The project does not propose features that would be characterized as creating a new source of glare that would adversely affect daytime or nighttime views in the area. The proposed materials include concrete roof tiles, simple forms with stucco or stone ve neer walls, metal and stucco railings, and awnings. The roof and wall colors and materials are not reflective and would not create significant sources of glare.

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

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

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

From Owen’s Peak and “P” Mountain, the closest primary ridgelines to the project site, viewers may be able to see cumulative projects in the same viewshed, and portions of the project site. The proposed buildings would be a maximum of 35 feet in height. There is existing development in the project vicinity including single family residences on the hill side and knoll above the project site and three -story condominiums to the south. The project would not substantially contrast with the visual patterns of the area. The project would appear as an extension of the already urbanized landscape. When the proposed project is considered with other cumulative projects in the same viewshed, cumulatively, the

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increase in development would blend in with the existing urban landscape and would not result in a significant visual impact. Therefore, the proposed project would not substantially contribute to a cumulative change in the visual character of the surrounding area.

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

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

3.1.7 Conclusion
The project site is in an urbanized area and would not conflict with applicable zoning and other regulations governing scenic quality, including the scenic resource protection policies in the Conservation and Open Space Element of the City’s General Plan (refer to Section 3.8, Land Use and Planning). Implementation of the proposed project would not result in any conflicts with existing zoning policies that address visual quality and scenic resources. Landscaping associated with the project would also soften views of the project site from adjacent uses.

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

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Figure 3.1-1 Photo Simulation Overview

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Figure 3.1-2 Photo Simulation 1 (Southbound Woodward Street at Vineyard Road)

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Figure 3.1-3 Photo Simulation 2 (Southbound Woodward Street)

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Figure 3.1-4 Photo Simulation 3 (From Twin Oaks Valley Road Bridge Looking at Project Site)

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Figure 3.1-5 Photo Simulation 4 (Northbound Woodward Street at Mission Road)

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Figure 3.1-6 Photo Simulation 5 (Rendering of Project Entrance at Woodward Street)

Figure 3.1-7 Photo Simulation 6 (Rendering of Project from the Entrance to Mission 316 West)

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3.2 Air Quality
Introduction
This section identifies, describes, and evaluates air quality issues associated with the proposed project. An analysis of the proposed project’s consistency with the City’s Climate Action Plan is included in Section 5.6 (Environmental Effects Found Not to be Significant – Greenhouse Gas).

This section analyzes short-term construction impacts and long-term operational impacts to air quality and determines whether the project would result in a significant air quality impact. This section is based upon the following report, which is included as Appendix C of the Environmental Impact Report2:
• Air Quality Assessment, Woodward 46 Specific Plan (SP22 -0005, SP22-0006, GPA22-0004, MFSD22-0005, TSM22-0004, prepared by LDN Consulting, January 7, 2025 (LDN 2025).

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

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

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

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

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

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

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

Meteorological trends within the City of San Marcos (City) produce daytime highs typically ranging between 64ºF in the winter to approximately 88ºF in the summer with August usually being the hottest month. Daytime low temperatures range from approximately 37ºF in the winter to approximately 59ºF in the summer. Precipitation is generally about 16.2 inches per year. Prevailing wind patterns for the area vary during any given month during the year and vary depending on the time of day or night. The predominant pattern throughout the year is usually from the west or westerly (LDN 2025).

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

Project area air quality can best be characterized by using ambient measurements made by the SDAPCD. SDAPCD operates a network of ambient air monitoring stations throughout San Diego County, which measure ambient concentrations of pollutants and determine whether the ambient air quality meets national and state air quality standards. Pursuant to the 1990 Clean Air Act amendments, U.S.

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

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

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Table 3.2-2. San Diego County Air Basin Attainment Status by Pollutant Criteria Pollutant Federal Designation State Designation Ozone (O3) – 8-hour Nonattainment Nonattainment
Ozone (O3) – 1-hour Attainment (1) Nonattainment
Carbon Monoxide (CO) Attainment Attainment
Respirable Particulate Matter (PM10) Unclassifiable (2) Nonattainment Fine Particulate Matter (PM2.5) Attainment Nonattainment (3) Nitrogen Dioxide (NO2) Attainment Attainment
Sulfur Dioxide (SO2) Attainment Attainment
Lead (Pb) Attainment Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Visibility Reducing Particles No Federal Standard Unclassified Source: SDAPCD 2023.

Notes: (1) The federal 1-hour standard of 12 parts per hundred million (PPHM) was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in State Implementation Plans.
(2) At the time of designation, if the available data does not support a designation of attainment or nonattainment, the area is designated as unclassifiable.
(3) The California Air Resources Board (CARB) has not reclassified the region to attainment yet due to (1) incomplete data, and (2) the use of non-California Approved Samplers (CAS). While data collected does meet the requirements for designation of attainment with federal PM

2.5 standards, the data completeness requirements for state PM 2.5 standards substantially exceed federal requirements and mandates and have historically not been feasible for most air districts to adhere to given local resources. SDAPCD has begun replacing most regional filter -based PM 2.5 monitors as they reach the end of their useful life with continuous PM2.5 air monitors to ensure collected data meets stringent completeness requirements in the future. SDAPCD anticipates these new monitors will be approved as "CAS" monitors once CARB reviews the list of approved monitors, which has not been updated since 2013.

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

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

The immediate project vicinity includes single-family residential neighborhoods to the north and east, multi-family residential developments to the south, and undeveloped land to the west across Woodward Street. Directly north of the project site is an area designated as Open Space in the City’s General Plan. The City of San Marcos Civic Center is located south of the project site and contains a mix of institutional, office, and medical office uses as well as adjacent commercial land uses which

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offer a variety of retail space, restaurants, service uses, and shopping. The Civic Center SPRINTER rail station is located approximately 0.1 -mile from the project site at the intersection of E. Mission Road and San Marcos Boulevard.

Table 3.2-3. Two Year Ambient Air Quality Summary Near the Project Site (Camp Pendleton or Carmel Mountain Ranch Stations)
Pollutant(1) Averaging
Time CAAQS NAAQS 2021 2022
Days
Exceeded
Over 2 Years
O3
(ppm)
1 hour 0.09 ppm No Standard 0.07 0.08 0
8 hour 0.070 ppm 0.070 ppm 0.06 0.07 0
PM10 (3)
(µg/m3)
24 hour 50 µg/m3 150 µg/m3 PM10 Data Not Available for Monitoring Sites near Project Site. Annual(2) 20 µg/m3 No Standard PM2.5 (3)
(µg/m3)
24 hour No Standard 35 µg/m3 23.5 14.9 N/A
Annual(2) 12 µg/m3 15 µg/m3 8.5 7.6 N/A
NO2
(ppm)
Annual(2) 0.030 ppm 0.053 ppm 0.013 0.013 N/A
1 hour 0.18 ppm 0.100 ppm 0.059 0.059 N/A
CO(2)
(ppm)
1 hour 20 ppm 35 ppm 3.0 2.2 N/A
8 hour 9 ppm 9 ppm 1.8 1.2 N/A
Source: LDN 2025.

Notes: (1) SO2 is only monitored at the El Cajon Monitoring Station. Within the entire County of San Diego, SO2 emissions within the County are essentially Zero for all metrics including the Average, Maximum 24 hour and 1- hour standards. The Highest 1-hr measurement identified is 0.004 ppm and the most restrictive standard (CAAQS for SO2) is 0.25 ppm.
(2) Annual arithmetic mean
(3) Data was collected from Carmel Mountain Ranch station which began in 2019. All other data presented was collected at the Camp Pendleton Monitoring Station
ppm = parts per million
µg/m3 = micrograms per cubic meter
Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, w ith an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. The criteria air pollutants that are monitor ed by the US EPA are ozone (O
3), carbon monoxide (CO), nitrogen dioxide (NO 2),
particulate matter less than or equal to 10 microns or 2.5 microns in diameter (PM10, and PM2.5) sulfur dioxide (SO2), and lead (Pb). These pollutants, as well as toxic air contaminants (TACs), are discussed in the following text. In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility-reducing particles are also regulated as criteria air pollutants. Examples of sources and effects of these pollutants are identified below:

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

It is a product of the photochemical process involving the sun's energy. O 3 exists in the upper

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

It should be noted that Oxides of Nitrogen (NOx) is a family of poisonous, highly reactive gases. These gases form when fuel is burned at high temperatures. NOx pollution is emitted by automobiles, trucks, and various non-road vehicles (e.g., construction equipment, boats, etc.) as well as industrial sources such as power plants, industrial boilers, cement kilns, and turbines. NOx often appears as a browning gas. It is a strong oxidizing agent and plays a major role in the atmospheric reactions with Volatil e Organic Compounds (VOCs) which produce ozone on hot summer days (LDN 2025).

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

Nitrogen Dioxide (NO2): NO2 is formed when nitrogen (N2) combines with oxygen (O 2). Its life span in the atmosphere ranges from one to seven days. NO2 is typically created during combustion processes and is a major contributor to smog formation and acid deposition. NO2 may result in numerous adverse health effects, including respiratory damage. It absorbs blue light, resulting in a brownish -red cast to the atmosphere and reduced visibility.

Particulate Matter Less Than or Equal to 10 Microns in Diameter (PM10) : A major air pollutant consisting of tiny solid or liquid particles of soot, dust, smoke, fumes, and aerosols. The size of the particles (equal to 10 microns or smaller, about 0.0004 inch or less in diameter) allows them to easily enter the lungs where they may be deposited, resulting in adverse health effects, including allergies, asthma, and respiratory illness. PM
10 also causes visibility reduction.

Particulate Matter Less Than or Equal to 2.5 Microns in Diameter (PM2.5) : A similar air pollutant to PM10 consisting of tiny solid or liquid particles which are 2.5 microns or smaller (which are often referred to as fine particles). These particles are formed in the atmosphere from primary gaseous emissions that include sulfates formed from SO 2 released from power plants and industrial facilities and nitrates that are formed from NO x released from power plants, automobiles, and other types of combustion sources. The chemical composition of fine particles depends mostly on location of the emissions, time of year, and weather conditions. Adverse health effects of PM 2.5 are similar to those of PM10.

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

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

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

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

Hydrogen Sulfide (H2S): A colorless, toxic, and flammable gas with a recognizable smell of rotten eggs or flatulence, H2S occurs naturally in crude petroleum, natural gas, volcanic gases, and hot springs .

Exposure to low concentrations of hydrogen sulfide may cause irritation to the eyes, nose, or throat. It may also cause difficulty in breathing for some asthmatics. Brief exposures to high concentrations of H2S (greater than 500 parts per million) can cause a loss of consciousness and possibly death.

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

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

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

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

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

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

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

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

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

Table 3.2-4. Ambient Air Quality Standards
Pollutant Average
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Measurement Method7 Ozone (O3)8
1 Hour 0.09 ppm
(180 µg/m3) Ultraviolet
Photometry

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

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

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Pollutant Average
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Measurement Method7 Nitrogen
Dioxide
(NO2)10
Annual
Arithmetic
Mean

0.030 ppm
(57 µg/m3) Gas Phase
Chemilumi-
nescence

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

0.100 ppm8
(188/ µg/m3) -
Sulfur
Dioxide
(SO2)11
Annual
Arithmetic
Mean
-
Ultraviolet
Fluorescence

0.030 ppm10
(for Certain
Areas)
-
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararoosaniline
Method)9
24 Hour 0.04 ppm
(105 µg/m3)

0.14 ppm10
(for Certain
Areas) (See
Footnote 9)
-
3 Hour - 0.5 ppm
(1300 µg/m3)
1 Hour 0.25 ppm
(655 µg/m3)
75 ppb
(196 µg/m3)
Lead12,13
30 Day
Average 1.5 µg/m3
Atomic
Absorption
-
Calendar
Quarter - 1.5 µg/m3
Same as Primary
Standard
High Volume Sampler
and Atomic Absorption Rolling 3-
Month
Average

0.15 µg/m3
Visibility
Reducing
Particles
8 Hour See footnote 13
No National Standards
Sulfates 24 Hour 25 µg/m3 Ion
Chromatography
Hydrogen
Sulfide 1 Hour 0.03 ppm
(42 µg/m3)
Ultraviolet
Fluorescence
Vinyl
Chloride12
24 Hour 0.01 ppm
(26 µg/m3)
Gas
Chromatography

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

2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24- hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/m
3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.

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

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

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

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

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Pollutant Average
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Measurement Method7

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

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

9. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3 .

The existing national 24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3 , as was the annual secondary standard of 15 μg/m3 . The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.

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

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

12. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

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

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

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

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

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but some areas, including San Diego County, have still not met the 2008 standard and their attainment status changed in level of severity.

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

The CARB has established California ambient air quality standards (CAAQS), which are generally more restrictive than the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before a basin can attain the standard. Air quality is considered “in attainment” if pollutant levels are continuously below the CAAQS and violate the standards no more than once each year. The CAAQS for O
3, CO, SO 2 (1-hour and 24 -hour), NO2, PM10, and PM 2.5 and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded.

Additionally, sulfates, vinyl chloride, hydrogen sulfide, and visibility -reducing particles are also regulated as criteria air pollutants in California. The CAAQS cur rently in effect in California are also shown in Table 3.2-4 and include the most recently adopted federal standards for chronic (8-hour) O3 exposure and for ultra -small diameter particulate matter of 2.5 microns or less in diameter (PM 2.5).

CAAQS restrict four additional contaminants: visibility reducing particles, sulfates, hydrogen sulfide, and vinyl chloride. Current attainment designations for the SDAPCD are presented in Table 3.2-2.

California Clean Air Act
The California Clean Air Act (CCAA), signed into law in 1988, requires all areas of the state to achieve and maintain the CAAQS by the earliest practical date. Air pollution from commercial and industrial facilities is regulated by local air quality management districts, whereas mobile sources of air pollution are regulated by the California Air Resources Board (CARB) and the USEPA. All air pollution control districts have been formally designated as “attainment” or “nonattainment” for each state air quality standard, as shown in Table 3.2-2. Areas in California where ambient air concentrations of pollutants are higher than the state standard are considered to be in “non-attainment” status for that pollutant.

If there are inadequate or inconclusive data to make a definitive attainment designation, districts are considered “unclassified.”
California Health and Safety Code Section 41700
Section 41700 of the California Health and Safety Code states that a person must not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of pe rsons or to the public; that endanger the comfort, repose, health, or safety of any of those persons or the public; or that cause, or have a natural tendency to cause injury or damage to business or property. This section also applies to sources of objectionable odor.

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Local
San Diego Air Pollution Control District
Although CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources. The project is located within the SDAB and is subject to SDAPCD guidelines and regulations. In San Diego County, O
3 and particulate matter are the pollutants of main
concern, because exceedances of the CAAQS for those pollutants are experienced here in most years.

In J anuary 2021, SDAPCD sent a request to EPA to reclassify San Diego County from Serious Nonattainment to Severe Nonattainment for the 2008 ozone NAAQS and from Moderate to Severe Nonattainment for the 2015 ozone NAAQs. EPA granted this request in April 2021. SDAPCD prepared and submit ted to the USEPA, via CARB, ozone attainment plans identifying control measures and associated emissions reductions necessary to demonstrate attainment of the 75-ppb 2008 standard by July 20, 2027 and attainment of the 70-ppb 201 5 standard by August 3, 2033. Reclassification imposes additional requirements under the CAA (for example, transportation control strategies and measures to offset emissions increases from vehicle miles traveled) that will help ensure the area has the tools needed to attain the standard . The 2020 Plan for Attaining the National Ozone Standards (SDAPCD 2020) addresses all requirements for both ozone standards.

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

3. The RAQS details how the region will manage and reduce O3 precursors (NOx and VOCs) by identifying measures and regulations intended to reduce these contaminants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potentia l sources, including those under the authority of CARB and USEPA. Incentive programs for reduction of emissions from heavy -duty diesel vehicles, off-road equipment, and school buses are also established in the RAQS.

The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that th e strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the development of their general plans. Projects that produce less growth than predicted by SANDAG would generally conform to the RAQS.

City of San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan identifies one goal and several policies regarding air quality. Those policies that are applicable to the project are listed below:
• Goal COS-4: Improve regional air quality and reduce greenhouse gas emissions that contribute to climate change.
o Policy COS-4.1: Continue to work with the U.S. EPA, CARB, SANDAG, and the SDAPCD to meet State and federal ambient air quality standards.
o Policy COS-4.5: Encourage energy conservation and the use of alternative energy sources within the community.

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o Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
o Policy COS -4.8: Encourage and support the generation, transmission, and use of renewable energy.

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

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.8, 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 air quality.

3.2.3 Thresholds of Significance
The State of California has developed guidelines to address the significance of air quality impacts based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines which provides guidance that a project would have a significant environmental impact if it would:
• Threshold #1: Conflict with or obstruct implementation of the applicable air quality plan; • Threshold #2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard;
• Threshold #3: Expose sensitive receptors to substantial pollutant concentrations; • Threshold #4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
To determine whether a project would: (a) result in emissions that would violate any air quality standard or contribute substantially to an existing or projected air quality violation; or (b) result in a cumulatively considerable net increase of PM
10 or PM 2.5 or exceed quantitative thresholds for O 3
precursors, nitrogen oxides (NO x) and volatile organic compounds (VOCs), project emissions may be evaluated based on the quantitative emission thresholds established by the SDAPCD, the agency responsible for air quality planning, monitoring, and enforcement within this basin. As part of its air quality permitting process, the SDAPCD has established thresholds in Rule 20.2 for the preparation of Air Quality Impact Assessments (AQIAs) (SDAPCD 2019).

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

The thresholds listed in Table 3.2-5 represent screening-level thresholds that can be used to evaluate whether project-related emissions could cause a significant impact on air quality for both construction

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and operation. Emissions below the screening-level thresholds would not cause a significant impact.

If emissions exceed these thresholds, modeling would be required to demonstrate that the project’s total air quality impacts result in ground -level concentrations that are below the State and Federal AAQS, including appropriate background levels. For nonattainment pollutants (PM10 and PM2.5 plus O3, with O3 precursors NOx and VOCs), if emissions exceed the thresholds shown in Table 3.2-5, the project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality.

Table 3.2-5. Screening-Level Criteria for Air Quality Impacts Pollutant Total Emissions (Pounds/Day)
Construction Emissions
Respirable Particulate Matter (PM10) 100
Particulate Matter (PM2.5) 55
Nitrogen Oxide (NOx) 250
Sulfur Oxide (SOx) 250
Carbon Monoxide (CO) 550
Volatile Organic Compounds (VOCs) 75
Reactive Organic Gases (ROG) (SCAQMD) 75
Operational Emissions
Respirable Particulate Matter (PM10) 100
Particulate Matter (PM2.5) 55
Nitrogen Oxide (NOx) 250
Sulfur Oxide (SOx) 250
Carbon Monoxide (CO) 550
Lead and Lead Compounds 3.2
Volatile Organic Compounds (VOCs) (1) 75
Reactive Organic Gases (ROG) SCAQMD(1) 75
Source: LDN 2025.

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

In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as toxic air contaminants (TACs) or Hazardous Air Pollutants (HAPs). SDAPCD Regulation XII establishes acceptable risk levels and emission control requirements for new and modified facilities that may emit additional TACs. Under Rule 1210 (adopted in 1996 and revised several times, most recently 2021), emissions of TACs that result in a cancer risk of 10 in 1 million or less and a health hazard index of one or less would not be required to notify the

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public of potential health risks. If a project has the potential to result in emissions of any TAC or HAP that results in a cancer risk of greater than 10 in 1 million, the project would be deemed to have a potentially significant impact and would be requi red to implement toxics best available control technology (T-BACT) (SDAPCD 2021).

SDAPCD Rule 51 (Public Nuisance) also prohibits emission of any material which causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person (SDAPCD 1976). A project that proposes a use which would produce objectionable odors, such as agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (CARB 2005) would be deemed to have a significant odor impact if it would affect a considerable number of offsite receptors. The impacts associated with construction and operation of the project were evaluated for significance based on the aforementioned significance criteria.

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

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

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 proper ties 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.

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.

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In addition, the project conforms to all local air district significance thresholds. As discussed below in Threshold #2 and shown in Tables 3.2-6 and 3.2-7, air quality emissions generated by the project would be much lower (at least five times lower) than the SDAPCD screening thresholds. Since the project would not generate significant direct or cumulative construction or operational impacts, the project would therefore be considered consistent with the County’s RAQS and would comply with the state’s SIP. Impacts would be less than significant.

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

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

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

Construction grading operations for the project are anticipated to include 41,989 cubic yards (cy) of cut material . With over-excavation and bulking, the total fill volume would be 50,270 cy, for a difference of 8,281 cy. If suitable, the excess material would be used as wall backfill and the site would balance. If it is not suitable, the 8,281 cy would be exported from the site. For purposes of the air quality analysis, to be conservative , it was assumed that as much as 10,000 cy of export would be required. The project would start grading sometime in 2025 with residential construction to start shortly thereafter.

The California Emissions Estimator Model (CalEEMod) 202 2.1 was used to calculate the emissions associated with the construction of the project and uses methodologies presented in the US EPA AP - 42 document with emphasis on Chapter 11.9. Earthwork associated with grading within CalEEMod uses a “Grading Equipment Pas ses” methodology which has been approved by SCAQMD in consultation with building estimator references and is used as the basis of emission generatio n. The AERSCREEN dispersion model was used to determine the concentration for air pollutants at any location near the pollutant generator as well as to predict the maximum exposure distance and concentrations. The following design features were assumed within the CalEEMod analysis:
• All heavy diesel construction equipment would be classified as Tier IV • In accordance with Rule 67 of the California Air Resource Board, only Low VOC paints shall be utilized onsite.
• Compliance with SDAPCD Rule 55 (Fugitive Dust) and fugitive dust control measures, which would be provided by the City of San Marcos.

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In addition, due to bedrock conditions, the project also may require some blasting -related activities.

During blasting operations, grading operations would temporarily stop and resume once blasting is completed. It is expected that each blast operation would require between 10,000 - 12,000 pounds (lbs) (5-6 tons) of ammonium nitrate. Blasting operations usually require a chemical material that is capable of extremely rapid combustion resulting in an explosion or detonation. These materials are usually mixtures of several ingredients but are often oxygen deficient as combustion reactions take place which causes a formation of carbon monoxide and to a lesser extent, nitrogen oxides. For ammonium nitrate and fuel oil (ANFO) mixtures , it is expected that carbon monoxide would be generated in quantities of 67 pounds per every ton of explosives and nitrogen oxides would be generated at 17 pounds per the same quantity. Particulate matter will also be generated from blasting and was estimated using US EPA AP-42 (Compilation of Air Emissions Factors from Stationary Sources) methodology (Table 11.9-1)
3 (LDN 2025).

The proposed project would utilize approximately 6 tons of ammonium nitrate per blast which would generate up to 402 lbs (67 lbs/ton * 6 tons) of carbon monoxide and up to 102 lbs (17 lbs/ton * 6 tons) of nitrogen oxides during a blast . These quantities would be additive to the mass grading operations for the entire project site and were added to the worst-case mass grading daily CO and NOx output. Additional particulates derived from each blast is estimated to be over a 20,000 s.f. area (roughly 100-foot by 200-foot in dimension). Given this, it is estimated that each blast would generate

20.59 lbs/blast. A blasting permit would be required from the San Marcos Fire Department which would include required terms and would limit the blasting material to 6 tons per day as this was indicated as the expected blast charge.

The project’s requested approvals include a Conditional Use Permit (CUP 22--0005), which would allow for the use of a temporary rock crusher. The rock crusher , a Thunderbird Hazemag impact crusher, would be located in the central portion of the site to provide the most distance from adjacent residential uses. The crusher would be approximately 329 feet from the residential use to the east, 667 feet from the closest residential use to the north and 531 feet from the closest residential use to the south.

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

Operational Emissions Analysis
Daily project operations would generate emissions from sources such as area, energy, mobile, waste and water use. Area Sources include consumer products, landscaping, and architectural coatings as part of regular maintenance. Operational emissions were cal culated using the CalEEMod 2022.1 model for both summer and winter scenarios and assumed average winter and summer temperatures.

The traffic inputs for CalEEMod were adjusted to be consistent with the proposed project traffic study.

Based on that study, the proposed project would generate 368 net average daily trips (LLG 2023).

3 Table 11.9- 1 is Emissions Factor Equations for Uncontrolled Open Dust Surfaces at Western Surface Coal Mines https://www.epa.gov/sites/default/files/2020-10/documents/c11s09.pdf

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Table 3.2-6. Construction Emissions (pounds/day)
Year ROG NOx CO SO2 PM10
Dust
PM10
Exhaust
PM10
(Total)
PM2.5
Dust
PM2.5
Exhaust
PM2.5
(Total)
2025 7.17 6.57 33.2 0.07 0.15 20.9 21 0.15 10.4 10.5
2026 0.37 2.31 15.7 0.02 0.04 0.31 0.36 0.04 0.07 0.12
Blasting
Emissions(1)
102 402 20.59 20.59
Total
Construction
with Blasting
Emissions
(Maximum)

7.17 108.57 435.2 0.07 20.74 20.9 41.59 0.15 10.4 10.5
Screening
Level
Threshold
75 250 550 250 - - 100 - - 55
Exceed
Threshold?
No No No No - - No - - No
Source: LDN 2025.

Notes: (1) The project would utilize approximately 6 tons of ammonium nitrate per blast which would generate up to 402 lbs (67 lbs/ton * 6 tons) of carbon monoxide and up to 102 lbs (17 lbs/ton * 6 tons) of nitrogen oxides during a blast. Particulate matter derived from each blast is estimated to be over a 20,000 s.f. area (roughly 100 -foot by 200-foot in dimension) resulting in 20.59 lb of PM10 per blast.

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

Table 3.2-7. Operational Emissions (pounds/day)
ROG NOx CO SOx PM10 PM2.5
Summer Scenario
Mobile Source 1.35 0.8 8.37 0.02 1.73 0.45
Area Source 1.25 0.02 2.61 < 0.005 < 0.005 < 0.005
Energy Use < 0.005 0.08 0.03 < 0.005 0.01 0.01
Total 2.61 0.9 11 0.02 1.74 0.46
Screening Level Threshold 75 250 550 250 100 55
Exceed Threshold? No No No No No No
Winter Scenario
Mobile Source 1.31 0.86 8 0.02 1.72 0.45
Area Source 1.13 0.01 1.29 < 0.005 < 0.005 11.9

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ROG NOx CO SOx PM10 PM2.5
Energy Use < 0.005 0.08 0.03 < 0.005 0.01 0.01
Total 2.45 0.96 9.32 0.02 1.73 0.45
Screening Level Threshold 75 250 550 250 100 55
Exceed Threshold? No No No No No No
Source: LDN 2025.

Notes: Daily pollutant generation assumes trip distances within CalEEMod.

Threshold #3: Expose sensitive receptors to substantial pollutant concentrations Sensitive receptors are defined as schools, hospitals, resident care facilities, or day -care centers, as well as residential receptors in the project vicinity. The project vicinity includes single-family residential neighborhoods to the north and east and multi -family residential developments to the south. The threshold related to sensitive receptors addresses whether the project could expose sensitive receptors to substantial pollutant concentrations of criteria pollutants or TACs. The closest sensitive receptors include residential uses to the east and south. In the greater project vicinity there is a preschool located at 403 N. Twin Oaks Valley Road, a retirement home at 650 Woodward Street and the Senior Center at 111 Richmar Avenue.

As identified above, if a project has the potential to result in emissions of any TAC that results in a cancer risk of greater than 10 in 1 million or substantial non-cancer risk, the project would be deemed to have a potentially significant impact.

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

Risks were calculated based on the Office of Environmental Health Hazards Assessment update guidance. Cancer risk is calculated by multiplying the daily inhalation or oral dose, by a cancer potency factor, the age sensitivity factor, the frequency of time spent at home, and the exposure duration divided by averaging time, to yield the excess cancer risk. Based upon the air quality modeling, worst- case onsite PM
10 from onsite construction exhaust would cumulatively produce 0.0074 tons over the construction duration (432 calendar days) or an average of 1.80x10-4 grams/second (LDN 2025).

Utilizing these figures and based on the AERSCREEN dispersion model, the maximum 1 -hr concentration is 0.197 µg/m3 during the worst-case construction period. The annual concentration is

0.016 µg/m3. Therefore, the inhalation cancer risk is 2.8 per million over the construction duration.

This risk would be expressed at the point of maximum exposure 125 meters (410 feet) away. As a condition of project approval, the project would be required to utilize Tier 4 diesel equipment. Since the threshold is 10 per mi llion exposed with T -BACT installed, the project would have a less than significant impact and would be in compliance with the City’s thresholds. It should be noted that sensitive residential receptors are adjacent to the project site, and are located approximately 100 feet to the south and east. Single family residences are located approximately 200 feet to the north. The preschool, retirement home and senior center are located at a greater distance. Since the maximum risk is 2.8 per million exposed (and the threshold is 10 per million), all sensitive receptors would have cancer risks at or less than 6 per million exposed which would also represent a less than significant impact (LDN 2025).

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There are known chronic health risks associated with diesel exhaust which are considered non-cancer risks. Non-Cancer risks or risks defined as chronic or acute are also known with respect to diesel particulate matter and are determined by the hazard index . To calculate hazard index, diesel particulate matter concentration is divided by its chronic Reference Exposure Levels (REL). Where the total equals or exceeds one, a health hazard is presumed to exist. RELs are published by the Office of Environmental H ealth Hazard Assessment. Diesel Exhaust has a REL of 5 μg/m 3 and targets the respiratory system ( LDN 2025). The hourly concentration of 0.197 µg/m3 divided by the REL of 5 µg/m3 yields a Health Hazard Index of 0.4, which is less than one. Therefore, based on thresholds for non-cancer risks, non-cancer health risks are also considered less than significant.

Therefore, toxic air contaminant impacts associated with the project would be less than significant.

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

Operation
Future development on the project site includes multi-family residences. This type of use is not typically characterized as one that would generate odors, compared to uses such as industrial and manufacturing. Moreover, typical odors generated from operation of the proposed project residential land uses would primarily include vehicle exhaust generated by residents and through the periodic use of landscaping and maintenance equipment. Therefore, odor-related impacts from future uses on the project site would be less than significant.

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

As part of the RAQS and SIP planning process, the SDAPCD develops an emission inventory, based on growth projections from SANDAG (which are based on land use designations) and existing emissions figures within the SDAB. The SDAPCD then uses the emission inventory to conduct modeling to demonstrate that the SDAB will attain and maintain the state and federal O 3 standards. This inventory
could be thought of as an “emissions budget” for the SDAB, accounting for current emissions as well as previously approved projects consistent with current General Plan policies.

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Projects that are consistent with the currently adopted General Plan are determined to be consistent with SDAB’s air quality plans, including the RAQS and the SIP. If a project proposes development that is consistent with or less than estimates provided in the General Plan, the project would not conflict with or obstruct implementation of the RAQS or SIP. Provided a project’s emissions are consistent with the projections within the RAQS and SIP, the project would not result in a cumulatively considerable impact on O
3 within the SDAB. As discussed in Section 3.2.4, the project would be developed at a density slightly less than was identified in the applicable planning documents for the project site.

The proposed p roject is , therefore, consistent with the General Plan and would not result in a cumulatively considerable impact. In addition, the project conforms to all local air district significance thresholds. As shown in Tables 3.2-6 and 3.2-7, air quality emissions generated by the project would be much lower (at least five times lower) than the SDAPCD screening thresholds. Also, since the project would not generate significant direct or cumulative construction or operational impacts, the project would be consistent with the County’s RAQS and would comply with the state’s SIP.

Cumulative localized impacts would potentially occur if a construction project were to occur concurrently with another off -site project. There are no other cumulative projects in proximity to the proposed project. Further, it is unknown whether the cumulative projects under review will be approved or not, and, if approved, when actual construction would begin, it would be speculative to estimate any potential overlap of the proposed project. However, future projects would be subject to CEQA and would require an air quality analysis and, where necessary, mitigation if the project would exceed the SDAPCD significance thresholds. Criteria air pollutant emissions associated with construction activity of future projects would be reduced through implementation of control measures required by SDAPCD.

Cumulative PM10 and PM2.5 emissions would be reduced because all future projects would be subject to SDAPCD Rule 55, Fugitive Dust, which sets forth general and specific requirements for all construction sites in the SDAPCD.

As construction and operation of the project would be typical of residential development uses, implementation of the project is not expected to contribute to any cumulative health risks. Cumulative impacts would be
less than significant.

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

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

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3.3 Biological Resources
Introduction
This section provides a biological resources impact analysis for the proposed project. The analysis in this section is based upon the following reports prepared by Rincon Consultants (Rincon) and Alden Environmental:
• Woodward Specific Plan Full Biological Resources Report. Prepared by Rincon, March 2025 (Rincon 2025)
• Focused Rare Plant Survey Report for Woodward Specific Plan Development Project, October 4, 2023 (Rincon 2024)
• Coastal California Gnatcatcher Protocol Survey Report Woodward Specific Plan Development Project, June 18, 2023 (Rincon 2023)
• 2024 Survey Report for Foraging Crotch’s Bumble Bee (Bombus crotchii) on the Woodward Specific Plan Development Project, August 15, 2024 (Alden Environmental 2024) These reports are included as Appendices D.1, D.2,D.3 and D.4 of this Environmental Impact Report (EIR).

During the Initial Study checklist prepared for the proposed project, it was determined that there would be no impact to state or federally protected wetlands, and no impact to wildlife corridors and nursery sites. Section 5.2, Environmental Effects Found Not to be Significant – Biological Resources, of this EIR provides additional information on these topics. The Initial Study is included as Appendix B.1 of this document.

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

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

Significant Impact Less than
Significant
Mitigated to Less
Than Significant
#2: Have a substantial adverse
effect on any riparian habitat or
other sensitive natural community
identified in local or regional plans,
policies, regulations, or by the
California Department of Fish and
Significant Impact Less than
Significant
Mitigated to Less
Than Significant

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Threshold of Significance Project Direct
Impact
Project Cumulative
Impact
Impact After
Mitigation
Wildlife or U.S. Fish and Wildlife
Service?
#3: Conflict with any local policies
or ordinances protecting biological
resources, such as tree
preservation policy or ordinance.

Less than
Significant
Less than
Significant
Mitigated to Less
Than Significant
#4: Conflict with the provisions of
an adopted Habitat Conservation
Plan, Natural Community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan.

Less than
Significant
Less than
Significant
Mitigated to Less
Than Significant

3.3.1 Existing Conditions
The 8.27-acre project site is currently undeveloped, vacant land located east of Woodward Road and north of E. Mission Road. The project is in a developed portion of the City with residential uses to the north, east and south. Elevation ranges from 754 feet above mean sea level (amsl) from the east, 700 feet from the northern boundary of the project, sloping down to 615 feet in the southwestern portion.

Vegetation Mapping and Biological Surveys
To locate and characterize natural vegetation communities, including habitats for special -status species, within the project site, Rincon conducted a biological field survey on December 29, 2022, including a biological reconnaissance survey, vegetation map ping, and general habitat assessment.

Additionally, focused rare plant surveys were conducted in June and September 2023 and focused coastal California gnatcatcher protocol surveys were conducted in May and June 2023.

Literature and Database Review
Prior to the field survey, Rincon conducted background research to preliminarily characterize the nature and extent of biological resources on and adjacent to the project site. Rincon reviewed project site aerial photographs and previous historical land us e of the project site. Queries of the California Department of Fish and Wildlife (CDFW) California Natural Diversity Database (CNDDB) and the California Native Plant Society (CNPS) Online Inventory of Rare and Endangered Plants were conducted to obtain com prehensive information regarding state and federally listed species as well as other special-status species considered to have potential to occur within a 5-mile radius of the project site.

For CNPS query purposes, a nine-quadrangle search area centered on the project site was used; species with elevation ranges exceeding that of the project site were excluded, and plant species with a California Rare Plant Rank (CRPR) of 3 and 4 were excluded as potential impacts to these species are not typically considered significant under CEQA (Rincon 2025).

General Biological Surveys
A field reconnaissance survey of the study area was conducted by Rincon Biologist Jacob Hargis on December 29, 2022, from 8:45 a.m. to 12:00 p.m. to document the existing site conditions and

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evaluate the potential for presence of sensitive biological resources, including special-status plant and wildlife species, sensitive plant communities, potential jurisdictional waters, wildlife corridors and nursery sites, and locally protected resources. The biological survey study area included the proposed project, encompassing 8.57 acres, plus an additional 200-foot buffer surrounding the project. Weather conditions during the survey included temperatures of 54 to 56 degrees Fahrenheit, winds (0 to 2 miles per hour) with cloudy skies. The survey consisted of walking meandering transects throughout the study area, where accessible. The biologist visually scanned for special -status species (or sign thereof) and habitats suitable for these species. Binoculars were used to scan those areas otherwise inaccessible by foot, including the buffer area and to scan shrubs for the presence of nests.

The habitat requirements for each regionally occurring special -status species were assessed and compared to the type and quality of the habitats observed within the study area during the site visit.

Observed Plants
The project site contains dense Diegan Coastal Sage Scrub dominated by California sagebrush, California buckwheat together with laurel sumac, black sage, and coyote brush. Non -native, annual species such as Brassica sp. Salsola, and other herbaceous forbs and weedy species were present within the understory and intermittent open areas along the slope of the site. Clusters of coastal prickly pear (Opuntia littoralis) along the rocky outcroppings were observed in the southern portion sloped area of the site. A full list of floral species observed during the field reconnaissance survey conducted on December 29, 2022, can be found in Appendix C of Appendix D.1 of the EIR.

Focused Rare Plant Survey
Rincon botanist, Casey Clark, conducted a focused rare plant survey on June 16, 2023 , and September 20, 2023. The survey results are included as Appendix D.2 of the EIR.

To optimize detection, the field survey was conducted during the appropriate phenological period to detect and identify the San Diego sand aster (i.e., May through September). The survey was conducted using systematic field techniques by walking parallel transects through the entire survey area. Special attention was given to areas with a high potential to support rare plant species (e.g., north -facing slopes, vegetation community interfaces, areas with unique soils, and other attributes required of species that have been previously documented). San Diego sand aster was not observed during the surveys and the surveys were conducted during an adequate rain year when the conditions were conducive for germination. No other special status plant species were detected, and none are expected based on the results of the focused rare plan survey.

Observed Wildlife
The majority of the wildlife species observed during the field reconnaissance survey were birds.

Common bird species were observed within the study area and included California scrub -jay (Aphelocoma californica), California towhee (Melozone crissalis), Anna’s hummingbird (Calypte anna), white-crowned sparrow ( Zonotrichia leucophrys), American crow ( Corvus brachyrhynchos). Signs of mammal species observed included woodrat middens (Neotoma sp.) and coyote (Canis latrans) scat.

Woodrat middens (nests) are large nests or dens made of woody debris, such as sticks, dead cacti, and bark. Please refer to Appendix D of Appendix D.1 of the EIR for a full list of faunal species observed.

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Coastal California Gnatcatcher Protocol Survey
Rincon conducted protocol breeding season coastal California gnatcatcher ( Polioptila californica Polyopia; CAGN) for the proposed project to further evaluate presence/absence of the species. Surveys were conducted by Rincon biologist Kelly Rios who currently holds an Endangered and Threatened Species Permit issued by the United States Fish and Wildlife Service (USFWS), Permit TE 018909-6, under Section 10(a)(1)(A) of the Federal Endangered Species Act. The 15 -day notification letter of intent to conduct protocol breeding season surveys for CAGN was sent to the USFWS Carlsbad office on April 18, 2023.

All CAGN surveys were conducted in accordance with the survey protocol for CAGN surveys within Multi- Habitat Planning Area ( MHPA) areas, titled Section III of the USFWS Coastal California Gnatcatcher Presence/Absence Survey Protocol, issued February 28, 1997, and revised July 28, 1997. The protocol requires that between February 15 and August 30, a minimum of six surveys shall be conducted at least one week apart to determine presence/absence of CAGN.

A total of six surveys were conducted between May 3 and June 14, 2023. The six surveys occurred between 6:00 AM to 12:00 PM each day. Suitable Diegan Coastal Sage Scrub occurs within the project site boundaries, north and east of the project site, and west of the project site across Woodward Street.

The study area consists of predominately Diegan Coastal Sage Scrub and D isturbed Diegan Coastal Sage Scrub. Larger, more dense shrub cover within the community dominated by laurel sumacs (Malosma laurina ) and Ca lifornia sage brush occurs in the northern portion of the survey area.

Additional open space Multiple Habitat Conservation Program (MHCP) Reserve Habitat is adjacent to the project on the north and east sides (
Figure 3.3-1).

During the 2023 CAGN protocol surveys, no individuals, pairs, or nests were observed within the study area or adjacent areas. CAGN had been previously identified in the Diegan Coastal Sage Scrub within the project site, including within the overall study area to the east and west, during USFWS protocol surveys that were conducted in 2018 and preconstruction surveys conducted in 2020 for the adjacent Mission 316 development project located south of the project site (KMEA 2020). The survey area for the Mission 316 protocol CAGN surveys totaled 28 acres, which included a 500-foot buffer around the

3.7-acre project to the south. These surveys recorded individuals foraging, nesting pairs, and two family groups within the project site. Individuals were also recorded within sage scrub habitat and designated MHCP Hardline Reserve to the west of the project site across Woodward Street. Foraging individuals were also observed and recorded to the adjacent area east of the project site, south of Silk Mill Place Road.

Foraging Crotch’s Bumble Bee Survey
Alden Environmental conducted a foraging bumble bee survey for Crotch’s bumble bee (CBB; Bombus crotchii) during the period of May 16 through July 12, 2024. Prior to beginning the survey, a habitat assessment was conducted to identify suitable foraging habitat for the CBB. The assessment included reviewing CDFW Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (2023), as well as reviewing available bumble bee data (iNaturalist and Bumble Bee Watch) and CNDDB to identify any reported CBB observations in the site vicinity. In addition, current vegetation mapping prepared for the project, historic aerial photographs, and site photographs were reviewed to identify areas that may support suitable foraging resources (flowerin g plants) for the species as well as nesting locations. Potential habitat for the CBB on site was determined from those existing conditions.

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According to the Survey Considerations (CDFW 2023), it is recommended that at least three site visits take place spaced 2 to 4 weeks apart during the period of highest detection probability for foraging CBB (i.e., the April – August Colony Active Period for the species) and when floral resources are present.

Three site visits were made to the survey area approximately 3-5 weeks apart during the Colony Active Period when floral resources were present, May 16, 2024, June 6, 2024, and July 12, 2024.

One CBB was observed during the June 6, 2024 survey within the south central portion of the project site.

Additional Bombus species were also observed during each of the three surveys. Twelve Yellow-faced bumble bees (Bombus vosnesenskii), including one queen, were observed on May 16, 2024; twenty five, including one male, were observed on June 6, 2024; and sixteen were observed on July 7, 2024.

Sixteen California bumble bee (Bombus californicus) were also observed on July 12, 2024. Other bee and wasp species observed throughout the survey included the European honey bee (Apis mellifera), Hover fly ( Syrphidae), tarantula hawk ( Pepsis thisbe ), Robber fly ( Asilidae), California digger bee (Anthophora californica), Mexican cactus fly ( Copestylum mexicanum), carpenter bee ( Xylocopinae), and Figeater beetle (Cotinis mutabilis).

Vegetation Communities
Vegetation classification was based on the classification systems provided in the Draft Vegetation Communities of San Diego County (Oberbauer et al. 2008) to provide consistency with the San Diego Association of Governments (SANDAG) MHCP and modified as ap propriate to reflect the existing site conditions. Where applicable, vegetation communities were further classified using A Manual of California Vegetation, Second Edition (Sawyer et al. 2009) to better identify the species composition and provide consistency with CDFW classifications. Sensitive vegetation community ranking is based on MHCP habitat groups (SANDAG 2003). The MHCP designates six habitat group categories:
• Group A - Wetland Communities
• Group B - Rare Upland
• Group C - Coastal Sage Scrub
• Group D - Chaparral
• Group E - Annual Grassland
• Group F - Other
The following provides a description of the vegetation communities observed on the project site and study area. These communities are mapped in
Figure 3.3-2.

Diegan Coastal Sage Scrub
This vegetation community is the most prevalent community within the study area (15.48 acres) and the project site (7.73 acres). The majority of the project site, as well as the study area to the north, supports high-quality Diegan Coastal Sage Scrub. This habitat community is also present within the study area to the south, east, and across Woodward Street to the west. Historical disturbance within the central and southern portions of the site identified 0.51 acres of a more Disturbed Diegan Coastal Sage Scrub community ( discussed in more detail below), with evidence of revegetation in the last several years.

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The community is dominated by low, soft -woody subshrubs that are most active in winter and early spring. Many taxa are facultatively drought -deciduous. Diegan Coastal Sage Scrub is typically on low moisture-availability sites such as steep, xeric (dry or with little moisture) slopes or clay-rich soils that are slow to release stored water.

The shrub layer is dense and dominated by laurel sumac ( Malosma laurina), California sagebrush (Artemisia californica) and lemonade berry (Rhus integrifolia), with California buckwheat (Eriogonum fasciculatum), deerweed (Acmispon glaber), white sage (Salvia apiana), black sage (S. mellifera) and coyote brush ( Baccharis pilularis ) (Oberbauer et al. 2008). Several non-native species including tocalote (Centaurea melitensis), mustards (Brassica sp.), slender wild oat (Avena barbata) and ripgut brome (Bromus diandrus) are also common throughout this community. Diegan Coastal Sage Scrub is considered a sensitive community by the City, falling under Habitat Group C.

Disturbed Diegan Coastal Sage Scrub
This vegetation community comprises 1.10 acres within the study area, and approximately 0.51 acres of the project site and is structurally similar to Diegan Coastal Sage Scrub but has been subjected to historical anthropogenic disturbance from land use practices. An old access trail leading up from the southern area of the project site shows evidence of human disturbances, but vegetative regrowth of coastal sage scrub species was observed in those areas leading up to and including the central portion of the project site. This area appears to be previously disturbed, forming an open area, with sage scrub revegetating. This habitat is also found within the fuel management area for the Mission Villas 316 Project, along the southern portion of the project site. As a result, much of the Disturbed Diegan Coastal Sage Scrub appears to be revegetating and contains a higher pro portion of bare ground and weedy species than the Diegan Coastal Sage Scrub species. Dominant shrub species include California buckwheat, Calif ornia sagebrush, black sage, coyote brush, with golden yarrow ( Eriophyllum confertiflorum), coastal prickly pear (Opuntia littoralis) and sparse herbaceous species, including giant woollystar (Eriastrum densifolium) and small seed sandmat (Euphorbia polycarpa) and large patches of open/bare ground. Disturbed Diegan Coastal Sage Scrub is considered a sensitive community by the City (despite being disturbed), falling under Habitat Group C.

Urban/Developed
Urban/Developed refers to areas that have been constructed upon or otherwise physically altered to an extent that native vegetation is no longer supported. Developed land is characterized by permanent or semi -permanent structures, pavement or hardscape, and landscaped areas that o ften require irrigation. Approximately 9.02 acres of land cover within the study area and 0.14 acres within the project site have been developed or altered, including public roadways, development, and the installation of a large retaining wall and concrete “v-ditch” from the development south of the project site.

Eucalyptus Woodland
Eucalyptus woodland habitats range from a single-species thicket with little to no shrubby understory to scattered trees over a well -developed herbaceous and shrubby understory. Typically, eucalyptus woodlands form a dense canopy with the overstory composi tion limited to one species of the genus, or mixed stands composed of several Eucalyptus species; few native overstory species are present within eucalyptus planted areas, except in small, cleared pockets (Oberbauer 2008). A dense stand of eucalyptus woodlands was identified adjacent to Woodward Street to the west comprising 0.24 acre, following the road from south to north, also adjacent to the riparian woodland habitat identified within

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the study area. Eucalyptus trees intermix with Diegan Coastal Sage Scrub understory along the western portion of the study area across Woodward Street.

Disturbed Habitat
Disturbed habitats are areas that have been physically disturbed by previous legal human activity and are no longer recognizable as a native or naturalized vegetation association but continue to retain a soil substrate. Typically, vegetation, if present, i s nearly exclusively composed of non -native plant species such as ornamentals or disturbance-adapted ruderal exotic species or shows signs of past or present animal usage such as grazing, that removes any capability of providing viable natural habitat for use to wildlife other than dispersal. Examples of disturbed land include areas that have been graded, repeatedly cleared for fuel management purposes, and/or have experienced repeated use that prevents natural revegetation (i.e., dirt parking lots, trails that have been present for several decades), recently graded firebreaks, graded construction pads, construction staging areas, off -road vehicle trails, and old homesites. Characteristic species found in disturbed habitats are invasive, non- native forb species and a limited number of grass species, including Brassica sp. and fountain grass (Pennisetum spp.) (Oberbauer et al. 2008). Disturbed habitat, comprising of 0.98 acre was observed within the study area along the southeastern slope and a small area to the west of Woodward Street.

A large open pad, surrounded by revegetating disturbed coastal sage scrub comprises a n additional

0.05 acres of disturbed habitat.

The disturbance along the southeast slope has impacted the naturally occurring vegetation community, establishing primarily non -native plant species adapted to disturbances including, shortpod mustard (Hirschfeldia incana), tocalote (Centaurea melitensis), fountain grass (Pennisetum setaceum) and tree tobacco ( Nicotiana glauca). Some native species are dispersed throughout the disturbed habitat, including coyote brush, California sagebrush, and Menzies’ golden bush ( Isocoma menziesii ssp. menziesii).

Southern Riparian Forest
Southern riparian forest habitat is typically found along streams and rivers with dominant characteristic species that include California sycamore ( Platanus racemosa) and cottonwoods (Populus sp.) amongst other wetland plants. Approximately 0.48 acres of this habitat type is within the study area and was observed located just west of Woodward Steet (Figure 3.3-2). This habitat type is associated with the San Marcos Creek freshwater forested/shrub wetland that runs between W .

Borden Road and E. Mission Road; however, the creek lies outside of the study area (Rincon 2025). A concrete culvert outlet likely conveys flows underneath E . Mission Road and further south. Dense canopies of riparian deciduous trees comprised of California sycamore, cottonwoods, and willow (Salix sp.) with eucalyptus trees and an understory of upland scrub species were present. This area was visually observed from the project site and not closely inspected as access to adjacent private property is not under the control of the Applicant. Southern Riparian Forest is considered a sensitive community by the City, falling under Habitat Group A.

Rare Plant Survey/Special-Status Plants
The database queries identified 61 special -status plants within the San Marcos, California, United States Geological Survey ( USGS) topographic quadrangle and eight surrounding quadrangles (Appendix D of EIR Appendix D.1). One species that is associated with disturbed habitat ha s a moderate potential to occur on site: San Diego sand aster ( Corethrogyne filaginifolia var. incana ).

Focused surveys for San Diego sand aster were conducted during the appropriate blooming period (May through September) by Rincon i n 2023. No individuals or populations of San Diego sand aster

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were observed during the two focused surveys. No special-status plant species were observed on the project site during the field reconnaissance survey in 2022 or during the focused rare plant surveys in 2023.

Special-Status Wildlife Species
The review of biological databases resulted in the identification of 60 special -status wildlife species occurring within five miles of the study area. Of these, six species were determined to have at least a moderate potential to occur due to the presence of suitable habitat in the study area.

Three special-status wildlife species have been observed within the project site , CAGN , CBB, and Cooper’s hawk ( Accipiter cooperii). Three additional species have a high potential to occur on site:
orange-throated whiptail (Aspidoscelis hyperythra), coastal whiptail (Aspidoscelis tigris stejnegeri), and Bryant’s woodrat ( Neotoma bryanti intermedia). One species, rufous -crowned sparrow , has a moderate potential to occur based on suitable Diegan Coastal Sage Scrub foraging and nesting habitat present within the project site, 500-foot buffer, and potential habitat connectivity to surrounding areas.

An additional ten wildlife species have a low potential to occur due to the presence of marginal habitat or that the species may use the project site temporarily during foraging or overnight roosting as described in Appendix D of EIR Appendix D.1 . Due to the low probability of occurrence, they are not discussed further.

Coastal California Gnatcatcher
Coastal California gnatcatcher, a Federally Threatened, Species of Special Concern (SSC), and MHCP- covered species, is an obligate, permanent resident of Coastal Sage Scrub below 2,500 feet in Southern California. This species occurs in low Coastal Sage Scrub in arid washes and on mesas and slopes.

CAGN has been observed in the project site. Protocol surveys for the Mission Villas project to the south of the project site were conducted by KMEA in 2018 and preconstruction surveys were conducted by KMEA in 2020 (KMEA 2018, 2020). Results from the surveys are shown in the Biological Resources Map (
Figure 3.3 -3). As discussed previously, updated USFWS protocol surveys were conducted between May 3 and June 14, 2023, and no observations of CAGN were observed during the six surveys.

Crotch’s Bumble Bee
CBB is now considered a state candidate for listing as endangered. CBB occurs primarily in California, adjacent foothills in southwestern California, and in southwest Nevada near the border (Xerces Society 2023). This species inhabits scrub and open grassland habitats with floral associations for foraging.

Nests can be located underground in abandoned rodent nests, above ground in tufts of grass, old bird nests, rock piles, or cavities in dead trees (Xerces Society 2023). One CBB was detected in the Diegan Coastal Sage Scrub habitat within the central portion of the project site during the 2024 protocol survey.

Cooper’s Hawk
Cooper’s hawk, a Watch List and MHCP-covered species, is typically found in woodland, and forested habitats and is found throughout urban landscapes where cover and prey are available. They typically nest in riparian growths of deciduous trees, oaks, canyon bottoms, and pines. This species has a high potential to occur as a transient. The site contains small mammal and songbird prey availability with

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dense eucalyptus and riparian woodland within the study area to the west that could provide suitable nesting habitat. The project site itself lacks tall trees, dense woodland, or riparian habitats that provide suitable nesting habitat for this species. A Cooper’s hawk was observed flying over the project site during a previous pre-construction survey in 2020 for the Mission 316 Villas project, which is located immediately south of the project site.

Orange-Throated Whiptail
Orange-throated whiptail, a Watch List and MHCP-covered reptile species, requires intact Coastal Sage Scrub, with California buckwheat as the dominant species, and sage ( Salvia sp.), yucca (Yucca sp.), cactus (Opuntia sp.), and sagebrush (Artemisia sp.) present. This species has a high potential to occur on site and within the study area due to the high suitability of Diegan Coastal Sage Scrub and Disturbed Coastal Sage Scrub, in which California buckwheat and California sagebrush are prevalent.

Coastal Whiptail
Coastal whiptail, an SSC, is found in deserts and semi -arid areas with sparse vegetation and open areas, and woodland and riparian areas. This species can occur in firm, sandy, or rocky soils. Coastal whiptail has a high potential to occur in the more open scrub areas.

Bryant’s Woodrat
Bryant’s woodrat, an SSC species, occurs in coastal scrub of Southern California from San Diego County to San Luis Obispo County. This species prefers moderate to dense canopies. Bryant’s woodrat is particularly abundant in rock outcrops, rocky cliffs, and slopes and typically associates with cacti patches and dense undergrowth. This species typically overlaps with another Neotoma sp., the big eared wood rat (Neotoma lepida). Numerous woodrat stick nests “middens” were observed throughout the project site, although presence of the sensitive Neotoma subspecies was not confirmed. Further determination is needed to evaluate the two species by nest size, material, location; and proximity to cacti, rock outcroppings, water sources, and surrounding habitat. The Bryant’s woodrat has a moderate potential to occur in the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Scrub habitats within the project site and study area.

Southern California Rufous-Crowned Sparrow
Southern California rufous-crowned sparrow, a Watch List and MHCP-covered species, is found in open oak woodlands and dry uplands with grassy vegetation and bushes. This species is often found near rocky outcroppings, and occurs in coastal scrublands and chaparral areas. The Southern California rufous-crowned sparrow has a moderate potential to occur in the Diegan Coastal Sage Scrub and Disturbed Diegan Coastal Sage Scrub habitats within the project site and study area.

Nesting Birds and Raptors
The habitats within the project site and study area, which include Diegan Coastal Sage Scrub, provide suitable nesting habitat for a variety of nesting bird species such as passerines and non -passerine terrestrial birds that may nest on the ground or within the scrub vegetation, including coastal California gnatcatcher and southern rufous crowned sparrow. The project site does not contain suitable habitat for raptor species due to the lack of large trees for nesting, however the large stand of eucalyptus trees and riparian woodland habitat within the study area across Woodward Street could provide nesting habitat for raptor species such as red -tailed hawks ( Buteo jamaicensis) or Cooper’s hawk (Accipiter cooperii). Ornamental palm trees associated with the residential houses on the upper

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eastern slope off of Silk Mill Place occur within the study area. These trees could potentially provide low quality suitable nesting habitat for raptors. Nesting birds are protected pursuant to the California Fish and Game Code (CFCG) and Migratory Bird Treaty Act (MBTA).

Critical Habitat
Federally designated Critical Habitat does not occur within the study area or project boundaries.

MHCP Conservation Areas
MHCP Hardline Reserve open space habitat is shown in Figure 3.3-1. As shown in Figure 3.3-1, MHCP Hardline Reserve lands are located to the north, northeastern corner, southeast and west of the project site. The portions of the MHCP Hardline Reserve lands located in the northeastern and southeastern corners of the project site are likely misaligned and boundaries do not overlap within the project site but do still occur within the larger biological resources study area

3.3.2 Regulatory Setting
Federal
United States Army Corps of Engineers – Clean Water Act Recognizing the potential for continued or accelerated degradation of the Nation's waters, the U.S.

Congress enacted the Clean Water Act (CWA), formerly known as the Federal Water Pollution Control Act (33 U.S.C. 1344). The objective of the CWA is to maintain and restore the chemical, physical, and biological integrity of the waters of the United States. Section 404 of the CWA authorizes the Secretary of the Army, acting through the Chief of Engineers, to issue permits for the discharge of dredged or fill material into the waters of the United States, including wetlands.

United States Fish and Wildlife Service – Endangered Species Act The USFWS is responsible for enforcing the federal Endangered Species Act (ESA), Migratory Bird Treaty Act, and Wildlife Coordination Act, and reviews and comments on applications for Section 404 CWA permits submitted to the USACE. If the proposed project is determined to have an adverse effect on a species that is federally listed as threatened or endangered, consultation with the USFWS would be required. If the proposed project may result in “take” of a federally listed species, an incidental take permit would be required. “Take” is defined in the ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.” The project site does not contain any areas mapped as “critical habitat,” as mapped by USFWS.

United States Fish and Wildlife Service – Migratory Bird Treaty Act The Migratory Bird Treaty Act (MBTA) (16 USC 703 et seq.) is a federal statute that implements treaties with several countries on the conservation and protection of migratory birds. The number of bird species covered by the MBTA is extensive and is listed in 50 CFR 10.13. The regulatory definition of “migratory bird” is broad and includes any mutation or hybrid of a listed species and includes any part, egg, or nest of such bird (50 CFR 10.12). Migratory birds are not necessarily federally listed endangered or threatened birds under the ESA. The MBTA, which is enforced by USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migratory bird or attempt such actions, except as permitted by regulation. The applic able regulations prohibit the

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take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, except under a valid permit or as permitted in the implementing regulations (50 CFR 21.11).

State
California Department of Fish and Wildlife
The CDFW has the authority to reach an agreement with an agency or private party proposing to affect intermittent or permanent wetlands habitat, pursuant to Sections 1601 -1616 of the State Fish and Game Code. Section 1602 of the State Fish and Game Code requires notification to CDFW prior to diversion of, obstruction of, use of material from, or deposition of materials in any river, stream, or lake. In accordance with its policy of “no net loss of wetland habitats,” the Department requires mitigation for all impacts to any wetlands, regardless of acreage.

California Endangered Species Act
The California Endangered Species Act (CESA) (California Fish and Game Code §2050, et seq.) generally parallels the main provisions of the Federal ESA and is administered by the CDFW. Its intent is to prohibit “take” and protect state listed endangered and threatened species of fish, wildlife, and plants. Unlike its federal counterpart, the CESA also applies the take prohibitions to species petitioned for listing (state candidates).

Natural Community Conservation Planning
CDFW's Natural Community Conservation Planning ( NCCP) program is an effort by the State of California, and numerous private and public partners, that takes a broad-based ecosystem approach to planning for the protection and perpetuation of biological diversity. An NCCP program identifies and provides for the regional or areawide protection of plants, animals, and their habitats, while allowing compatible and appropriate economic activity.

Multiple Habitat Conservation Program (MHCP) - The MHCP is a comprehensive conservation planning process that addresses the needs of multiple plant and animal species in Northwestern San Diego County. The MHCP encompasses the cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach , and Vista. Its goal is to conserve approximately 19,000 acres of habitat, of which roughly 8,800 acres (46 percent) are already in public ownership and contribute toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.

The City of San Marcos began preparing a draft of the City Subarea Plan of the MHCP in December 1999 and although the City’s Draft Subarea Plan has not yet been approved by the USFWS and CDFW, the plan is a component of the adopted MHCP, and is currently being used as a guide for open space design and preservation within the City. The intent of the City’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as focused planning areas (FPAs), have been designated with parcel -level preserve goals which would contribute to achieving local and regional conser vation goals while minimizing adverse effects on property rights and property values.

The project site is located within the MHCP. However, t he project site is not located within an FPA as defined in the MHCP and the City’s Draft Subarea Plan.

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Local
San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of biological resources. The following goals and policies apply to the project:
• Goal COS -1: Identify, protect, and enhance significant ecological and biological resources within San Marcos and its adaptive Sphere of Influence. o Policy COS-1.1: Support the protection of biological resources through the establishment, restoration, and conservation of high quality habitat areas. o Policy COS-1.2: Ensure that new development, including Capital Improvement Projects, maintain the biotic habitat value of riparian areas, oak woodlands, habitat linkages, and other sensitive biological habitats.
• Goal COS-2: The City is committed to conserving, protecting, and maintaining open space, agricultural, and limited resources for future generations. By working with property owners, local organizations, and state and federal agencies, the City can limit th e conversion of resource lands to urban uses.
o Policy COS -2.1: Provide and protect open space areas throughout the City for its recreational, agricultural, safety, and environmental value. o Policy COS-2.2: Limit, to the extent feasible, the conversion of open space to urban uses and place a high priority on acquiring and preserving open space lands for recreation, habitat protection and enhancement, flood hazard management, water and agricult ural resources protection, and overall community benefit.
o Policy COS-2.6: Preserve healthy mature trees where feasible; where removal is necessary, trees shall be replaced at a ratio of 1:1.

San Marcos City CouncilSeptember 9, 2025

San Marcos City Council
September 9, 2025