> D.4 Biological Resources Letter Report — San Marcos City Council, May 26, 2026

ATTACHMENT D.4

BIOLOGICAL RESOURCES LETTER REPORT

Project Name and Number: Santa Fe Flores Townhomes (modified project; GPA25-0001; R25-0001; MFSDP25-0001; TSM25-0001)
Report: Biological Resources Letter Report
Date: March 24, 2026
Project Proponent: Santa Fe Flores LP
P.O. Box 903
Rancho Santa Fe, CA 92067
Prepared for: City of San Marcos
City-approved CEQA Consultant: Jade Woll
RECON Environmental, Inc.
3111 Camino del Rio North, Suite 600
San Diego, CA 92108
Signature of City-approved CEQA Consultant:

1.0 INTRODUCTION, PROJECT DESCRIPTION, AND LOCATION
On February 28, 2023, the City of San Marcos City Council adopted a Mitigated Negative Declaration ( MND; ND22- 008; SCH No. 2022090486), approved a General Plan Amendment (GPA) (GPA21-0008), and approved a Multi-Family Site Development Plan (MFSDP21-0002) for the Santa Fe Flores, LP Project (approved project). The requested Rezone (R21-0004) required a second reading prior to approval on March 14, 2023. A biological resources survey report was prepared in 2022 for the approved project which evaluated the impacts associated with a GPA to change the land use from Commercial (C) and Light Industrial (L-I) to Medium Density Residential 2 (MDR2) and a zone change from Commercial (C) and Light Industrial (L-I) to Multi-Family Residential (R-3-10) to allow for the construction of 50 dwelling units, in conjunction with a Density Bonus, on a 2.53-acre site (2.23 net acres) consisting of two parcels, assessor parcel numbers (APNs) 217-161-18 and 217-161-19.

Subsequent to MND approval, the applicant modified the site plan (modified project) and added 0.37 acres of APN 217-161-17. The modified project would develop 46 multi-family residential townhome units in seven buildings that would be three stories and 35 feet 4 inches in height. Vehicle parking would include 92 spaces within attached garages and 15 guest spaces.

The modified project site totals 2.6 net acres [2.23 acres plus 0.37 acres (added with modified project; see above)].

The modified project also proposes approximately 0.12 acres of off-site improvements, including the construction of a new shared driveway extending into the southern portion of APN 217-161-17, upgrades to the existing liquor store parking lot, and landscaping within the eight-foot-wide irrevocable offer of dedication area along the project frontage. The liquor store would not be part of the modified project and would remain. Project grading would include 23,300 cubic yards of cut and 3,200 cubic yards of fill, resulting in the export of 20,100 cubic yards of soil.

An addendum (Addendum No. 1) has been prepared to assess impacts associated with the modified project. This report describes the results of the biological resources survey conducted for the a pproved project in 2022, as well as the updated biological resources survey conducted for the modified project in 2024.

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 2 ends

The modified project is located in San Marcos, California (Figure 1), in the Los Vallecitos de San Marcos Land Grant, of the U.S. Geological Survey (USGS) 7.5-minute topographic map, San Marcos (Figure 2; USGS 1996). It is located west of North Las Flores Drive, north of South Santa Fe Avenue and north of State Route 78. The project occurs within APNs 217-161-18, 217-161-19, and a portion of 217-161-17 (Figure 3). The modified project is located within a developed area and is bounded by an existing multi-family residential development located east of North Las Flores Drive, by South Santa Fe Avenue to the south, existing industrial to the north and west, and an existing liquor store and parking lot to the southwest. The Sprinter railroad tracks and single-family residential homes off North Las Flores Drive are north and northeast of the modified project, and the Vista Meadows mobile home community is south of South Santa Fe Avenue across from the modified project (Figure 3).

2.0 ENVIRONMENTAL SETTING
The modified project is located within a developed area surrounded by light-industrial, residential, and commercial properties on all sides of the project. The City of San Marcos (City) adheres to the draft Subarea Plan under the Multiple Habitat Conservation Program (MHCP), though it has not been formally approved (City of San Marcos 2001).

The MHCP is a habitat conservation plan for the seven jurisdictional areas within the northern subregion of San Diego County, including San Marcos (San Diego Association of Governments [SANDAG] 2003). This draft City of San Marcos Subarea Plan identifies a series of focused planning areas (FPA) within which some lands will be dedicated for preservation of native habitats. These areas contain both “hardline” preserve areas, which will ultimately be preserved as open space, and “softline” planning areas, which will include some areas that ultimately will become preserves and other areas that will ultimately be developed, as determined through the planning process. The modified project is located outside of any hardline preserve areas or softline planning areas identified by the draft City of San Marcos Subarea Plan. The nearest hardline reserve is approximately 2,000 feet east and northeast of the modified project.

Areas just outside the City of San Marcos within unincorporated San Diego County are within the planning boundaries of the San Diego Multiple Species Conservation Program draft North County Plan. The modified project is outside of and situated approximately 1,500 feet south of these areas, which are identified in the draft North County Plan as “Outside Open Space Network” indicating they are not intended for conservation lands (Figure 4).

3.0 SURVEY METHODS
RECON Environmental, Inc. (RECON) biologist Jade Woll conducted an initial biological survey of the approved project on March 3, 2022 (Figure 5). The modified project was surveyed by RECON biologist Danelle Gadia on October 31, 2024 (Figure 5) within an approximately 2.7-acre survey area, including on-site and off-site areas to be potentially impacted. The 2024 survey determined the current condition of the biological resources present within the modified project. Prior to conducting field surveys in both 2022 and 2024, a review of publicly available data was conducted to determine the potential for special-status species to occur within the project site. The review included data provided by U.S. Fish and Wildlife Service (USFWS) (USFWS 2024), California Natural Diversity Data base (CNDDB; CDFW 2024a), and California Native Plant Society (CNPS 2024).

During the field survey, habitats were assessed for their potential to support special- status species, and all incidentally observed species were recorded. No focused special-status species surveys were conducted. All plant and wildlife species observed during the general survey are presented in Attachments 2 and 3, respectively. Plant or wildlife species are considered special status if they are: (1) covered or listed as a narrow endemic under the MHCP (SANDAG 2003); (2) listed by state or federal agencies as threatened or endangered or are proposed for listing; (3) included on CNPS California Rare Plant Ranks 1, 2, 3, or 4 (CNPS 2024); or (4) considered rare, endangered, or threatened by local conservation organizations or specialists (Reiser 2001).

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 3 ends

4.0 VEGETATION COMMUNITIES/LAND COVER TYPES
Two vegetation communities/land cover types were identified within the survey area: disturbed land and urban/developed. The acreages of each vegetation community/land cover type within the survey area are presented in Table 1 and depicted in Figure 6. Under the MHCP, environmentally sensitive lands are categorized into different habitat groups of sensitivity. Group A consists of wetland/riparian habitats, which are considered the most sensitive of habitats. Upland vegetation communities that are classified as Group B (rare uplands), Group C (coastal sage scrub), Group D (chaparral), and Group E (annual [non-native] grasslands) are considered sensitive by the MHCP. Group F (other lands), which includes disturbed lands, is not considered sensitive (SANDAG 2003).

Table 1
Land Cover Types within the Modified Project Survey Area Land Cover Types
(Holland Code as modified by Oberbauer)
MHCP
Group Total (acres)1,3
Disturbed Land (11300) F 2.3
Urban/Developed (12000) --2 0.4
TOTAL1,3 2.7
MHCP = Multiple Habitat Conservation Program
1Includes off-site improvement area. Rounded to the nearest tenth of an acre. Any discrepancies in totals are due to rounding.
2No MHCP assigned group.
3Total acres includes approved project acreage (2.3 acres) plus modified project acreage (0.4 acres).

Disturbed Land. Disturbed land consists of areas that may have been disturbed by human activity and no longer function as a native vegetation community. Vegetation in such areas is typically dominated by opportunistic non - native species but may also contain a substantial portion of bare ground. Disturbed land can also include areas that have been previously graded, repeatedly cleared for fuel management, and/or experience repeated use (e.g. , off- road-vehicle trails and construction staging sites) (Oberbauer et al. 2008).

Disturbed land occurs within the majority of the survey area and includes areas that have been disturbed through frequent off-roading activity (Attachment 1, Photographs 1 and 2). This land cover type includes non-native forbs and ornamental species with dominant species including telegraph weed (Heterotheca grandiflora), Russian thistle (Salsola tragus), bristly ox-tongue (Helminthotheca echioides), vanilla-scented wattle (Acacia redolens), and Peruvian pepper tree (Schinus molle). Several scattered native shrubs were identified throughout the disturbed land but these individual species were too few to form a distinct native habitat (see Figure 6 ). Disturbed land is classified as Group F by the MHCP. Impacts to Group F habitat types would not be considered significant and would not require mitigation.

Urban/Developed Land. Urban/developed land consists of any land that has been constructed upon, containing permanent or semi-permanent structures, pavement or hardscape, or landscaped areas that are regularly maintained and/or irrigated (Oberbauer et al. 2008). Urban/developed land includes a paved parking lot in the southwestern corner of the survey area and ornamental landscaping along the eastern edge of the survey area (see Figure 6 and Photograph 1). As noted in Section 1.0 above, the existing liquor store would not be part of the modified project and would remain.

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 4 ends

5.0 WILDLIFE SPECIES
Wildlife species observed during the time of the survey include those typically found within disturbed and urban/developed land such as American crow (Corvus brachyrhynchos), house finch (Haemorhous mexicanus), California ground squirrel (Otopermophilus beecheyi), and black phoebe (Sayornis nigricans).

6.0 AQUATIC RESOURCES
A formal wetland delineation was not conducted; however, no potential jurisdictional wetlands or waters were observed within the modified project. Additionally, no vernal pools or depressions containing wetland or vernal pool plant species characteristic of vernal habitat were observed during the survey.

7.0 SPECIAL-STATUS SPECIES

7.1 Special Status Plant Species
One special status plant species, decumbent goldenbush (Isocoma menziesii var. decumbens), was observed within the approved project during the 2022 biological survey (see Figure 6; RECON 2022). A total of 30 individuals were observed (Figure 6). No other sensitive plants were observed within the modified project area or are anticipated to occur due to high levels of disturbance within the BSA (e.g., off-roading activity, prevalence of nonnative species).

Additionally, thread-leaved brodiaea (Brodiaea filifolia) was not observed during the 2022 biological survey, which was conducted during the species blooming period (March–June) when vegetative stems/stalks or blooming individuals would have been visible. Furthermore, the modified project lacks suitable vernal pool and grassland habitat to support this species and consists of predominantly non-native species and heavily disturbed areas from frequent off-roading activity. A comprehensive list of sensitive plant species with a potential to occur within the BSA based on the records search is presented in Attachment 4 and includes species with potential to occur based on species range and habitat conditions (CDFW 2024b and 2024c).

7.2 Special Status Wildlife Species
No special status wildlife species were observed within the survey area; however, one special status wildlife species, Cooper’s hawk (Accipiter cooperii), has a moderate potential to occur on-site. A comprehensive list of sensitive wildlife species with potential to occur in the survey area based on the record search is presented in Attachment 5 and includes species with potential to occur based on species range and habitat conditions (CDFW 2024a and 2024d; USFWS 2024).

Cooper’s Hawk (Nesting). The Cooper’s hawk is a CDFW watch list species (nesting) and a MHCP-covered species (CDFW 2024a; SANDAG 2003). This species has a moderate potential to occur due to the presence of suitable trees for nesting within the disturbed land and urban/developed within the survey area . No individuals or active nests were observed at the time of the survey.

Nesting/Migratory Birds. The survey area has the potential to support migratory and nesting birds. Under Section 3503 of the California Fish and Game Code (CFGC), it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. Section 3503.5 of the CFGC prohibits take, possession, or destruction of any birds in the orders Falconiformes (raptors) or Strigiformes (owls), or of their nests and eggs.

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 5 ends

8.0 WILDLIFE CORRIDORS AND LINKAGES
Though it is reasonable to assume that urban-adapted species may occur locally within the modified project, the project as a whole does not function as a wildlife movement corridor and there is no indication that it supports any wildlife nursery sites. The modified project is outside any City FPAs and biological core and linkage areas (BCLA).

9.0 SIGNIFICANCE OF PROJECT IMPACTS AND PROPOSED MITIGATION This section describes project impacts and recommended avoidance and mitigation measures based on the County’s MHCP (SANDAG 2003) and Report Format and Content Recommendations for biological resources reports (City of San Marcos 2022).

9.1 Vegetation Community Impacts and Proposed Mitigation The modified project would cause direct permanent impacts to 2.3 acres of disturbed land and 0.4 acres of urban/developed (Table 2; Figure 7). Impacts to disturbed land and urban/developed are not considered significant and, therefore, no mitigation would be required.

Table 2
Habitat/Vegetation Communities, Impacts, and Mitigation Habitat/
Vegetation Community
Total Impacts
(acres)3
Mitigation
Ratio
Mitigation
Required
(acres)
Disturbed Land (Group F) 2.3 0:1 0.0
Urban/Developed (--1) 0.4 N/A N/A
TOTAL2 2.7 - 0.0
1No Multiple Habitat Conservation Program assigned group. 2Total acres include approved project acreage (2.3 acres) plus modified project acreage (0.4 acres).
3Rounded to nearest tenth of an acre. Any discrepancies in totals are due to rounding.

N/A = not applicable

9.2 Sensitive Plant Species
The modified project would result in direct permanent impacts to decumben t goldenbush, an impact that was disclosed in the MND for the approved project. No additional sensitive plant species were observed within the additional 0.4 acres of the modified project area in 2024. Project impacts to sensitive plant species would be limited to decumbent goldenbush within the previously approved project footprint. The 2023 MND concluded that these impacts are less than significant because the habitat for decumbent goldenbush is of marginal quality due to heavy disturbance and comprises a small fraction of the habitat available to this species both at a local level (within the City) and on a regional scale. Because the modified project does not result in any additional impacts to this species beyond that which was disclosed for the approved project, the impacts that would occur to sensitive plants would remain less than significant and no mitigation would be required.

9.3 Sensitive Wildlife Species
Migratory and Nesting Birds. Direct impacts to migratory and nesting birds, including Cooper’s hawk, could result from the accidental destruction of nests during project construction activities. These impacts could occur if removal of suitable habitat for these species, such as the ornamental trees that ring the survey area were to occur during the general bird breeding season (between February 1 and September 15). Therefore, mitigation measure BIO-1 from the Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 6 ends

MND will be implemented during construction to prevent direct impacts to migratory and nesting birds, including Cooper’s hawk. Mitigation measure BIO-1 language from the MND is provided below for reference. Please note that the measure BIO-1 from the approved project used “March” and “September” as the dates within which surveys would be required. To provide greater specificity and ensure all migratory birds, including early nesting passerines and raptors are protected, minor edits to BIO-1 are provided below. In addition, impacts to nesting birds may occur up to 300 feet from the modified project footprint and as such, BIO-1 has been modified to clarify that surveys should be conducted within that survey distance prior to construction. New language is included in underline; removed language is shown in strike-through font:

BIO-1: If construction initiation occurs between March February 1 and September 15, a pre-construction nesting bird and raptor survey within 300 feet of the project impact area shall be completed by a qualified biologist prior to vegetation removal. The pre-construction survey shall be conducted within 10 calendar days prior to the start of construction activities (including removal of vegetation). If any active nests are detected, the area will be flagged and mapped along with a buffer as recommended by the qualified biologist. The buffer area(s) established by the qualified biologist will be avoided until the nesting cycle is complete or it is determined that the nest is no longer active. The qualified biologist shall be a person familiar with bird breeding behavior and capable of identifying the bird species of San Diego County by sight and sound and determining alterations of behavior as a result of human interaction. Buffers will be based on species-appropriate buffers and/or local topography and line of sight, species behavior and tolerance to disturbance, and existing disturbance levels, as determined appropriate by the qualified biologist.

9.4 Jurisdictional Wetlands and Waterways
No potential jurisdictional wetlands or waters were observed on-site. Therefore, there are no anticipated impacts to any jurisdictional wetlands or waterways and no mitigation would be required.

9.5 Wildlife Movement and Nursery Sites
Though it is reasonable to assume that urban-adapted species may occur locally within the impact footprint, the site as a whole does not function as a wildlife movement corridor and there is no indication that the site supports any wildlife nursery sites. Therefore, the project will not result in any impact to wildlife movement or nursery sites and no mitigation would be required.

The modified project also is outside any City FPAs and BCLA. Therefore, there are no impacts anticipated to wildlife movement corridors, wildlife nursery sites, FPAs, or a BCLA.

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 7 ends

10.0 REFERENCES CITED
American Society of Mammalogists
2020 Mammalian Species (online). http://www.mammalsociety.org/publications/mammalian-species. July.

Bradley, R. D., L.K. Ammerman, R. J. Baker, L. C. Bradley, J. A. Cook, R. C. Dowler, C. Jones, D. J. Schimdly, F. B. Stangl Jr., R. A. Van Den Bussche, and B. Wursig
2014 Revised Checklist of North American Mammals North of Mexico. Occasional Papers, Museum of Texas Tech University No. 327. October.

Brenzel, K. N.
2001 Sunset Western Garden Book. Sunset Publishing. Menlo Park, California.

California Department of Fish and Wildlife (CDFW)
2024a Special Animals. Natural Diversity Database. Department of Fish and Wildlife. October.

2024b Special Vascular Plants, Bryophytes, and Lichens List. Natural Diversity Database. Department of Fish and Wildlife. October.

2024c State and Federally Listed Endangered, Threatened, and Rare Plants of California. October .

2024d State & Federally Listed Endangered & Threatened Animals of California. October .

California Native Plant Society (CNPS)
2024 Rare Plant Program. Inventory of Rare and Endangered Plants of California (online edition, v8 -03).

Sacramento, CA. Accessed in July. Available at http://www.rareplants.cnps.org.

Chesser, R. T., S. M. Billerman, K. J. Burns, C. Cicero, J. L. Dunn, B. E. Hernández-Baños, A. W. Kratter, I. J. Lovette, N. A.

Mason, P. C. Rasmussen, J. V. Remsen, Jr., D. F. Stotz, and K. Winker 2021 Check-list of North American Birds (online). American Ornithological Society. http://checklist.aou.org/taxa.

Crother, B. I., Ronald M. Bonett, Jeff Boundy, Frank T. Burbrink, Kevin de Queiroz, Darrel R. Frost, Richard Highton, John B. Iverson, Elizabeth L. Jockusch, Fred Kraus, Kenneth L. Krysko, , Adam D. Leaché, Emilly Moriarty Lemmon, Roy W. McDiarmid, Joseph R. Mendelson III, Peter A. Meylan, Tod W. Reeder, Sara Ruane, and Michael E. Seidel 2017 Scientific and Standard English Names of Amphibians and Reptiles of North America North of Mexico, with Comments Regarding Confidence in our Understanding, Eighth Edition. Society for the Study of Amphibians and Reptiles Herpetological Circular No. 43.

Eriksen, Clyde, and Denton Belk
1999 Fairy Shrimp of California’s Puddles, Pools, and Playas. Mad River Press, Eureka.

Evans, Arthur V.
2008 Field Guide to Insects and Spiders of North America. Sterling Publishing Company, New York.

Harvey, M. J., J. S. Altenbach, and T. L. Best
2011 Bats of the United States and Canada. The Johns Hopkins University Press, Baltimore.

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 8 ends

Jennings, M. R., and M. P. Hayes
1994 Amphibian and Reptile Species of Special Concern in California. Final report submitted to the California Department of Fish and Game, Inland Fisheries Division, Rancho Cordova, CA. Contract number 8023.

Jepson Flora Project (eds.)
2020 Jepson eFlora, http://ucjeps.berkeley.edu/IJM.html.

Nature Festivals of San Diego County
2002 Checklist of Butterflies of San Diego County. Professional review by David Faulkner of the San Diego Natural History Museum and Dr. John Brown of the Smithsonian Institute. Revised September. http://www.sdnhm.org/science/entomology/projects/checklist-of-butterflies-of-san-diego-county/.

NatureServe
2021 NatureServe Explorer. www.natureserve.org.

Oberbauer, T., M. Kelly, and J. Buegge
2008 Draft Vegetation Communities of San Diego County. Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California,” Robert F. Holland, Ph.D., October 1986. March.

Page, L. M., H. Espinosa-Pérez, L. T. Findley, C. R. Gilbert, R. N. Lea, N. E. Mandrak, R. L. Mayden, and J. S. Nelson 2013 Common and scientific names of fishes from the United States, Canada, and Mexico, 7 th edition. American
Fisheries Society, Special Publication 34, Bethesda, Maryland.

Rebman, J. P., and M. G. Simpson
2014 Checklist of the Vascular Plants of San Diego County, 5th edition. San Diego Natural History Museum.

RECON Environmental, Inc.
2022 Biological Resources Report for the Santa Fe Flores Project (RECON Number 9865). November 29.

Reiser, C. H.
2001 Rare Plants of San Diego County. Aquafir Press. July.

San Diego, County of
2010 Guidelines for Determining Significance. Biological Resources, Land Use and Environment Group.

Department of Planning and Land Use. Department of Public Works. Fourth Revision. September 15.

San Diego Association of Governments (SANDAG)
2003 Final MHCP Plan. Prepared for the Multiple Habitat Conservation Program for the Cities of Carlsbad, Encinitas, Escondido, San Marcos, Solana Beach, and Vista. Volumes I, II, and III. March.

San Marcos, City of
2001 Natural Community Conservation Plan for the City of San Marcos. Agency review draft, May.

2022 Report Format and Content Recommendations, Biological Resources Report. May. Available:
https://www.san-marcos.net/home/showpublisheddocument/26428/637883135667770000

Tremor, Scott, D. Stokes, W. Spencer, J. Diffendorfer, H. Thomas, S. Chivers, and P. Unitt, eds. 2017 San Diego County Mammal Atlas. San Diego Natural History Museum.

Santa Fe Flores Townhomes Project Biological Resources Letter Report

Page 9 ends

Unitt, P. A.
2004 San Diego County Bird Atlas. San Diego Natural History Museum, Ibis, San Diego

United States Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS) 2024 The PLANTS Database. National Plant Data Team, Greensboro, North Carolina, USA. Accessed from http://plants.usda.gov.

U.S. Fish and Wildlife Service (USFWS)
2024 Species Observation Database.

U.S. Geological Survey (USGS)
1996 7.5 minute topographic map series, San Marcos quadrangle, Los Vallecitos de San Marcos Land Grant.

Western Bat Working Group (WBWG)
2017 Western Bat Species (species accounts). http://wbwg.org/western-bat-species/.

11.0 LIST OF PREPARERS
RECON Environmental, Inc.

Jade Woll, Biologist
Danelle Gadia, Biologist
Benjamin Arp, GIS Specialist
Stacey Higgins, Senior Production Specialist
Steven Gaughran, Production Specialist

!
!
!
!
!
!
!
!
!
!
!
Los
Penasquitos Canyon Presv
Daley Ranch
Lake Wohlford
Batiquitos Lagoon
Lake Hodges
San Vicente
Reservoir
Usmc Air
Station
Miramar
Camp Pendleton
Marine Co Base
Cleveland National
Forest
Temecula
San Diego
Encinitas
Oceanside
Poway
San Marcos
Vista
Carlsbad
Santee
Escondido
Solana
Beach
Del
Mar
Pauma and
Yuima
Reservation
Pala
Reservation
San
Pasqual
Reservation
Rincon
Reservation
Pechanga
Tribal Lands
Bonsall
Camp Pendleton
North
Camp Pendleton South
Eucalyptus
Hills
Fairbanks
Ranch
Fallbrook
Hidden
Meadows
Lake
San Marcos
Rainbow
Rancho
Santa Fe
Valley Center

R I V E R S I D E

C O U N T Y

S A N D I E G O

C O U N T Y
78 56
67 805
5 15
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 10/29/2024 fmm Regional Location
FIGURE 1
0 5Miles [
Project Locationkj
kj
FIGURE 2
Project Location on USGS Map
Map Source: USGS 7.5 minute topographic map series, San Marcos quadrangle, 1996, Los Vallecitos de San Marcos Land Grant 0 2,000Feet
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 12/12/2025 bma [
Project Boundary
Off-site Improvements
FIGURE 3
Project Location on Aerial Photograph

NLAS FL

ORES DR

NORMANSTRASSERD
VIA
LA V
ENTA

S SANTA FE AVE
21716117
21716119
21716118
21716117
0 150Feet
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 12/12/2025 bma [
Project Boundary
Off-site Improvements
Approved Project
Modified Project
Parcels
Image Source: Nearmap (flown September 2025)
FIGURE 4
Project in Relation to MSCP Preserve Area

RANCHO SA
NTAFE

MISSION

SOUTH SANTA FE
UV78
0 600Feet
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 12/12/2025 bma [
Project Boundary
Off-site Improvements
North County Draft MSCP
Outside Open Space Network
Draft San Marcos MHCP Subarea Plan
Focused Planning Areas
Hardline Preserve Area
Softline Planning Area
Image Source: Nearmap (flown September 2025)
FIGURE 5
Project Survey Areas

NLAS FLO
RES DR

S SANTA FE AVE
0 100Feet
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 12/12/2025 bma [
Project Boundary
Off-site Improvements
Survey Area 2022 (Approved Project)
Survey Area 2024 (Modified Project)
Image Source: Nearmap (flown September 2025)
FIGURE 6
Existing Biological Resources

LAS FLORES DR
N L
AS F

LORES DR

S SANTA FE AVE
0 100Feet
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 12/12/2025 bma [
Project Boundary
Off-site Improvements
Modified Project
Decumbent Goldenbush
(Isocoma menziezii decumbens)
Vegetation Community
Disturbed Land
Urban/Developed
Image Source: Nearmap (flown September 2025)
30 individuals
FIGURE 7
Impacts to Biological Resources

LAS FLORES DR
N L
AS FLO
RES
DR

S SANTA FE AVE
0 100Feet
M:\JOBS6\10587\common_gis\PRO\standard_figures\standardfigures.aprx 12/12/2025 bma [
Project Boundary
Off-site Improvements
Modified Project
Impact Areas
Decumbent Goldenbush
(Isocoma menziezii decumbens)
Vegetation Community
Disturbed Land
Urban/Developed
Image Source: Nearmap (flown September 2025)
30 individuals

ATTACHMENTS

ATTACHMENT 1
Site Photographs

P:\10587\Bio\Photos\Photos1&2.docx 11/18/2024
PHOTOGRAPH 1
View of Disturbed Land in Project Site, Facing Southeast

PHOTOGRAPH 2
View of Disturbed Land and Urban/Developed in Project Site, Facing Northwest

ATTACHMENT 2
Plant Species Observed

Santa Fe Flores Townhomes Project

Page 1 ends

Attachment 2
Plant Species Observed
Scientific Name Common Name Habitat Origin
ANGIOSPERMS: MONOCOTS

ARECACEAE PALM FAMILY
Washingtonia robusta Mexican fan palm DL I

POACEAE (GRAMINEAE) GRASS FAMILY
Avena sp. oats DL I
Bromus diandrus ripgut grass DL I
Bromus rubens [=Bromus madritensis ssp. rubens] red brome DL I Festuca perennis [=Lolium multiflorum and Lolium perenne] rye grass DL I Hordeum murinum wall barley DL I
Pennisetum setaceum crimson fountain grass DL I
ANGIOSPERMS: EUDICOTS

AIZOACEAE FIG-MARIGOLD FAMILY
Carpobrotus edulis freeway iceplant DL I

ANACARDIACEAE SUMAC OR CASHEW FAMILY
Schinus molle L. Peruvian pepper tree DL I
Searsia [=Rhus] lancea African sumac UD I

APIACEAE (UMBELLIFERAE) CARROT FAMILY
Foeniculum vulgare fennel DL I

ASTERACEAE SUNFLOWER FAMILY
Baccharis pilularis chaparral broom, coyote brush DL N
Baccharis salicifolia ssp. salicifolia mule fat, seep-willow DL N Cynara cardunculus ssp. flavescens cardoon, artichoke thistle DL I Dittrichia graveolens stinkwort DL I
Hedypnois cretica Crete weed

DL I

Santa Fe Flores Townhomes Project

Page 2 ends

Attachment 2
Plant Species Observed
Scientific Name Common Name Habitat Origin
Helminthotheca [=Picris] echioides bristly ox-tongue

DL I
Heterotheca grandiflora telegraph weed

DL N
Isocoma menziesii coastal goldenbush

DL N
Isocoma menziesii var. decumbens decumbent goldenbush

DL N

BRASSICACEAE (CRUCIFERAE) MUSTARD FAMILY
Brassica sp. mustard DL I
Brassica rapa turnip, field mustard DL I

CAPRIFOLIACEAE HONEYSUCKLE FAMILY
Lonicera japonica Japanese honeysuckle UD I

CHENOPODIACEAE GOOSEFOOT FAMILY
Salsola tragus Russian thistle, tumbleweed DL I

CONVOLVULACEAE MORNING-GLORY FAMILY
Calystegia macrostegia morning-glory DL N

EUPHORBIACEAE SPURGE FAMILY
Euphorbia peplus petty spurge DL I

Santa Fe Flores Townhomes Project

Page 3 ends

Attachment 2
Plant Species Observed
Scientific Name Common Name Habitat Origin

FABACEAE (LEGUMINOSAE) LEGUME FAMILY
Acacia redolens Maslin desert carpet DL I
Acmispon glaber [=Lotus scoparius] deerweed, California broom DL N Astragalus trichopodus var. lonchus ocean locoweed DL N Medicago polymorpha California burclover DL I
Melilotus albus white sweetclover DL I

GERANIACEAE GERANIUM FAMILY
Erodium botrys long-beak filaree DL I
Erodium moschatum greenstem filaree DL I

MALVACEAE MALLOW FAMILY
Malva neglecta common mallow, cheeses DL I

OXALIDACEAE OXALIS FAMILY
Oxalis pes-caprae Bermuda buttercup DL I

POLYGONACEAE BUCKWHEAT FAMILY
Polygonum aviculare Prostrate knotweed DL I

SCROPHULARIACEAE FIGWORT FAMILY
Myoporum parvifolium slender myoporum UD I

VERBENACEAE VERVAIN FAMILY
Lantana montevidensis trailing lantana UD I
NOTE: Scientific and common names were primarily derived from Jepson eFlora (Jepson Flora Project 2020). In instances where common names were not provided in this resource, common names were obtained from Rebman and Simpson (2014). Additional common names were obtained from the USDA maintained database (USDA 2021) or the Sunset Western Garden Book (Brenzel 2001) for ornamental/horticultural plants. Common names denoted with * are from County of San Diego 2010.

HABITAT ORIGIN
DL = Disturbed Land N = Native to locality
UD = Urban/Developed I = Introduced species from outside locality

ATTACHMENT 3
Wildlife Species Observed

Santa Fe Flores Townhomes Project

Page 1 ends

Attachment 3
Wildlife Species Observed

Scientific Name

Common Name

Occupied
Habitat
On-Site Abundance/
Seasonality (Birds Only) Evidence of Occurrence

INVERTEBRATES

PIERIDAE WHITES & SULPHURS
Pieris rapae cabbage white (I) DL O
BIRDS

ACCIPITRIDAE HAWKS, KITES, & EAGLES
Buteo lineatus red-shouldered hawk FO F/ Y O

COLUMBIDAE PIGEONS & DOVES
Zenaida macroura mourning dove FO C/ Y O

TROCHILIDAE HUMMINGBIRDS
Calypte anna Anna’s hummingbird DL C/ Y O

CORVIDAE CROWS, JAYS, & MAGPIES
Corvus brachyrhynchos American crow FO C/ Y O

AEGITHALIDAE BUSHTIT
Psaltriparus minimus bushtit UD C/ Y V
Melozone [=Pipilo] crissalis California towhee DL C/ Y O

MAMMALS

SCIURIDAE SQUIRRELS & CHIPMUNKS
Otopermophilus [=Spermophilus] beecheyi California ground squirrel DL B

CANIDAE CANIDS
Canis latrans coyote DL S
(I) = Introduced species
NOTE: Zoological nomenclature for invertebrates is in accordance with the NatureServe 2021 and Evans 2008; for fish with Natu reServe 2021; for reptiles and amphibians with Crother et. al (2017); for birds with Chesser et al. 2021; for mammals with Bradley et al. (2014), American Society of Mammalogists 2021.

Santa Fe Flores Townhomes Project

Page 2 ends

Attachment 3
Wildlife Species Observed

Scientific Name

Common Name

Occupied
Habitat
On-Site Abundance/
Seasonality (Birds Only) Evidence of Occurrence

HABITATS ABUNDANCE
DL = Disturbed land C = Common to abundant; almost always encountered in proper habitat, usually in FO = Flying overhead moderate to large numbers
UD = Urban/developed F = Fairly common; usually encountered in proper habitat, generally not in large numbers

EVIDENCE OF OCCURRENCE SEASONALITY (birds only)
B = Burrow Y = Year-round resident; probable breeder on-site or in vicinity O = Observed
S = Scat
V = Vocalization

ATTACHMENT 4
Sensitive Plant Species with the Potential to Occur

Santa Fe Flores Townhomes Project

Page 1 ends

Attachment 4
Sensitive Plant Species Observed or with the Potential to Occur Scientific Name
Common Name
Sensitivity Code & Status
Habitat Preference/
Requirements
Detected On-Site
Yes/No
Potential to
Occur On-Site
(Observed or

L/M/H/U)
Basis for Determination of
Occurrence Potential
State/
Federal
Status
CNPS
Rank
County of
San Diego
ANGIOSPERMS: DICOTS

APIACEAE CARROT FAMILY
Eryngium aristulatum var. parishii
San Diego button-celery
SE/FE 1B.1 -- Biennial/perennial herb; vernal
pools, mesic areas of coastal sage
scrub and grasslands, blooms
April–June; elevation less than
2,000 feet. Known from San Diego
and Riverside counties. Additional
populations occur in Baja
California, Mexico.

No U Unlikely to occur due to lack
of vernal pools, mesic areas of
coastal sage scrub, and
grasslands. This species has
been documented within a
one-mile radius of the project
site (CDFW 2024b).

ASTERACEAE SUNFLOWER FAMILY
Isocoma menziesii var. decumbens
decumbent goldenbush
–/– 1B.2 -- Perennial shrub; chaparral, coastal
sage scrub; sandy soils, often in
disturbed areas; blooms April–
November; elevation less than 500
feet.

Yes H This species was observed
within the project site.

Santa Fe Flores Townhomes Project

Page 2 ends

L/M/H/U)
Basis for Determination of
Occurrence Potential
State/
Federal
Status
CNPS
Rank
County of
San Diego
ANGIOSPERMS: MONOCOTS

THEMIDACEAE BRODIAEA FAMILY
Brodiaea filifolia
thread-leaved brodiaea
[=thread-leaf brodiaea]
SE/FT 1B.1 -- Perennial herb (bulbiferous);
cismontane woodland, coastal
sage scrub, playas, valley and
foothill grassland, vernal pools;
often clay soils; blooms March–
June; elevation 80-3,675 feet.

California endemic. Known from
San Diego, Riverside, Orange, Los
Angeles, and San Bernardino
counties.

No U Unlikely to occur due to lack
of cismontane woodland,
coastal sage scrub, playas,
valley and foothill grassland,
and vernal pools. This species
has been documented within
a one-mile radius of the
project site (CDFW 2024b).

Brodiaea orcuttii
Orcutt’s brodiaea
–/– 1B.1 -- Perennial herb (bulbiferous);
closed cone coniferous forest,
chaparral, meadows and seeps,
valley and foothill grassland,
vernal pools; mesic, clay soil;
blooms May–July; elevation less
than 5,600 feet.

No U Unlikely to occur due to lack
of closed cone coniferous
forest, chaparral, meadows and
seeps, valley and foothill
grassland, and vernal pools
.

This species has been
documented within a one-
mile radius of the project site
(CDFW 2024b).

Santa Fe Flores Townhomes Project

Page 3 ends

L/M/H/U)
Basis for Determination of
Occurrence Potential
State/
Federal
Status
CNPS
Rank
County of
San Diego
NOTE: Scientific and common names were primarily derived from Jepson eFlora (Jepson Flora Project 2020). In instances where common names were not provided in this resource, common names were obtained from Rebman and Simpson (2014). Additional common names were obtained from the USDA maintained database (USDA 2021) or the Sunset Western Garden Book (Brenzel 2001) for ornamental/horticultural plants. Common names denoted with * are from County of San Diego 2010.

FEDERAL CANDIDATES AND LISTED PLANTS STATE LISTED PLANTS FE = Federally listed endangered SE = State listed endangered FT = Federally listed threatened

CALIFORNIA NATIVE PLANT SOCIETY (CNPS): CALIFORNIA RARE PLANT RANKS (CRPR) 1B = Species rare, threatened, or endangered in California and elsewhere. These species are eligible for state listing. .1 = Species seriously threatened in California (over 80% of occurrences threatened; high degree and immediacy of threat). .2 = Species fairly threatened in California (20-80% occurrences threatened; moderate degree and immediacy of threat).

POTENTIAL TO OCCUR ON-SITE
U = Unexpected

ATTACHMENT 5
Sensitive Wildlife Species with the Potential to Occur

Santa Fe Flores Townhomes Project

Page 1 ends

Attachment 5
Sensitive Wildlife Species Occurring or with the Potential to Occur Common Name/
Scientific Name
Sensitivity Code & Status
Habitat Preference/
Requirements
Detected
On-Site?
Yes/No
Potential to
Occur On-Site
(Observed or

L/M/H/U)
Basis for Determination of
Occurrence Potential
State/Federal
Status
County of
San Diego

INVERTEBRATES

BRANCHINECTIDAE FAIRY SHRIMP
San Diego fairy shrimp
Branchinecta sandiegonensis
FT MHCP Vernal pools. No U Not expected to occur. No
vernal pools or other
depressions containing
wetland or vernal pool plant
species characteristic of vernal
habitat were observed.

BIRDS

ACCIPITRIDAE HAWKS, KITES, & EAGLES
Cooper’s hawk (nesting)
Accipiter cooperii
WL/- MHCP Mature forest, open
woodlands, wood edges,
river groves. Parks and
residential areas.

No M Moderate potential to nest
within the project site due to
the presence of suitable trees
for nesting.

POLIOPTILIDAE GNATCATCHERS
Coastal California gnatcatcher
Polioptila californica californica
SSC/FT MHCP Coastal sage scrub, maritime
succulent scrub. Resident.

No U Not expected to occur due to
the lack of coastal sage scrub,
and maritime succulent scrub.

This species has been
documented within a one-mile
radius of the project site
(CDFW 2024b).

Santa Fe Flores Townhomes Project

Page 2 ends

L/M/H/U)
Basis for Determination of
Occurrence Potential
State/Federal
Status
County of
San Diego

PASSERELLIDAE NEW WORLD PASSERINES
Southern California rufous-crowned sparrow
Aimophila ruficeps canescens
WL/- MHCP Coastal sage scrub,
chaparral, grassland.

Resident.

No U Not expected to occur due to
the lack of coastal sage scrub,
chaparral, and grassland. This
species has been documented
within a one -mile radius of
the project site (CDFW 2024b).

MAMMALS

MUSTELIDAE WEASELS, OTTERS, & BADGERS
American badger
Taxidea taxus
SSC/- -- Grasslands, Sonoran desert
scrub.

No U Not expected to occur in the
project site due to the high
level of disturbance and lack
of suitable habitat. This species
has been documented within a
one-mile radius of the project
site (CDFW 2024a).
(I) = Introduced species
NOTE: Zoological nomenclature for invertebrates is in accordance with the NatureServe 2021 and Evans 2008; for fish with NatureServe 2021; for reptiles and amphibians with Crother et. al (2017); for birds with Chesser et al. 2021; for mammals with Bradley et al. (2014), American Society of Mammalogists 2021. Determination of the potential occurrence for listed, sensitive, or not eworthy species is based upon known ranges and habitat preferences for species follows Eriksen and Belk 1999, Nature Festivals of San Diego County 2002, Evans 2008, Page et al. 2013, Jennings and Hayes 1994, Unitt 2004, Tremor et. al. 2017, Western Bat Working Group 2017, and Harvey et al. 2011. Listing status is based on California Department of Fish and Wildlife, Natural Diversity Database (CDFW) 2024d and the County of San Diego MHCP (SANDAG 2003).

Santa Fe Flores Townhomes Project

Page 3 ends

Attachment 5
Sensitive Wildlife Species Occurring or with the Potential to Occur

STATUS CODES
Listed/Proposed
FT = Listed as threatened by the federal government

Other
SSC = California Department of Fish and Wildlife species of special concern WL = California Department of Fish and Wildlife watch list species MHCP = Multiple Habitat Conservation Program covered species

Potential to Occur On-Site
M = Medium
U = Unexpected

San Marcos City CouncilMay 26, 2026

San Marcos City Council
May 26, 2026