San Marcos City Council
September 8, 2026

ATTACHMENT F

SUPPLEMENTAL APPEAL LETTER
DATED JULY 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
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July 31, 2026

Via Overnight Mail, and Email
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Rebecca Jones, Mayor
Members of City Council
c/o Phillip Scollick, City Clerk
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069

Re: Lanikai’s Response in Support of Ap peal of City Manager Resolution ADM 26- 5226 –Appeal Hearing Scheduled For September 8, 2026

Dear Mayor Jones and Members of the City Council:

This firm represents Lanikai Management (“Lanikai”), applicant for the Lanikai senior residential project (the “Project”) proposed for the 3.9-acre parcel at the northwest corner of E. Mission Road and Woodward Street. The Project has undergone a full and robust environmental review pursuant to the California Environmental Quality Act (CE QA), a process that has taken more than eight years to complete. The Project’s mitigated negative declaration (MND) is complete and ready to be circulated to the public as required by CEQA a nd then presented to th e City of San Marcos Planning Commission and City Council for approval. City staff, however, has refused to release the MND to the public, thereby bringing a cold halt to the CEQA process and leaving the Project is limbo.

Staff’s position was recently formalized in City Manager Resolution ADM 26-5226, adopted on July 2, 2026, which is the subject of Lanikai’s appeal to the City Council dated July 10, 2026. This letter and its attached exhibits provide the lega l and factual bases for La nikai’s appeal, which is scheduled to be heard by the City Council on September 8, 2026.

As explained below, staff’s position that the MND is incomplete is not supported by evidence in the record. Rather, staff is withholding release of the MND to leverage certain road improvements which the City wants Lanikai to pay for and install. The data show that the Project’s traffic impacts do not warrant the road improvements in question. To the contrary, the Project’s traffic will have minimal effect on the intersection and road segments in controversy.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS

Undaunted by this fact, staff claim that the Project’s senior pedestrians, due to their age and slower walking speeds, require a hugely expensive curb extension (know n as a “bulb-out") so that they can safely cross E. Mission without unduly affecting vehicle flow. We will demonstrate below that this claim is baseless. By the City’s own reckoning, the Project generates only 23 pedestrian trips per day, which comes to less than three (3) per hour if one spreads them out only among daylight hours (8 a.m. to 4 p.m.).
1 This impact, even if it counts as one under CEQA, can be effectively mitigated by modifying the traffic signals at E. Mission and Woodward to include pedestrian- friendly activators, which, when the button is pushed, would increase the crossing time by 8 seconds and then revert back to normal. This pedestrian-related delay becomes negligible, almost imperceptible, over the course of a day.

Staff, however, will not even entertain this easy and relatively inexpensive fix. Instead, staff continue to insist that Lanikai install the raised curb bulb-out. What the evidence shows is that staff want the bulb-out not to address a Project impact or improve pedestrian safety, but to redress a design flaw along this stretch of E. Mission Road, one that has existed since the road was built.

The law, however, does not permit the City to foist the cost of correcting this long-standing design problem onto Lanikai.

Staff have also argued that the raised curb bulb-out is required by the City’s Active Transportation Plan (ATP). This, too, turns out to be a gross overstatement. The ATP does require “curb extensions” in some situations – and it’s far from clear if Lanikai creates such a one here – but the ATP also states that the curb extension can be accomplished via striping (i.e., painting) and delineation, which Lanikai ha s offered to do. (ATP, § 1.107.5 [Accommodating Pedestrians] , attached hereto as Exhibit 1 .) Raised curbs are also allowed, but not required. ( Id.) In fact, Lanikai’s research reveals that raised curb-bulb outs do not exist anywhere else in the City of San Marcos and, according the California Highway De sign Manual, should be installed only when a specific set of criteria are met. For example, they should be installed primarily where there is street parking along the roadway in quest ion, as they allow the pedestri ans to be seen more easily by passing vehicles. There is no street parking along this portion of E. Mission. In addition, raised curb bulb-outs should be installed only where th e average vehicle speed is 35 miles per hour or less; Mission Road’s posted speed limit is 40 miles per hour, with 85 percent of cars travelling at 45 miles per hour.

In short, the Project’s impacts do not warrant th e raised curb bulb-out, a nd staff’s arguments for demanding it do not withstand scrutiny. This is primarily because staff is trying to disguise a public amenity (which the City is require d to pay for) as a required mitigation measure (which Lanikai must pay for). The attempt fails at every turn, resulting in a violation of both CEQA and the “rough

1 The pedestrian per-hour figure diminishes to almost nothing if the 23 pedestrian trips are allocated over an entire day.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
proportionality” rule of Dolan v. City of Tigard, 512 U.S. 374, 394-395 (1994) and Ehrlich v. City of Culver City, 12 Cal.4th 854 (1996).

Finally, there is the matter of the Project’s proposed “right-in/right-out” driveway along E. Mission Road. Staff contend that driveway curb cuts al ong E. Mission are not allowed under the City’s Street Design Criteria, which would leave Lanikai with only one driveway for ingress and egress, located on Woodward Street. The Ca lifornia Fire Code, however, re quires at leas t two separate driveways for multi-family reside ntial projects of 100 dwelling uni ts or more. (C al.Fire Code, §D106.1, a copy of which is attached hereto as Exhibit 2 .) Lanikai’s project consists of 115 dwelling units and thus is subject to the Fire Code’s two-driveway rule. 2 The City’s local fire code
is even more demanding, as it requires two-access ways for any project with more than 50 units.

Staff initially recognized that the curb cut at Mission was necessa ry to satisfy these public safety mandates. Now, however, staff is asserting that it will approve the driveway at Mission only if Lanikai installs the disputed ra ised curb bulb-out at the inte rsection of Mission and Woodward.

There is, of course, no techni cal study or other evidence s howing a connection between the driveway at Mission and the demanded bulb-out; traffic in and out of the first does not require the second. Lanikai’s research also shows that th e alleged “rule” prohibiting driveways along E.

Mission is honored more in the breach than in the observance. For example, the City approved the West and East Mission 316 projects located immediately across Woodward from the Lanikai site, and those projects include a new driveway onto Mission. (See Mission 316 West Draft EIR, p. 4.4- 9, attached hereto as Exhibit 3.)

Ultimately, then, the only reason the MND cannot be finalized and circulated is that staff continue to demand road improvements unrel ated to any significant effect of the Project. There are no additional environmental studies to prepare, no additional impacts to consider or disclose in the document. Staff is simply holding the MND hostage hoping that Lanikai will eventually capitulate and agree to include the disputed public amenit ies into the Project’s design. Lanikai will not do that; and the City Council must rein it its staff to prevent further violations of CEQA and the takings clause of the Fifth Amendment.

For these reasons, more fully articulated below, Lanikai respectfully requests that the City Council overturn City Manager Resolution ADM 26-5226; declare the MND complete and consistent with the project description proposed by Lanikai; and direct the City Ma nager to release it for public review and comment.

2 The Fire Code “2-driveway” rule also includes a separation element, which requires that the two driveways “be placed apart equal to not less than one-half of the length of the maximum overall diagonal dimension of the property to be served, measured in a straight line between accesses.” (Cal.Fire Code, D106.3 [see Exhibit 2 attached hereto.) Due to this separation requirement, Lanikai cannot place both driveways along its Woodward frontage; one of the driveways must be on Mission.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
What follows is a point-by-point rebuttal to the statements and findings set forth in the City Manager’s resolution.

Lanikai’s Response to City Manager Resolution ADM 26-5226

Compliance with City Standards.

In the “WHEREAS” clauses of the Resolution, the City Manager states that the City’s Street Design Criteria “do not permit a driveway on a prime arterial or secondary arterial when a driveway is possible at another location.” Accord ing to the Resolution, E. Mission is an arterial road way and thus the proposed “Mission Road driveway is not pe rmitted under SMMC

17.40.060(a), nor would it be permitted without appropriate mitigation of the impacts associated with it.” (Resolution, p. 2., Item 1.). As stated above, the City routinely deviates from SMMC

14.40.060(a) by allowing driveways along arterials, including Mission Road, as it did in 2014 with the Mission 316 East project located a fe w hundred feet from the Lanikai site. 3 Further, such
deviations are no doubt necessary to ensure comp liance with the Fire Code’s requirement that residential projects with 100 units have two separate means of escape during an emergency. That is the situation at Lanikai; and due to the Fire Code’s access “separation” requirement, those two driveways cannot both be located on Woodward. (S ee Cal.Fire Code, D106.3, attached hereto as Exhibit 2.) And, as mentioned above, the City’s own fire code demands two access points for residential projects with 50 or more units. So, there is no ques tion that a second driveway at Mission is needed to ensure the project’s compliance with these emergency response requirements.

The real question, then, is whether Lanikai’s proposed driveway at E. Mission creates impacts that must be mitigated by the raised curb bulb-out demanded by staff. The evidence shows that the answer is NO. The Project’s traf fic engineer, Justin Schlaefli, in reports reviewed and approved by City Staff, determined that during the AM peak hour, the Project generates only 23 vehicle trips, distributed evenly between the proposed driveway s at Woodward and Mission. Of these, only 7 would be outbound trips onto Mission. The PM peak is similar, with th e Project generating 32 vehicle trips during that hour, ag ain evenly distributed between the two driveways. Only 6.5 of these trips would be outbound onto Mission. This means that during the AM and PM peak hours, only one vehicle per every nine minutes would exit the Project via the E. Mission driveway.

According to Mr. Schlaefli, that level of traffic is de minimis and would have no bearing on vehicle queues at the Woodward and E. Mi ssion intersection; nor would it re sult in a significant traffic safety issue requiring modification of the in tersection’s design. (See Schlaefli Memorandum to Greg Scaduto (Lanikai), dated June 24, 2026, attached hereto as Exhibit 4 [right-in / right-out driveway onto Mission creates no traffic queuing impact at Mission/Woodward intersection].)

3 The City, in January 2020, approved the Mission 316 West project, which also includes two access points, one onto Woodward and one onto E. Mission using the Mission 316 East project’s driveway. (Mission 316 West Draft EIR, p.

4.4-9, attached hereto as Exhibit 3.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
In short, the Project’s proposed driveway at E. Mission does not require the raised curb bulb-out; it does, however, ensure that the Project complies with the Fire Code and provides adequate ingress and egress in the event of a fire or other emergency. It is also cons istent with driveway curb cuts permitted for other projects along this stretch of Mission Road.

Project Description

The Resolution, in “WHEREAS” item 2, asserts that the “draft MND does not adequately describe or evaluate a Project design that complies with applicable City require ments, standards, and criteria,” and goes on to argue that the “Mission Road driveway is not in compliance with City standards and criteri a, and it cannot be suppo rted without frontage imp rovements the Applicant declines to make.” The Resolution then states th at the driveway must be removed and that the MND “does not evaluate the impacts of removi ng the Mission Road driveway, which include modifications to frontage improvements, ac cess configurations, emergency access, trip distribution, and potentially the number of units proposed by the Project.” (Resolution, p. 2, Item

2.)

The Resolution’s statement, however, is premis ed on two false assumptions: First, that no driveways are allowed on Mission Road, which is factually inaccurate as the City’s approval of the Mission 316 project will attest; and second, that the Project’s impacts, whether in the form of vehicle traffic or pedestrian tr affic, trigger the need for the so-called “frontage” improvements along Mission. The evidence simply does not support the City Mana ger’s position. There are no data showing that the Project’s traffic or pedestrians create impacts that can only be mitigated by (a) eliminating the Mission driveway or (b) installing the raised curb out. Quite the opposite is true.

The data show that the Project’s traffic – both vehicle and pedestrian – is so small in number as to require no improvements along Mission or at the Mission/Woodward intersection at all.

For example, without the Project, all road segments and intersections operate at acceptable levels of service (LOS D or better) from the presen t through 2050, except two: (1) the intersection at Twin Oaks Valley Road and San Marcos Boulev ard, and (2) the intersec tion at E. Mission and Woodward. Both of these intersections are expect ed to operate at LOS E during the period in question. When added to anticipated “ambient” traffic levels, the Project’s traffic does not change the LOS on any road segment or intersection. Moreover, at th e Twin Oak Valley/San Marcos Boulevard and Mission/Woodward intersections, the Project’s traffic increases delay by less than

0.2 second, well under the 2-second delay significance threshold established by City.

To put these traffic figures in context, it is instructive to look at the trip counts for the Woodward 46 project, located directly acro ss the street from the Lanikai site, which the City approved in September 2025. According to its EIR, the Woodward 46 project would generate 29 vehicle trips during the AM Peak (6 in / 23 out) and 37 vehicl e trips during the PM P eak (26 in / 11 out). (Woodward 46 DEIR, Table 3.8-7, attached hereto as Exhibit 5.) The City determined that these

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
trips, when added to anticipated ambient tr affic levels from 2026 through 2050, would not result in any significant effect in term s of LOS at any road segment or intersection, including the very same road segments and intersections affected by the Lanikai project. ( Id.) Interestingly, because the Lanikai development is for seniors only, it generates fewer vehicle trips than Woodward 46 does – 23 versus 29 in the AM Peak, and 32 versus 37 in the PM Peak. It thus stands to reason that Lanikai, like Woodward 46, will produce no signifi cant traffic impacts, which is precisely what the Lanikai MND has concluded.

So, given the traffic data of these two projects, why is City staff claiming that Lanikai’s project will create significant traffic impacts that must be mitigated by road improvements such as the raised curb bulb-out – someth ing never mentioned in any of CEQA document prepared for Woodward 46? The only explanation is that staff are imposing a double-standard: one set of rules for Lanikai and another, more relaxed set of rules for everyone else.

Environmental Effects of Required Modifications.

Next, the Resolution, in “WHEREAS” item 3, cont ends that because Lanikai has refused to incorporate the “design revisions” demanded by staff (i.e., the raised curb-bulb out), “the draft MND does not provide a legally adequate basis to conclude that potentially significant effects have been avoided or mitigated to a less-than-significant level.” (Resolution, Item 3, pp. 2-3.)

The Resolution is in error and has placed the sli pper on the wrong foot. The traffic data set forth in the MND (and discussed in this letter) clearly establish that the Project will not have a significant impact on any road segment or intersection in the City. Accordingly, there is no basis for the City to demand mitigation from Lanikai, and the City has provided no evidence to the contrary. In short, there is no reason for Lanikai to study traffic mitigation in the MND. There is no need for it, and no legal justification for the City insisting upon it.

The same is true of the Projec t’s alleged contribution to pedestrian crossing delays at Woodward and Mission. According to data provided by City staff and the City Attorney, Lanikai’s project will generate only 23 pedestrian trips per day. (See Letter from City Attorney Punam Prahalad to David Hubbard, counsel for Lanikai, dated August 14, 2025, p. 9 of 54, attached hereto as Exhibit

6.) While those 23 pedestrian trips will likely be taken by senior citizens who walk more slowly than non-seniors, the resulting delay impact is de minimis. First, the number of pedestrian trips is incredibly small, even when allocated over a shortened day (i.e., daylight hours only). Second, those trips can be accommodated by simply installing new signal devices at the Woodward/Mission intersection that provide extra crossing time when activated by the pedestrian.

The devices then revert back to normal signal timing after the pedestrian makes it to the other side of the street. The project’s traffic consultant, Justin Schlaefli, explains this simple operational fix as follows:

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
The Mission crossing is approximately 118 feet, with a reported existing crossing time of about 31 seconds. The California MUTCD standard walking speed is 3.5 ft/s (about 34 seconds for this crossing); the recognized speed for older/disabled pedestrians is 2.8 ft/s, which yields about 42 seconds. Retiming to the 2.8 ft/s senior walking speed would therefore add roughly 8 to 11 seconds of pedestrian clearance time.

The operational effect is negligible, for tw o reasons. First, the pedestrian phase only runs when the push button is actuated - per th e City's own figure, about 23 pedestrian crossings per day, mostly outside peak hour s. Second, the pedestrian clearance runs concurrently with the parallel vehicle green , so the added time simply extends that green when a pedestrian is present; the longe r minimum is absorbed within the signal cycle. Averaged over the day, the change in delay for the intersection is a fraction of a second per vehicle and would not change the intersection's level of service. If the signal runs in coordination, the City would verify the longer pedestri an minimum fits the cycle - at the cycle lengths the City typically runs, it does.

The City operates Type 2070 controllers, and pedestrian Walk and Flashing Don't Walk intervals are programmable parameters. The work consists of a timing analysis, revised timing sheets, and implementation/ field verification by the City's signal technician. At a planning level, I would estimate:

- Engineering analysis and revised timing sheets: $3,000 - $5,000 - City staff implementation and field check : $500 - $1,500 (often absorbed as routine in-house work)
- Coordination plan check, if the City requires one because the intersection runs coordinated: $1,500 - $3,000

Total: roughly $5,000 - $10,000, and potentially near zero if the City simply retimes it in-house as routine maintenance. No new poles, heads, or push buttons are required (existing equipment is assumed to remain). For contrast, the bulb-out the City proposes is a construction project - curb, gutter, dr ainage, and ADA ramp work typically well into six figures - to shorten the crossing by only 10-12 feet, which at standard walking speed saves about four seconds.

In short, the pedestrian crossing concern in Item 4 is fully addressable through signal timing at nominal cost, without the bulb-out or roadway widening the City proposes.

(Schlaefli email to Greg Scaduto (Lanikai), dated July 14, 2026, attached hereto as Exhibit 7.)

Simply put, the Project’s pedestrian traffic does not rise to the level of a significant impact as defined by CEQA. And even if it did, that impact can be easily and inexpensively mitigated by installing more refined signal timing devices at the Woodward/Mission intersection. There is no need for the raised curb bulb-out demanded by City staff.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
The data discussed above beg the following questi on: If Lanikai’s vehicle trip and pedestrian numbers are too small to create a significan t impact on Mission or the Mission/Woodward intersection, why is City staff insisting that Lani kai install the raised curb bulb-out? The answer is found in an email from Isaac Etchamendy, Director of Development Services and City Engineer, to Justin Schlaefli, dated March 5, 2024, attached hereto as Exhibit 8 . In that email, Mr.

Etchamendy confesses that the City is demandi ng the bulb-out curb extension not so much to ensure pedestrian safety but to correct a long-standing flaw in the merge lane at E. Mission Road itself:

That lane merge is not consistent with cu rrent design requirements of the HDM. As a result, we have little desire to keep it, even as some type of an acceleration lane, given its insufficient length. Thus, we have contemplated a reallocation of the localized right- of-way along Mission to push the curb line south and establishing a bus bay. This reallocation of existing right-of-way to remove a substandard merge lane helps towards supporting this road as a complete street. Striving toward complete streets is mandated by our General Plan Mobility Element Polic y M-1.7 as well as being supported by the General Plan’s Mode preferences for Mission Road.

Later in the email, Mr. Etchamendy states that the bulb-out might also benefit pedestrians seeking to cross Mission. He does not, however, describe the bulb-out as necessary to mitigate a significant CEQA impact of the Project. Nor does he suggest that the bulb-out is required by the City’s Active Transportation Plan (ATP), most likely because he knows that the ATP does not require curb extensions to be raised. Rather, the ATP allows curb extensions at road-grade provided they are striped, painted, and delineated – something Lani kai has stated it is happy to do. (See ATP, §

1.107.5 [Accommodating Pedestrians], p. 13, attached hereto as Exhibit 1; see also, Letter from David Hubbard, counsel for Lanikai, to Punam Prahalad, City Attorney, dated May 26, 2026, p. 2, attached hereto as Exhibit 9.)

In light of Mr. Etchamendy’s email and City staff’s continued insistence on the bulb-out and related improvements to Mission Road, Lanikai asked Mr. Schlaefl i to assess whether staff’s position, from a traffic engineering perspective, has any basis in fact. His analysis is set forth in a memorandum addressed to Greg Scaduto of La nikai dated June 24, 2026, a copy of which is attached hereto as Exhibit 4. Key findings from that memorandum include the following:
 The conditions the Project generates can be addressed through stripi ng, delineation, and signal-timing measures already contemplated for the site — without raised curb construction, right-of way reallocation, or relocation of the existing traffic signal system.  Because Mission Road carries a raised median at this location, the Project’s proposed Mission Road driveway operates as a right-in / right-out movement only, which avoids queuing impacts at the Mission/Woodward intersection.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

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 The Project’s outbound peak-hour volume (14 vehicles in the AM, 13 in the PM) is split between the two site driveways (Woodward and Mission). Even assigning that volume conservatively, the Mission Road driveway is expected to discharge on the order of six to seven vehicles per peak hour — roughly one vehicle every nine to ten minutes.  The bulb-out does not satisfy the Caltrans criteria for curb extensions. o Caltrans Highway Design Manual Chapter 303.4 provides that curb extensions (bulb- outs) “are most appropriate for urban conventional highw ays and Rural Main Streets with posted speeds 35 miles per hour or less. ” Mission Road is posted at 40 mph, and our radar speed survey measured an 85th-percentile speed of 45 mph — well above the 35-mph ceiling at which curb extensions are considered appropriate. o Curb extensions are designed primarily to reclaim the sight dist ance occupied by on- street parking and to improve sight lines past parked cars. There is no on-street parking on either Mission Road or Woodward Street at this intersection, so the design premise for a bulb-out is absent.
 A condition of approval must be roughly pr oportional to an impact the development actually creates. At approximate ly 23 pedestrian trips per day (the City’s own estimate), the Project adds a negligible increment to crossing demand at Mission Road and Woodward Street. There is no engineering basis to conclu de that this level of pedestrian activity necessitates a raised curb exte nsion, much less one funded en tirely by the Project. The existing signalized crossing already serves pedestrians, and any incremental senior- pedestrian demand is accommodated through signal timing (see 3.4), not through curb geometry.
 A single-corner bulb-out can increase, rather than reduce, pedestrian exposure. o Extending the curb into the roadway at one corner narrows the effective travel way and brings waiting pedestrians closer to, and more directly in line with, westbound through traffic on Mission Road.
o At an operating speed of 45 mph and with no on-street parking to buffer the corner, this placement does not improve the safety margin for pedestrians and may degrade it.
 Pedestrian crossing accommodation at a si gnalized intersection is governed by the pedestrian clearance (walk / flashing-don’t-walk) interval, not by curb geometry.  Whatever clearance time is appropriate for th e anticipated pedestrian s is established far more reliably, and at negligible cost, by retim ing the pedestrian interval. In short, the

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
senior-pedestrian objective the City cites is met through signal timing; it is not materially advanced by a raised curb extension.
 The Mission Road improvement addresses a pre-existing roadway deficiency, not a Project impact.
o The record reflects that the City’s un derlying objective along Mission Road is to correct a substandard merge / acceleration-lane condition west of Woodward Street — a configuration the City itself has described as inconsistent with current Highway Design Manual requirements — an d to advance its broader complete- streets goals for the corridor.
o These are legitimate City objectives, but they reflect a pre-existing condition of the public street and a longer-term corridor ci rculation program; they are not impacts created by a 115-unit senior community generating 460 daily trips. The cost and responsibility of remedying a pre-existing roadway deficiency cannot be assigned to the Project.
 Based on the City-approved traffic data and the applicable Caltrans design criteria, it is my professional opinion that the raised bulb-out at Mission Road and Woodward Street is not warranted by the Lanikai Senior Apartment Project.

With Mr. Schlaefli’s expert findings in place, we turn to the City Manager’s remaining arguments regarding the alleged inadequacy of the MND.

Access, Emergency Access, and Site Circulation.

In “WHEREAS” Item 4, the Resolution states that the “draft MND does not adequately analyze the environmental, transportation, circulation, and emergency access implications of modifications to the Project that are necessary to satisfy City requirements.” According to the Resolution, these modifications “include changes to emergency access and access locations , site access, public improvements, and potentially number of residential units.” This statement is borderline absurd. As shown above, there are no City requirements, beyond those already satisfied, that the City can impose on the Project. The data simply do not support any claim by City staff that additional mitigation measures are necessary to reduce significant impacts of the Project. Thus, there is no need to analyze th e “environmental, trans portation, circulation, and emergency access implications” of complying with the City’s demands for modifications to the Project. The mere fact that th e City Manager is suggesting that Lanikai, to me et the City’s unfounded desire for the modifications in question, may have to forfeit dwelling units, confirms that staff has lost all sense of the constitutiona l limits of its power. Under well-established law,

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

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City staff cannot impose requirements or constraints on the Project, or take any piece of Lanikai’s property (including dwelling units ), without demonstrating that such a “taking” is roughly proportional to a significant im pact of the Project. ( Dolan v. City of Tigard, 512 U.S. 374, 394- 395 (1994) and Ehrlich v. City of Culver City, 12 Cal.4th 854 (1996).4 The City has made no such demonstration, and the data establish that it will never be able to do so.

Traffic Analysis and Existing Conditions.

Under “WHEREAS” item 5, the Resolution acknowledge s that, because Lanika i’s initial traffic study predates CEQA’s requirement for a Vehicle Miles Traveled (VMT) analysis, Lanikai is entitled to use the LOS traffic metric instead. Th e Resolution then argues that the MND’s traffic studies “utilize information that does not reflect existing conditions or fail to evaluate relevant roadway facilities, acces s conditions, and operational characteri stics affected by Project-related traffic.” The Resolution goes on to claim that the traffic analyses uses outdated information and fails to evaluate Project impacts on certain roadway facilities.

Without specifics – such as the names of the “r oadway facilities” whic h allegedly have been omitted from the MND’s traffic analysis – it is difficult to discern what the City Manager is talking about. Nevertheless, the basic elements of a compliant LOS analysis are well-known, allowing us to test the validity of the City Manager’s position.

As should be clear to anyone familiar with LOS studies, the one performed for the Lanikai project includes all the elements required to determine whether the Project’s traffic will create a significant impact requiring mitigation. For example, the study:
(1) discloses that the Project will generate 460 average daily trips (ADT), of which 23 occur during the AM peak and 32 during the PM peak;
(2) includes turning move ment diagrams showi ng how the Project’s traffic is distributed on a street-by-street and intersection-by-intersection basis; (3) indicates that all affected road segments currently and in the foreseeable future will operate at acceptable levels of service, including Mission Ro ad which is anticipated to continue functioning at LOS A;

4 Note that the “rough proportionality” rule applies even when the mitigation measure or exaction is adopted legislatively and imposed uniformly. (Sheetz v. County of El Dorado, 601 U.S. 267, 270 (2024).)

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

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(4) concludes that the Project’s traffic, when added to ex isting conditions, does not cause any affected road segment, now or in the fu ture, to degrade to a lower LOS or otherwise exceed a significant impact threshold;
(5) discloses that all but two of the affected intersections operate now and in the future at acceptable levels of service (LOS D or better); and
(6) shows that the two intersection whic h are currently deficient – San Marcos Boulevard/Twin Oaks Valley and Mission/Woodward – will remain so into the future, regardless of the Project, and that the Project adds between 0.0 and 0.2 seconds of delay to these intersections, well below the City’s adopted significance threshold of 2.0 seconds of delay.
(See IS/MND, dated April 2026, attached hereto as Exhibit 10; see also Urban Systems Associates’ Traffic Impact Study, dated September 17, 2019 attached hereto as Exhibit 11.) Other data in the record establish that the Project’s proposed driveways at Woodward and Mission can accommodate project-related ingress and egress without causing traffic queues or safety issues.

As Mr. Schlaefli points out in his most recent memorandum, “the Project’s proposed Mission Road driveway operates as a right-in / right-out movement only, which avoids queuing impacts at the Mission/Woodward intersection.” (Schlaefli Memorandum, dated June 24, 2026, attached hereto as Exhibit 4.)
Thus, the evidence in the record confirms that the Project’s traffic impacts create no LOS deficiency or any other significant effect.

The City Manager’s assertion that Lanikai’s traffic information is outdated is likewise easy to dispatch.

First, the data referenced in the MND’s traffic studies were current when they were submitted to City staff in 2019, and CEQA generally does not require that technical reports be redone, updated, or recalibrated during the CEQA review process. (See CEQA Guidelines, § 15125(a) [Environmental baseline is established at the time environmental analysis is commenced].) Such a requirement would force project applicants to constantly chase their tails in a never-ending quest to capture the present before it becomes past.

Second, the Project’s traffic numbers do not change. The ADT and peak hour traffic figures are driven by the number of dwelling units contemplate d, which in this case is 115. So long as that number remains constant over time, the traffic counts stay the same.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
Third, the available data indicate that “ambient” tr affic levels on the affected road segments and intersections have not changed materially since 2019, and that the existing and future conditions assumed in Lanikai’s traffic studies remain valid for purposes of conducting a CEQA-compliant LOS analysis.5
Fourth, as discussed above, in September 2025 , the City approved the Woodward 46 project, located directly across the street from the Lanikai site. That pr oject’s AM and PM peak traffic figures exceed Lanikai’s. Nevertheless, when the Woodward 46 project’s peak traffic numbers were added to the ambient traffic data for bot h 2026 and 2050, the impacts were still negligible, leading the City to conclude that the project wo uld have a less than si gnificant impact on traffic. (See Woodward 46 Draft EIR, pp. 3.8-16—3.8-20, re levant excerpts attached hereto as Exhibit 5.) Accordingly, the City imposed no traffic mitigati on measures on the Woodward 46 applicant. (Îbid.) Staff are clea rly aware of the Woodward 46 traffic study, the data it used, and the conclusions it drew. If staff feel the Lanikai MND traffic analysis needs to be checked against “updated” ambient traffic figures, it has all the information it needs to make that assessment. More importantly, if the Woodward 46 project, which places vehicles into the same intersections as Lanikai’s project but at higher nu mbers, causes no significant tr affic impact, one would expect Lanikai’s impacts to be less than significant as well. In fact, we know this to be true because the Woodward 46 Draft EIR expressly incorporated Lanikai’s 115-unit development in its analysis of cumulative impacts, including traffic. (Woodward 46 Draft EIR, Table 2-4 [Cumulative Projects] Item 7, p. 2-20, attached hereto as Exhibit 5.)
Transportation Effects of Required Project Modifications. “WHEREAS” item 6 states that the draft MND “does not adequately evaluate the transportation effects associated with the Project as modified to comply with City requirements.” It then lists as examples “incomplete analysis of trip distribution, roadway operations, intersection performance, roadway segment impacts, emergency access, and circulation patterns associated with alternative access arrangements.” (Resolution, Item 6, p. 3.)
In many ways, item 6 merely repeats in different phrasing the complaints listed in item 4, and it is invalid for the same reason. The MND is not required to analyze the “transportation effects” created by City’s staff’ s unlawful and baseless demands for the raised curb bulb-out, lane modifications along Mission, or removal of the proposed driveway at Mission. As a lead agency, the City may not withhold release of a CEQA doc ument, be it an MND or EIR, simply because the applicant refuses to study the impacts of improvements that City staff want but have no legal basis to demand.

5 The term “ambient” traffic refers to existing or future background traffic not attributable to the project under review.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
Transportation Impacts to Mission Road/Woodward Street Intersection. “WHEREAS” item 7 states that because Lanikai is seeking to change the site’s zoning from commercial to residential, and is proposing to construct a 115-unit senior housing project, it “will increase the number of pedestri an and bicycle trips, includi ng seniors using the Mission and Woodward intersection.” The Resolution then comp lains that the MND “does not appropriately analyze the Project’s effects on pedestrian signal timing and the corresponding delays introduced to the intersection.”
Apart from the thinly-veiled “ageism” of item 7, which is objectionable on its face, the rest of the statement is silly. We know of no CEQA document approved by the City where staff required the applicant to study the number of pedestrian and bicycle trips the proposed project would generate and then determine whether thos e trips would create a significant impact. Nothing in CEQA, including CEQA Guidelines Appendix G, requires such an evaluation.

Further, Lanikai’s request to rezone the site from commercial to residential (senior-only) does not increase pedestrian, bicycle, or motor vehicle traffic. That statem ent is simply incorrect and the City Manager has provided no ev idence in support of it. Leavi ng that falsehood to one side, however, we know that the Project, by the City’s own assessment, will generate only 23 pedestrian trips per day. That number is so low, it simply cannot be viewed as creating a significant impact, even if all 23 pedestrians were trying to cross Mission at Woodward within the same hour.

More importantly, Justin Schlaefli has provided a detailed analysis of the impacts, such as they are, of resetting the signal timing at the Mission/Woodward intersection to allow seniors to cross the street safely. (See Exhibit 7, attached hereto.) Mr. Schlaefli concludes that simply re-setting the signal timing feature at this intersection will allow pedestrians who push the “WALK” button to extend the crossing time and safely traverse the intersection. (Id.) The green light flow-time for vehicles then reverts back to normal until anot her pedestrian seeks to cross the street. When averaged over a standard day, this adjustment to green light flow is completely absorbed, resulting in no significant impact. (Id.) This should satisfy City staff, though it is absurd that the MND for a much needed housing project is being held up by staff’s concern that 23 pedestrians per day are going to stifle vehicle traffic along Mission Road.6

6 It is worth mentioning that the City’s ATP expressly encourages timing adjustments at certain intersections to provide a safer, less stressful crossing for pedestrians. (ATP , § 1.107.5 [Accommodating Pedestrians], Exhibit 1 hereto.)

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
The bicycle issue is likewise ridiculous. The Lanikai project will be deed restricted to seniors aged 55 years and older. Seniors, especially those over 65, comprise a very small cohort of bicycle riders in the Southern California.7 According to City staff, the Project “will generate 1,679 bicycle trips per year,” which equates to under five (5) bike trips per day. (See Punam Prahalad letter to David Hubbard, dated August 14, 2025, p. 10 of 54, attached hereto as Exhibit 6.) Such a small number of trips will not materially burden the City’s existing bicycle lane network or add substantially to crossings times at intersections. The City, to our knowledge, has never asked a project applicant to measure the number of bicycle trips it will generate, and we know of no CEQA requirement for such an assessment. Thus, this appears to be another attempt by City staff to delay the Project and keep its MND hostage. Regardless, this is not an impact that requires more study or mitigation.

We would also point out that this long-delayed project is listed in the City’s Housing Element and will, among other benefits, assist the City meet its Regional Housing Needs Allocation (RHNA).

The Resolution’s “Findings”
In support of its “WHEREAS” statements, the Re solution includes twelve (12) “findings” that supposedly provide a foundation for the City Manager’s decision to withhold release of Lanikai’s MND. These so-called findings, however, merely repeat the “WHEREAS” statements addressed above and cite no evidence. 8 For this reason, they fail as a matt er of law, as findings must be supported by evidence in the record, and here they are not. (See Pacifica Corp. v. City of Camarillo (1986) 149 Cal.App.3d 168, 179.) Simply put, summary findings without supporting evidence are legally meaningless, as they do not allow the public (or, when necessary, the courts) to discern the analytical path taken by the decision-maker – here, the City Manager and, by this appeal, the City Council. (Pacifica Corp. v. City of Camarillo, supra 149 Cal.App.3d at p. 179, citing Topanga Assoc. for a Scenic Community v. County of Los Angeles (1974) 11 Cal.3d 506, 514-515 [findings “must bridge analytical gap between the raw evidence and ultimate decision or order”].) The only finding that raises a new issue not alr eady addressed in Lanika i’s responses to the Resolution’s “WHEREAS” statements is finding “g”, which claims that the “draft MND does not adequately evaluate pote ntial hazards associated with the Project’s pr oposed access, driveway location, ingress and egress movements, vehicula r turning movements, pedestrian crossings, bicycle movements, bus stop operations, and interactions among vehicles, pedestrians, bicyclists, transit users, and seniors.”
This is quite a list. We know of no CEQA document – Initial Study, MND, or EIR – where the applicant on a residential projec t, especially one as modest as this, was required to study such

7 See, Southern California Area Governments, Analysis of the 2011 Travel Survey for Active Transportation Modes, May 28, 2014.
8 Further, because Lanikai has already addressed these same issues in its responses to the “WHEREAS” statements, there is no reason to repeat that effort here.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
things as impacts on bus stop operations and transit users. CEQA is not a blank check for agency staff members to demand countless studies on a ny topic that flashes across their minds. To the contrary. CEQA admonishes lead agencies to focu s on project impacts that have the potential to significantly affect the environment, and to avoid wasting the applicant’s time and money chasing phantom impacts that have no realistic chance of becoming a significant burden on natural resources or human-built infrastructure. (See San Francisco Baykeeper, Inc. v. State Lands Commission (2015) 242 Cal.App.4 th 202, 222; see also CEQA Guidelines, §§ 15063(c)(3) and 15143 [Lead agencies to focus on significant effects] .) Here, the Lanikai project’s traffic figures clearly show that the Project will cause no significant impact on any road segment or intersection.

The same is true of the Project’s 23 pedestri ans per day. The Project’s proposed driveway at Mission not only ensures compliance with the 2-access rule imposed by the state’s Fire Code, it is a “right turn in” and “right turn out” curb cut, which effectively eliminates any queuing impact at the Mission/Woodward intersection.

Conclusion
The record evidence demonstrates that the Project does not require the raised curb bulb-out or any other so-called improvement demanded by staff. Th e Project can meet all City standards without them and still mitigate what few significant impacts it creates. All of this is spelled out in the draft MND.

Ultimately, Lanikai is appealing to the Council’s good judgment, common sense, and fairness. We don’t believe the Council wishes to squeeze every conceivable concession from a developer/applicant, especially where the proj ect impacts do not legally warrant the exactions proposed by staff. We would like the City to release the MND to the public and move the process forward. This is a senior housing development locat ed a mere two blocks from a senior center, a public library, and a major transi t hub. We don’t think it should be further delayed just because staff thinks 23 pedestrians and 5 bicyclists pe r day require expensive new infrastructure. We suspect the Council agrees.

Rebecca Jones, Mayor
Members of City Council
July 31, 2026

Gatzke Dillon & Ballance LLP

LAWYERS
THEREFORE, Lanikai respectfully requests that the City Council grant Lanikai’s appeal, reject Resolution ADM 26-5226, and direct the City Manager to release the draft the MND to the public, as CEQA requires.

Sincerely,

David P. Hubbard
of
Gatzke Dillon & Ballance LLP

Cc: Lanikai Management
Rick Gittings
City Attorney, Helen Holmes Peak
City Attorney, Punam Prahalad
City Manager, Michelle Bender
City Clerk

EXHIBIT 1

SAN MARCOS
Active Transportation Plan
JUNE 2024

SAN MARCOS ACTIVE TRANSPORTATION PLAN
12 1.107.4 Traffic Calming Strategies
Safe speeds are important to help protect the most vulnerable users of the road: pedestrians and bicyclists.

Speed management can be achieved through educational, enforcement, and engineering traffic calming strategies that encourage motorists to drive at lower speeds. The City’s Neighborhood Traffic Management Policy Guidelines dated August 2023 provide a process for members of the public to request a traffic calming evaluation by the City on roadways that meet specific criteria. The policy draws upon evidence-based research and guidelines in the industry to:
■ Reduce speed or volume of motor vehicles on residential streets; ■ Improve safety for pedestrians, cyclists, and motorists; ■ Reduce the number and severity of accidents;
■ Create a safer and more livable community; and
■ Encourage drivers to use roadways as intended and to be good neighbors.

The policy document also provides a comprehensive toolbox of context-sensitive solutions that can be implemented to address traffic-related concerns including: narrow lanes, turn restriction signs, speed cushions, curb radius reductions, traffic circles, bulb-outs, median barrier diverters.

1.107.5 Accommodating Pedestrians
The pedestrian network is composed of sidewalks, trails, and comfortable mid-block crossings. The overall pedestrian environment can be improved through various pedestrian treatments.

Pedestrian signal enhancements improve an intersection’s signal timing, allowing for a more comfortable pedestrian experience. For example, a l ead pedestrian interval (LPI) is a signal enhancement in which pedestrians receive a green crosswalk signal three to seven seconds before vehicles. This signal timing increases pedestrian visibility and re-emphasizes pedestrians’ right-of-way in a crosswalk.

LEAD PEDESTRIAN INTERVAL

TRAFFIC CIRCLE

TURN RESTRICTION SIGNS
13 SAN MARCOS ACTIVE TRANSPORTATION PLAN
FENCED MEDIAN Fenced medians should be considered if other solutions for deterring mid-block crossings are deemed infeasible. Many times, pedestrians cross at uncontrolled mid-block locations because there is a desire line that should be evaluated. A desire line is the desired path of travel between two land uses. A fenced median can direct pedestrians to a preferred crossing and prevent mid-block crossing activity if needed. This solution is most applicable on high-speed, high-volume roadways adjacent to a destination with large amounts of pedestrian flow at one time, such as a school or entertainment venue.

ENHANCED PEDESTRIAN ENVIRONMENT Treatments such as wider sidewalks and placemaking can create an enhanced pedestrian environment that improves the
character and function of the pedestrian space. Placemaking provides a creative opportunity and use of public right-of-way that incentivizes the pedestrian mode of travel. Placemaking invites artistic, cultural, inspirational, and communal collaboration of a gathering area within an enhanced pedestrian environment.

Landscape buffers are encouraged wherever feasible to provide separation between the roadway and pedestrians.

BULB OUTS Curb extensions, also known as bulb outs, extend the curb line into a roadway at a crossing location. Curb extensions can increase the area available for pedestrians to safely wait before crossing an intersection, reduce crossing distance, and increase pedestrian visibility. Curb extensions can be semi-permanent (striping and delineators) or permanent (sidewalk with curb and gutter). These features are highly encouraged to be implemented where feasible throughout the City dependent on roadway characteristics.

MID-BLOCK CROSSINGS Mid-block crossing enhancements provide for convenient pedestrian crossings with improved visibility and advanced warning at an uncontrolled location. Mid-block crossing designs must be appropriate for the characteristics of the roadway, provide adequate sight and stopping distance, and should consider the following enhancements depending upon the speed and volumes on the roadway:
■ Rectangular Rapid
Flashing Beacons (RRFB)
■ Pedestrian Hybrid
Beacons (PHB)
■ Overhead pedestrian signals
■ High-visibility crosswalks
■ Advanced yield lines
■ LED-enhanced
flashing signs
■ Median refuge islands
A site distance evaluation must be performed prior to installation of a mid-block crossing.

Crossings at controlled intersections (signalized or
stop-controlled) should also consider high-visibility striping and median refuge islands.

EXHIBIT 2
2025 California Fire Code, Title 24, Part 9 with January 2026 Errata

APPENDIX
D

FIRE APPARATUS ACCESS ROADS

SECTION
D106—MULTIPLE-FAMILY RESIDENTIAL DEVELOPMENTS
D106.1
Projects having more than 100 dwelling units.

Multiple-family residential projects having more than 100 dwelling units shall be equipped throughout with two separate and approved fire apparatus access roads.

Exception:

Projects having up to 200 dwelling units shall have not fewer than one approved fire apparatus access road where all buildings, including nonresidential occupancies, are equipped throughout with approved automatic sprinkler systems installed in accordance with
Section 903.3.1.1
or
903.3.1.2
.

D106.2
Projects having more than 200 dwelling units.

Multiple-family residential projects having more than 200 dwelling units shall be provided with two separate and approved fire apparatus access roads regardless of whether they are equipped with an approved automatic sprinkler system.

D106.3
Remoteness.

Where two fire apparatus access roads are required, they shall be placed a distance apart equal to not less than one- half of the length of the maximum overall diagonal dimension of the property or area to be served, measured in a straight line between accesses.
2025 California Fire Code, Title 24, Part 9 with January 2026 Errata
Errata Version: Jan 2026

Copyright © 2026 International Code Council, Inc., or its licensors (ALL RIGHTS RESERVED).

Accessed by Lisa Murphy on 07/30/2026 pursuant to License Agreement with ICC.

No further reproduction or distribution
authorized.

Any Unauthorized reproduction or distribution is a violation of the federal copyright, and subject to civil and criminal penalties thereunder.

PDF from:
http://codes.iccsafe.org/content/CAFC2025P2/appendix-d-fire-apparatus-access- roads#CAFC2025P2_Pt07_AppxD_SecD106
EXHIBIT 3
Mission 316 West Specific Plan
Draft Environmental Impact Report
SCH#2019029038
prepared by
City of San Marcos
Planning Division
1 Civic Center Drive
San Marcos, California 92069
Contact: Joseph Farace, Planning Manager
prepared with the assistance of
Rincon Consultants, Inc.
2215 Faraday Ave, Suite A
Carlsbad, California 92008
August 2019

Environmental Impact Analysis
Transportation

Draft Environmental Impact Report 4.4-9
required intersection stopping distance would be 300 feet per the California Highway Design Manual. A field survey was conducted to determine the available sight and stopping distance at Driveway #1 in accordance with the City of San Marcos guidelines. As shown in Figure 4.4-2, the available sight and stopping distance at Driveway #1 is 490 feet. Thus, the project driveway would meet the required intersection sight and stopping distance standard and not significantly increase hazards.

Driveway #2, located along E. Mission Road, would be right-in/right-out only due to a raised median along E. Mission Road. The Driveway would be a shared driveway with the adjacent development and is located on an inside of a horizontal curve which potentially limits the available sight distance when leaving the project site. A speed survey and sight distance analysis based on the City of San Marcos Minimum Sight Distance Standards concluded that the 85th percentile speed is 46 mph.

Based on the 85th percentile speed of 46 mph, the required sight distance would be 570 feet per the City of San Marcos standards and the required stopping distance would be 370 feet per the California Highway Design Manual (Appendix G). A field survey from LLG Engineers concluded that the available sight distance is 145 feet due to the obstruction from an existing wrought iron fence, as seen in Figure 4.4-3.

A Sight Corridor Easement (Map 16111) was recorded on the neighboring property (with the fence), which provides a clear sight easement to the east of Driveway #2 at the location of the wrought iron fence. The fence exceeded the allowable height limits of the easement and was removed on June 25, 2019, as seen in Figure 4.4-4. According to the sight distance analysis, with the removal of the fence, the available sight distance at Driveway #2 would meet the required sight distance of 596 feet. The adjacent property is required to comply with the Sight Corridor Easement enforced by the City. With the removal of the fence, the sight distance available at Driveway #2 would comply with the City of San Marcos Minimum Sight Distance Standards. Therefore, impacts would be less than significant at both project driveways.

EXHIBIT 4
URBAN SYSTEMS ASSOCIATES, INC.

Traffic Engineering • Transportation Planning
8451 Miralani Drive, Suite A • San Diego, CA 92126 • (619) 818-6465

MEMORANDUM
TO: Greg Scaduto, Lanikai Management Corp.

FROM: Justin P. Schlaefli, PE, TE, PTOE — President, Urban Systems Associates, Inc.

DATE: June 24, 2026
RE: Proposed Mission Road / Woodward Street Curb Extension (“Bulb-Out”) Requirement
Lanikai Senior Apartment Project, San Marcos, CA (City File SP17-0004) USAI Job No. 001718
DRAFT FOR CLIENT REVIEW — NOT FOR DISTRIBUTION

1. Purpose
At your request, this memorandum sets forth the traffic-engineering basis for our opinion that the raised curb extension (“bulb-out”) the City of San Marcos is requiring at the northwest corner of Mission Road and Woodward Street is not warranted by the Lanikai Senior Apartment Project (the “Project”), is inconsistent with the applicable Caltrans design criteria, and should not be imposed on the Project as a condition of approval. The conditions the Project does generate can be addressed through striping, delineation, and signal-timing measures already contemplated for the site — without raised curb construction, right-of-way reallocation, or relocation of the existing traffic signal system.

This memorandum is based on the City-approved Traffic Impact Analysis prepared by Urban Systems Associates, Inc. (USAI) for the Project, our prior bike-lane and sight-distance analyses, field-measured speed data, and the Caltrans Highway Design Manual (HDM), Chapter 303.4 (Curb Extensions / Bulbouts). Certain findings that depend on the final signal-modification and lane-alignment plans are noted as such and will be confirmed once those plans are received.

2. Project and Traffic Summary
The Project is a 115-unit, age-restricted senior residential community on approximately 3.9 acres at the northwest corner of Woodward Street and Mission Road. Site access is provided by two driveways — one on Woodward Street (full access) and one on Mission Road. Because Mission Road carries a raised median at this location, the Mission Road driveway operates as a right-in / right-out movement only.

Per the City-approved Traffic Impact Analysis, the Project generates the following trips using the SANDAG retirement-community rate of 4 trips per unit:

Measure Daily (ADT) AM Peak Hr PM Peak Hr
Total Project trips 460 23 32
Measure Daily (ADT) AM Peak Hr PM Peak Hr
In / Out split — 9 in / 14 out 19 in / 13 out
Outbound trips to Mission Rd.
driveway (approx.)
— ~7 ~6
The outbound peak-hour volume (14 vehicles in the AM, 13 in the PM) is split between the two site driveways. Even assigning that volume conservatively, the Mission Road driveway is expected to discharge on the order of six to seven vehicles per peak hour — roughly one vehicle every nine to ten minutes. By the City’s own pedestrian estimate, the Project generates approximately 23 pedestrian trips per day. These are the volumes against which the requested public-street improvements must be measured.

3. Engineering Findings

3.1 The bulb-out does not satisfy the Caltrans criteria for curb extensions.

Caltrans Highway Design Manual Chapter 303.4 provides that curb extensions (bulbouts) “are most appropriate for urban conventional highways and Rural Main Streets with posted speeds 35 miles per hour or less,” and that “when used, bulbouts should be placed at all corners of an intersection.” The proposed treatment is inconsistent with this guidance on three independent grounds:
• Operating speed exceeds the threshold. Mission Road is posted at 40 mph, and our radar speed survey measured an 85th-percentile speed of 45 mph — well above the 35- mph ceiling at which curb extensions are considered appropriate. • No on-street parking is present. Curb extensions are designed primarily to reclaim the shy distance occupied by on-street parking and to improve sight lines past parked cars.

There is no on-street parking on either Mission Road or Woodward Street at this intersection, so the design premise for a bulb-out is absent. • Single-corner application. The City is requiring a raised bulb-out at only one of the four corners. The Caltrans guidance calls for placement at all corners of an intersection; an isolated single-corner bulb-out produces an asymmetric, non-standard geometry.

3.2 The Project’s pedestrian activity does not establish a nexus for a 100% applicant- funded bulb-out.

A condition of approval must be roughly proportional to an impact the development actually creates. At approximately 23 pedestrian trips per day (the City’s own estimate), the Project adds a negligible increment to crossing demand at Mission Road and Woodward Street. There is no engineering basis to conclude that this level of pedestrian activity necessitates a raised curb extension, much less one funded entirely by the Project. The existing signalized crossing already serves pedestrians, and any incremental senior-pedestrian demand is accommodated through signal timing (see 3.4), not through curb geometry.

3.3 A single-corner bulb-out can increase, rather than reduce, pedestrian exposure.

Extending the curb into the roadway at one corner narrows the effective travel way and brings waiting pedestrians closer to, and more directly in line with, westbound through traffic on Mission Road. At an operating speed of 45 mph and with no on-street parking to buffer the corner, this placement does not improve the safety margin for pedestrians and may degrade it.

A curb extension that is geometrically non-standard for its setting should not be represented as a pedestrian-safety improvement without a supporting analysis, which the City has not provided.

3.4 Pedestrian crossing time is governed by signal timing, not by curb geometry.

Pedestrian crossing accommodation at a signalized intersection is governed by the pedestrian clearance (walk / flashing-don’t-walk) interval, not by curb geometry. The California MUTCD bases the clearance interval on the crossing distance and a standard walking speed of 3.5 feet per second, and it directs that a slower speed be used where slower pedestrians use the crossing — specifically 2.8 feet per second where older or disabled pedestrians routinely use the crosswalk. Accommodating slower (including senior) pedestrians is therefore a matter of setting the clearance interval to the appropriate walking speed — a timing adjustment available at the existing signal that requires no physical construction.

The existing crosswalk across Mission Road is approximately 118 feet long and is reported to provide about 31 seconds to cross, with visual and audible indications. The proposed bulb-out would shorten the crossing by only 10 to 12 feet — roughly a 9 percent reduction — which, even at the conservative 2.8 ft/s older-pedestrian walking speed, saves only about four seconds of clearance time. Whatever clearance time is appropriate for the anticipated pedestrians is established far more reliably, and at negligible cost, by retiming the pedestrian interval. In short, the senior-pedestrian objective the City cites is met through signal timing; it is not materially advanced by a raised curb extension.

3.5 Project traffic at the Mission Road driveway is insignificant and does not cause queuing.

The concern that vehicles exiting the Project onto westbound Mission Road would create queuing at the Mission Road / Woodward Street intersection is not supported by the data. As noted in Section 2, the Mission Road driveway is a right-out-only movement discharging on the order of six to seven vehicles in the peak hour — approximately one vehicle every nine to ten minutes. A right-turn departure of this magnitude merges into available gaps in the traffic stream and does not generate a standing queue, nor does it measurably affect operations or queue lengths at the adjacent signal. There is no traffic-engineering justification for tying a raised curb extension to the Project’s driveway volume.

It also bears noting that the Mission Road driveway is not an applicant preference that could simply be eliminated: removing it would leave the Project with a single point of access, contrary to the requirement for two points of ingress and egress for residential developments of 50 or more units. The Mission Road access is a code-driven necessity, and the modest right-out volume it carries does not warrant the requested improvement.

3.6 The Mission Road improvement addresses a pre-existing roadway deficiency, not a Project impact.

The record reflects that the City’s underlying objective along Mission Road is to correct a substandard merge / acceleration-lane condition west of Woodward Street — a configuration the City itself has described as inconsistent with current Highway Design Manual requirements — and to advance its broader complete-streets goals for the corridor. These are legitimate City objectives, but they reflect a pre-existing condition of the public street and a longer-term corridor circulation program; they are not impacts created by a 115-unit senior community generating 460 daily trips. The cost and responsibility of remedying a pre-existing roadway deficiency should not be assigned to the Project.

Consistent with this, our June 2023 bike-lane analysis concluded that the existing third (merge) westbound lane on Mission Road west of Woodward is not needed for capacity and is operationally a trap/merge lane. Eliminating that lane and restriping the curb-side area as a buffered bike lane — which fits within the existing curb line — resolves the substandard-merge condition the City has identified, without raised curb construction or right-of-way reallocation.

4. Recommended Approach
The legitimate pedestrian and corridor objectives at this location can be met without the raised bulb-out:

1. Provide curb extension by striping and delineation at the northwest corner (and, as offered, at the other corners), as expressly permitted under the City’s Active Transportation Plan, in lieu of a raised curb.

2. Restripe Mission Road west of Woodward to eliminate the substandard merge lane and establish a buffered bike lane within the existing curb line, consistent with our 2023 analysis.

3. Retime the pedestrian clearance interval at the existing signal to the appropriate walking speed (including the 2.8 ft/s value for older pedestrians, where applicable), rather than relying on a 10–12-foot reduction in crossing length.

4. Limit any traffic-signal work to the minimum required by the City to meet current standards (e.g., replacement of the northwest-corner pole and addition of free-standing pedestrian push buttons and ADA ramps), pending confirmation from the final signal- modification and lane-alignment plans.

5. Conclusion
Based on the City-approved traffic data and the applicable Caltrans design criteria, it is my professional opinion that the raised bulb-out at Mission Road and Woodward Street is not warranted by the Lanikai Senior Apartment Project. The treatment does not satisfy the Caltrans Highway Design Manual criteria for curb extensions (operating speed above 35 mph, no on- street parking, single-corner application); the Project’s pedestrian and vehicular volumes are too small to establish the necessary nexus or proportionality; the proposed geometry does not demonstrably improve, and may impair, pedestrian safety; and the City’s underlying goal of correcting a substandard Mission Road merge reflects a pre-existing roadway condition rather than a Project impact. The Project’s genuine obligations can be satisfied through striping, delineation, signal retiming, and the buffered bike-lane reconfiguration already proposed.

Please let me know if you would like this memorandum tailored for transmittal to the City, the Planning Commission, or the City Council, or expanded with exhibits (the lane-alignment exhibit, the conceptual bulb-out, and the Caltrans HDM excerpt). Certain findings will be confirmed upon receipt of the final signal-modification and lane-alignment plans.

Respectfully submitted,
Justin P. Schlaefli, PE, TE, PTOE
President, Urban Systems Associates, Inc.

EXHIBIT 5
Woodward 46 Specific Plan Project
Draft Environmental Impact Report
SCH No. 2023080449
SP22-0005/S
P22-0006/GPA22-0004/MFSD 22-0005/TSM22-0004/CUP22--0005 Prepared
for:

City of San M
arcos
Planning Division
1 Civic Center Drive
San Marcos, CA 92069
Contact: Scott Nightingale, Principal Planner

Prepared
by:

Sophia Mitchell & Associates
P.O. Box 1700
Gualala, CA 95445
Contact: Sophia Habl Mitchell
March 2025
■

2.0 Project Description, Location, and Environmental Setting Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 2-20
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

3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-16
Level of Service Standards
The City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards outlined in the General Plan Mobility Element. If the addition of the traffic generated from a proposed project results in any one of the followin g, improvements should be identified to increase performance to acceptable or pre-project conditions under each scenario:
• Triggers an intersection operating at acceptable LOS to operate at unacceptable LOS (LOS E or F) and increases the delay by more than 2.0 seconds. • Increases the delay for a study intersection that is already operating at unacceptable LOS (LOS E or F) by more than 2.0 seconds.
• Triggers a roadway segment operating at acceptable LOS (LOS A, B, C, D) to operate at unacceptable LOS and increases the volume/capacity (V/C) ratio by more than 0.02. • Increases the V/C ratio for a study roadway segment that is already operating at unacceptable LOS (LOS E or F) by more than 0.02.

Project Trip Generation
To determine the traffic generation of the proposed project, the April 2002 SANDAG (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002) r ates were applied to the proposed project. The “Condominium” trip rate was used to estimate the project residential trip generation.

Table 3.8 -7 presents the trip generation rates and forecasted project -generated trips for weekday conditions. As shown in Table 3.8-7, the project would generate approximately 368 average daily trips (ADT), including 29 AM peak hour trips and 37 PM peak hour trips. The project traffic was distributed based on the site location, access to SR-78, existing traffic patterns in the area and anticipated traffic routes to and from the site. The proposed project’s regional distributions assumes 75% of trips oriented to/from the south, and local distributions assumes 10% oriented to/from the west, 10% to/from the east and 5% to/from the north.

Table 3.8-7. Project Trip Generation
Land Use Quantity
Daily Trip
Ends (ADT)
AM Peak Hour PM Peak Hour
% of
ADT
In:Out
Split
Volume % of
ADT
In:Out
Split
Volume
Rate ADT In Out Total In Out Total
Condominium 46 DU 8/DU 368 8% 20:80 6 23 29 10% 70:30 26 11 37 Source: LLG2023a.

Note: Trip generation rates were obtained from the (Not so) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002 by SANDAG
DU = Dwelling Unit, ADT = Average Daily Traffic
Construction Trip Generation
Grading of the project site would consist of approximately 41,989 cubic yards (CY) of cut material and 50,270 CY of fill material requiring an export of approximately 8,281 CY of material . If suitable, the excess material would be used as wall backfill and the site would balance. If it is not suitable, it would

3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-17
be exported from the site. To be conservative, the environmental analysis assumes the materials would be exported. Assuming 15 cy truck trips, that would equate to 553 trips. These trips would be spread over approximately 23 working days for 24 trips per day associated with export. The grading phase of the project is not expected to generate trips above the trips associated with the 46-unit duplex residential development. Therefore, the grading phase would not result in any traffic related significant impacts or substantial effects above those associated with the project. No traffic related impacts are identified during construction.

Local Transportation Analysis of Near-Term (Year 2026) Conditions The following section presents the analysis of study area intersections and street segments under Near-Term Year 2026 Base conditions and Near-Term Year 2026 Base + Project conditions.

Near-Term Year 2026 Intersection Analysis
Table 3.8-8 summarizes the intersection operations through the study area for the Near -Term Year 2026 Base Condition and Base + Project conditions.

Table 3.8-8. Near-Term Year 2026 - Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour
Year 2026
Base
Conditions
Year 2026
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.

Delay
(sec.)(1)
LOS(2)
Avg.

Delay
(sec.)(1)
LOS(2)
1 Woodward
Street/Project
Driveway(6)
TWSC(5) AM -- -- 11.5 B -- Yes
PM -- -- 12.8 B -- Yes
2 Mission Road/Pico
Avenue
Signal AM 36.4 D 36.6 D 0.2 Yes
PM 29.7 C 29.9 C 0.2 Yes
3 Mission
Road/Woodward
Street (San Marcos
Boulevard)
Signal AM 81.9 F 82.0 F 0.1 Yes
PM 71.3 E 71.4 E 0.1 Yes
4 San Marcos
Boulevard/Twin Oaks
Valley Road
Signal AM 51.9 D 53.5 D 1.6 Yes
PM 48.2 D 48.5 D 0.3 Yes
5 San Marcos
Boulevard/Rancheros
Drive
Signal AM 29.4 C 29.6 C 0.2 Yes
PM 32.0 C 32.1 C 0.1 Yes
Source: LLG 2023a.

Notes: (1) Average Delay expressed in seconds per vehicle (2) LOS = Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) TWSC = Two-way stop controlled intersection.
(6) Intersection does not exist under Year 2026 Base condition

3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-18
As shown in Table 3.8-8, in the Near-Term Year 2026 Base condition, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of:
• Mission Road/Woodward (San Marcos Boulevard) – LOS F (AM Peak Hour) and LOS E (PM Peak Hour)
With the addition of project traffic (Base + Project condition) all intersections would continue to operate acceptably at LOS D with the exception of the Mission Road/Woodward (San Marcos Boulevard) intersection. The project’s increase in delay at that int ersection would be 0.1 seconds, which is less than the 2 seconds average delay. As part of the project design features (see Table 2-2) the applicant would construct an access point that provides adequate driveway sight distance and construct a minimum 50-foot southbound left-turn pocket on Woodward Street for left -turn access to the project site outside of the southbound through lane.

Therefore, none of the study intersections would degrade to an unacceptable level with implementation of the proposed project and no improvements would be required.

Near-Term (Year 2026) Segment Analysis
Table 3.8-9 summarizes the segment operations throughout the study area for the Near-Term Year 2026 Base and Near-Term Year 2026 Base + Project conditions. As shown in Table 3.8-9 , all of the study area segments are calculated to operate acceptably at LOS B or better with or without the project.

Table 3.8-9. Near-Term Year 2026 Roadway Segment Operations Without and With Project Roadway Segment
Capacity
(LOS
E)(1)
Year 2026 Base
Condition
Year 2065
Base + Project
Condition Δ(4)
Consistent
with City
LOS
Standards?
(5)
Daily
Volume V/C(2) LOS(3) Daily
Volume V/C(2) LOS(3)
Mission
Road
Pico
Avenue to
Woodward
Street
40,000 11,910 0.298 A 11,947 0.299 A 0.001 Yes
Woodward
Street to
Mission
Villas
Road
60,000 20,690 0.345 A 20,727 0.345 A 0.000 Yes
San
Marcos
Boulevard
Rancheros
Drive to
Mission
Road
40,000 15,980 0.400 B 16,256 0.406 B 0.006 Yes
Source: LLG 2023a.

Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Volume to Capacity
(3) LOS = Level of Service
(4) Δ denotes a project-induced increase in the Volume to Capacity (V/C) ratio. (5) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element.

3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-19
Local Transportation Analysis of Horizon Year 2050 Conditions Year 2050 Network Conditions
The Long-Term (Horizon Year 2050) street network in the SANDAG Series 14 forecast model includes the roadways built to their City Mobility Element Classification, including the planned widening of San Marcos Boulevard between Twin Oaks Valley Road and Miss ion Road to 6 -lane Major Arterial standards. For the purposes of the LTA, the network addition is assumed in the long -term traffic volumes forecast but no changes to the study area roadway geometry or intersection control were assumed.

Horizon Year 2050 Intersection Analysis
Table 3.8-10 summarizes the Year 2050 Without and With Project peak hour intersection analysis. As shown in Table 3.8–10, without the project, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of the following intersections:
• Mission Road/Woodward Street (San Marcos Boulevard) – LOS F (AM and PM Peak Hour) • San Marcos Boulevard/Twin Oaks Valley Road - LOS E (AM and PM Peak Hour) With the addition of project traffic all of the study area intersections would continue to operate at LOS D or better with the exception of Mission Road/Woodward Street (San Marcos Boulevard) which would continue to operate at LOS F in the AM and PM Peak hour and San Marcos Boulevard/Twin Oaks Valley Road, which would continue to operate at LOS E in the AM and PM Peak Hour. As shown in Table 3.8- 10, the project’s increase in delay at these intersection would range from 0.1 seconds to 1.1 seconds which is less than the 2 seconds average delay. Therefore, none of the study intersections analyzed in the Horizon Year 2050 scenario would degrade to an unacceptable level with implementation of the proposed project and no improvements would be required.

Table 3.8-10. Horizon Year (2050) Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour
Year 2050
Base
Conditions
Year 2050
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.

Delay
(sec.)(1)
LOS(2)
Avg.

Delay
(sec.)(1)
LOS(2)
1 Woodward
Street/Project
Driveway
TWSC(5) AM -- -- 11.7 B -- Yes
PM -- -- 13.1 B -- Yes
2 Mission Road/Pico
Avenue
Signal AM 49.3 D 49.4 D 0.1 Yes
PM 35.3 D 35.5 D 0.2 Yes
3 Mission
Road/Woodward
Street (San Marcos
Boulevard)
Signal AM 101.3 F 101.5 F 0.2 Yes
PM 96.3 F 96.4 F 0.1 Yes
4 Signal AM 71.4 E 72.5 E 1.1 Yes

3.8 Land Use and Planning
Woodward 46 Specific Plan Draft EIR March 2025
City of San Marcos Page 3.8-20
# Intersection Control
Type
Peak
Hour
Year 2050
Base
Conditions
Year 2050
Base + Project
Conditions Δ(3)
Consistent
with City LOS
Standards?(4) Avg.

Delay
(sec.)(1)
LOS(2)
Avg.

Delay
(sec.)(1)
LOS(2)
San Marcos
Boulevard/Twin Oaks
Valley Road
PM 58.2 E 58.5 E 0.6 Yes
5 San Marcos
Boulevard/Rancheros
Drive
Signal AM 36.6 D 37.1 D 0.5 Yes
PM 39.0 D 39.4 D 0.4 Yes
Source: LLG 2023a.

Notes: (1) Average Delay expressed in seconds per vehicle (2) LOS = Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) TWSC = Two-way stop controlled intersection.

Horizon Year 2050 Segment Operations
Table 3.8 -11 summarizes the segment operations throughout the study area for the Year 2050 Without and With Project daily street segment operations. As shown in Table 3.8 -11, all of the study area segments are calculated to operate acceptably at LOS B both with and without the project.

Table 3.8-11. Horizon Year 2050 Roadway Segment Operations Without and With Project Roadway Segment
Capacity
(LOS
E)(1)
Year 2026 Base
Condition
Year 2065
Base + Project
Condition Δ(4)
Consistent
with City
LOS
Standards?
(5)
Daily
Volume V/C(2) LOS(3) Daily
Volume V/C(2) LOS(3)
Mission
Road
Pico
Avenue to
Woodward
Street
40,000 12,310 0.308 A 12,347 0.309 A 0.001 Yes
Woodward
Street to
Mission
Villas
Road
60,000 21,790 0.363 A 21,287 0.346 A 0.000 Yes
San
Marcos
Boulevard
Rancheros
Drive to
Mission
Road
40,000 17,380 0.435 B 17,656 0.441 B 0.006 Yes
Source: LLG 2023a.

Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Volume to Capacity
(3) LOS = Level of Service

EXHIBIT 6

LOUNSBERY FERGUSON

ALTONA & PEAK LLP
960 Canterbury Place, Suite 300
Escondido, California 92025-3870
JOHN W. WITT
1932-2018
Telephone (760) 743-1201
Facsimile (760) 743-9926
www.LFAP.com

PUNAM P. PRAHALAD Direct: (760) 743-1226, ext. 137
PARTNER Email: [email protected]

August 14, 2025

By Mail and Email

David Hubbard
Gatzke Dillon & Balance LLP
2762 Gateway Road
Carlsbad, California 92009

RE: SP 17-0004/GPA 17-003/MFSDP 19-0001 – Development of 115 age-restricted apartment units; 8th Review/2nd MND Review; APN 220-063-04

Dear Mr. Hubbard:

The City received your letter dated July 24, 2025 to Mr. Chris Garcia in the City’s Planning Department regarding his letter dated June 26, 2025 summarizing the City’s 2 nd review of the
Project’s proposed MND and providing staff’s comments on the various components of Lanikai’s application.

Your letter identifies four main items of concern of the outstanding items identified for resolution/correction by City staff. Specifically, you refer to (1) a project-specific VMT analysis, (2) the class IV bike lane the City wants Lanikai to include in the project’s site plan, (3) the bulb- out at Woodward and Mission, and (4) elimination of the left-out access from the project onto Woodward.

With respect to the first issue, the City does not dispute that you have informed the City that the project is not subject to the VMT requirement. The City believes that completing the minor edits to the VMT memo already provided in the 8th review to the City would be far less resource intensive than conducting an entirely new transportation analysis using the LOS metric since the transportation analysis submitted in 2019 is not current, having been prepared 6 years ago, and would need to be updated. The VMT memo demonstrated that the project is exempt from a VMT analysis and only requires a minor revision for City staff to resolve the outstanding comment on the VMT memo.

David Hubbard
August 14, 2025

LOUNSBERY FERGUSON ALTONA & PEAK LLP

As to the requirement to install a class IV bike lane, staff does believe there is a nexus and that this requirement is not an unlawful exaction under the Fifth Amendment and applicable legal precedent, including the recent Court of Appeal determination in Sheetz v. County of El Dorado on remand from the U.S. Supreme Court as detailed in the attached memorandum.

With respect to item (3), the bulb out is required to address the impact of the Mission Road driveway and the development of a senior residential development on the City’s infrastructure.

The nexus for this requirement is also detailed in the attached memorandum.

With regard to item (4), based upon the traffic studies and traffic movements the City has reviewed, the City’s position is that the Woodward entrance and exit must be right turn in/right turn out only and the left-out access from the project onto Woodward should not be permitted.

This is further discussed in the attached memorandum.

We understand that the applicant does not wish to continue debating these four issues. However, we believe the City has provided sufficient basis for requirements it has provided, which basis is consistent with the analysis in the recent determination in the Sheetz case.

In addition to these four issues you identified, there are still a significant number of issues to be addressed before the Project is ready to be presented to the Planning Commission. These outstanding issues are:

o Potential impacts on habitat and wildlife agency consensus on wetland buffer; o Potential impacts on regulatory floodway, draft CLOMR, & revision of the flood analysis;
o Outstanding comments on VMT analysis;
o TDM plan needs to be revised;
o VWD correspondence acknowledging VWD water & study from 2019 does not require an update;
o Updated Fiscal & Economic analysis (existing is out of date); o Updated LOS analysis (existing is out of date);
o Draft MND to be updated with revised Biology Report with bird survey, LOS, VMT, & updated Fiscal & Economic analysis.

If after reviewing the attached memorandum, it is Lanikai’s intent to move forward with the current site plan, please advise whether Lanikai intends to (1) address all other outstanding items and (2) complete CEQA review before presenting the project to Planning Commission. If so, Lanikai should be made aware that it would be moving forward with the risk of a recommendation of denial from staff.

David Hubbard
August 14, 2025

LOUNSBERY FERGUSON ALTONA & PEAK LLP

Additionally, staff is concerned that if Lanikai determines it will move forward without addressing the listed outstanding items and/or completing CEQA review, given the condition precedent for approval of CEQA documentation prior to or concurrent with approval of a project, the City’s ability to approve the project would be negatively affected.

Sincerely,

Punam P. Prahalad

LOUNSBERY FERGUSON ALTONA & PEAK, LLP

Enclosure as noted

cc: Michelle Bender, City Manager
Isaac Etchamendy, Development Services Director and City Engineer Joe Farace, Director of Planning
C hris Garcia, Senior Planner

LANIKAI DEVELOPMENT:

EXACTION ANALYSIS OF RIGHT OF WAY DEDICATION AND

FRONTAGE IMPROVEMENTS

INTRODUCTION
Lanikai Partners LLC (Lanikai) proposes to construct a senior housing development at the northwest quadrant of the intersection of Mission Avenue with Woodward Drive (the Development) (Attachment 1). Analysis of anticipated traffic counts and other aspects of the environmental review conducted to date have identified that the Development will create impacts to the City’s infrastructure, particularly the transportation network. Accordingly, the City has required the Development to dedicate public right-of-way to support transportation improvements and to construct frontage improvements.

The applicant disputes the requirement to dedicate the public right-of-way and to construct the frontage improvements, citing Nollan v. California Coastal Commission (1987) 483 U.S. 825, Dolan v. City of Tigard (1994) 512 U.S. 374, and Sheetz v. County of El Dorado (2024) 601 U.S. 267 . This memorandum documents the evaluation of those concerns and demonstrates the nexus and the rough proportionality between the imposition of right -of- way dedication and frontage improvements on the one hand and the Development’s impact on the City’s facilities on the other, as required under current law.

METHODOLOGY
The City’s evaluation of whether the exaction of right -of-way and associated frontage improvements for the Development constitutes a taking was conducted using a multi -step methodology grounded in constitutional principles, California statutory requirements, and relevant case law.

The methodology is as follows:

1. Establish the legal framework by identifying the applicable legal standards for land use exactions.

2. Document the development characteristics for use in determining project impacts.

3. Identify and quantify the development impacts to City infrastructure based on project- and site-specific characteristics. These impacts occur at both a citywide and local level. Citywide infrastructure impacts are quantified on both a physical (i.e., 100 linear feet of travel lane) and a financial basis.

4. Identify the r equired exactions and project requirements, including right -of-way dedication, frontage improvements, public facilities fees , and project impact mitigations. Assess the General Plan consistency implications of the required exactions.

5. Evaluate the essential nexus between the project impacts and the required exactions.

6. Identify and quantify the burden on the development imposed by the required exactions.

7. Evaluate the rough proportionality by comparing the financial and physical scope of the required exactions to the quantified impact of the project on public facilities.

8. Assess the economic viability of the project with the required exactions by evaluating whether the required exactions would deny the developer all economically viable use of the property.

9. Evaluate compliance under the legal framework established in Step 1.

1. LEGAL FRAMEWORK
The City’s authority to impose dedications and exactions is constrained by the U.S.

Constitution and California law. The governing principles are:
• Nollan (1987): There must be an essential nexus between a legitimate public purpose and the condition imposed.
• Dolan (1994): There must be rough proportionality between the exaction and the development’s impact.
• Sheetz (2024) 601 U.S. 267, Sheetz (2025) 2025 WL 2116363: These requirements apply even to exactions imposed through legislative frameworks, such as development impact fees or general plan policies.
• Mitigation Fee Act (Gov. Code §66000 et seq.): The City must make five findings: (1) purpose of the fee; (2) use of fee; (3) benefit relationship; (4) burden relationship; and (5) proportionality. This methodology was found to be consistent with the essential nexus and rough proportionality tests in the 2025 Sheetz v. County of El Dorado decision by the 3
rd District Court of Appeals on remand from the Supreme Court. This is further discussed in Attachment 7.

2. DEVELOPMENT CHARACTERISTICS
Lanikai is requesting approval of a General Plan Amendment (GPA17-0003), Specific Plan Amendment (SP17-0004), and Multi-Family Site Development Plan (MFSDP19-0001) to construct an age 55+ residential development and associated infrastructure improvements.

The Development proposes to construct 115 units over four floors, with a total building size of approximately 106,300 square feet and 50 feet in height. The Development includes a mix of residential unit sizes including studio, one -bedroom, and two -bedroom units. Interior community areas include a library/TV room, fitness room, and a great room with kitchen.

Exterior spaces include private balconies or patios for each unit and a community patio area with lap pool. A site layout is provided in Attachment 2.

A rate of 3.1 persons per dwelling unit is typically assumed for population growth determination. However, given the age-restricted nature of the proposed 115-unit project, up to 2 persons per unit are assumed. Therefore, the Development would potentially add an estimated 230 people to the area, excluding employees.

The 174,676 square foot project site (Assessor’s Parcel 220 -063-04-00) is currently vacant land itself and bounded by vacant land to the north, Woodward Drive to the East, Mission Road to the South, and San Marcos Creek to the West. The surrounding neighborhood includes residential development, light rail transit, a public library, a community center, the Senior Activity Center, regional bike facilities, Richmar Park (0.25 miles west), Hollandia Park (0.8 miles east), and City Hall; see Attachment 3. The site is relatively flat.

The Development proposes to include two separate access points, one on Woodward Street and a second on Mission Road. The Development seeks to have a right-turn-in, left-turn-out entry along Mission Road, which is not consistent with the City’s Urban Street Design Criteria (USDG). The City has offered that it could contemplate allowing the second (Mission Road) driveway access point if the impacts of the new driveway are properly mitigated.

3. DEVELOPMENT IMPACTS
The Development proposes 230 new residents, adding drivers, pedestrians, transit users, and cyclists to Mission Road, Woodward Street, and the City transportation network in general. The traffic study indicates the Development will generate 167,900 Estimated Annual Trips (EAT). In addition, the introduction of senior residents , proposed driveway locations, and the particular site conditions have specific impacts for both citywide and local infrastructure needs.

The impacts of the D evelopment on the transportation network are not confined to the segment of street directly adjacent to the site. By definition, transportation infrastructure exists to move people and goods across a connected network; it is by definition a system. A trip generated by the D evelopment will not start and end at the project frontage; it will traverse multiple roadway segments and active transportation facilities citywide . Some of these facilities exist, and others do not.

Consequently, when new residents of the D evelopment travel throughout the community, they will impose incremental burdens on the entire citywide transportation system of roadways, pedestrian walkways, and bicycle facilities , extending well beyond the Development’s immediate frontage. This principle is widely recognized in transportation planning and impact analyses, where facility needs are expressed in terms of miles traveled rather than just along-site frontage segments.

The constitutional “rough proportionality” standard established in Dolan v. City of Tigard (512 U.S. 374, 1994) requires that the extent of an exaction have a reasonable relationship to the magnitude of the project’s impacts. ( Sheetz 2025 WL 2116363 *17. ) The citywide network serves the entire trip, and all facilities along the trip are needed for that travel to be possible. Therefore, it is proportionate to require the D evelopment to construct improvements along its own frontage ; this is a fair and measurable share of the facilities it will rely upon. This is especially true because the frontage is part of a designated facility in the City’s General Plan or Active Transportation Plan, ensuring network continuity and safety.

Even where some or all roadway , pedestrian, or bicycle segments already exist along the frontage, those facilities may require widening, accessibility enhancements, or the addition of missing multimodal elements such as bike lanes, transit enhancements, or sidewalks to complete the Citywide transportation network . In engineering terms, transportation infrastructure is not “present or absent ;” it has varying capacity, safety performance, and compliance with standards. A substandard bike lane, for example, may not safely accommodate increased bicycle volumes, especially where vulnerable users (such as seniors) are expected. The additional demand from the Development justifies upgrading that segment to meet the City’s ultimate network as required in the General Plan and Active Transportation Plan. In the absence of these improvements, the new residents’ ability to safely and efficiently complete their trips would be compromised, and the City’s network - level goals such as congestion mitigation and safety for vulnerable road users, and regional goals such as reduction of vehicle miles traveled and greenhouse ga ses would be undermined.

The transportation network is a system-based public facility, and impacts from the proposed Development will occur citywide, not just at the site frontage. Requiring the Development to construct improvements along its frontage is an equitable and legally defensible method of ensuring that each new development project contributes a proportionate share toward the network it depends on. This approach satisfies the “essential nexus” and “rough proportionality” standards under Nollan , Dolan, and Sheetz , and complies with the individualized determination requirement of both federal and California law , as discussed below.
3A. Roadway, Pedestrian, and Bicycle Facility Impacts from the Development Dolan requires “some sort of individualized determination” that the nature and extent of the exaction relate to the development’s projected impacts. In this case, trip generation and citywide roadway, pedestrian, and bicycle demand analyses quantify the incremental facility demand attributable to the project. Those impacts are far greater than the value of the frontage improvements required, satisfying the “extent” prong of Dolan.

The Supreme Court in Sheetz v. County of El Dorado (601 U.S. 267, 2024) confirmed that the Nollan/Dolan standards apply equally to legislatively adopted conditions, such as general plan requirements or fee programs. Thus, even when frontage improvements are required pursuant to citywide policy such as the General Plan or the Active Transportation Plan, the City’s approach of matching each development’s responsibility to its own frontage , rather than a greater segment, is a measured and constitutionally sound allocation of the burden.

For purposes of this analysis, the City considered that the predominant impact of the Development to City facilities would be to the transportation network, primarily to pedestrian, roadway, and bicycle infrastructure citywide. The assessment below quantifies the physical improvements that must be constructed citywide to support the proposed Development and attributes financial costs to the same.

Roadway Infrastructure
The City’s adopted Development Impact Fee Nexus Study 1 indicates that , “ the need for transportation facilities is based on the trip demand placed on the system by development… Vehicle trip generation rates are a reasonable measure of demand on the citywide system of street improvements across all modes because alternate modes (transit, bicycle, pedestrian) often substitute for vehicle trips. ” The Development will generate 167,900 Estimated Annual Trips (EAT) and will therefore place an increased demand on the citywide transportation network.

SANDAG current (2016) data indicates that the project location, Census Tract 200.22, will generate 19.3 vehicle miles traveled per capita per day . The Development population

1 https://www.san-marcos.net/home/showpublisheddocument/28857/638639102721170000 estimate is 230 residents, neglecting employees . Therefore, Lanikai proposes an impact of 1,162,235 annual vehicle miles traveled (VMT) to City infrastructure, each trip requiring an average of 9.65 lane miles of roadway infrastructure.

Therefore, the impact of the development on the citywide need for roadway infrastructure is

9.65 lane miles. The cost of providing this roadway infrastructure is a minimum of $2,934,835 (Attachment 6).

Pedestrian Infrastructure
The Development will generate a population of 230 residents. Available documentation does not indicate the number of employees proposed; accordingly, the impact of employees on City infrastructure has not been evaluated and is in addition to the impacts addressed here.

SANDAG’s nonmotorized database system for location 10016_Eleg further west on Mission Road indicates that segment was used by 336 pedestrians and 106 cyclists, indicative of active transportation usage of Mission Road. Assuming a relatively low walk share proportion at 5% from the proposed Development, 23 pedestrian trips per day can be expected based off the 167,900 Estimate Annual Trips.

The City finds no evidence to support Lanikai’s claims in its environmental documents that the age-55+ residents will “recreate onsite” and will not use pedestrian or bicycle facilities.

Quite to the contrary, residents are anticipated to use City pedestrian facilities and therefore are considered to increase pedestrian demand . Key destinations within 0.5 miles are shopping and local businesses, the Inland Rail Trail, city hall, the community center, and two parks, all of which are anticipated to be active transportation destinations for the proposed residents. Based on an individualized assessment of the specific resident population and the destinations to which that population may wish to travel, t he City established the three most likely pedestrian destinations f or the Development residents as the Civic Center Sprinter Station, San Marcos Public Library, and the San Marcos Senior Activity Center.

These destinations are mapped in Attachment 3.

Table 1: Active Transportation (Pedestrian and Bicycle) Destinations Destination Travel Distance (Feet) Travel
Distance
(Miles)
Sprinter Station 480 feet 0.09 miles
Library 850 feet 0.16 miles
Senior Activity Center 2,065 feet 0.39 miles

The impact of the Development on the need for citywide pedestrian facilities is 3,395 linear feet of pedestrian pathway, valued at a minimum of $129,010 (Attachment 6).

Bicycle Infrastructure
Bicycle trips generated by the Development are most likely to be to/from the active transportation destinations described in the Pedestrian Infrastructure section in Attachment 6. Bicycling distances to the destination s described in Table 1 measured roughly the same as the pedestrian distances. Assuming a low bicycle mode share of just 1%, the Development would generate 1,679 bicycle trips per year.

The impact of the Development on the need for citywide bicycle facilities is 3,395 linear feet of bicycle infrastructure, valued at a minimum of $130,368 (Attachment 6).

3B. Local Impacts of the Development
The bike lanes on the frontage of the property are required as part of the Active Transportation Plan in the C ity’s General Plan and are thus legislatively imposed land use exactions. Additionally, there are required project improvements needed to address specific concerns resulting from the Development design , population, and location. The following sections further analyze the needs of the proposed residents for the transportation improvements required by the City.

Increased Multimodal Demand from Land Use Change
The land use change from Commercial to Senior Residential will shift trip generation from an auto-centric use commercial to a more multi -modal oriented residential use , with senior residents visiting local destinations as shown in Attachment 3 and generating more active transportation trips than a commercial development would likely have ge nerated. This increased multi -modal demand must be mitigated through the provision of appro priate active transportation facilities.

Lack of Resident Access to Active Transportation Network No bike lane exists along the Mission Road frontage of the Development. A bike lane currently exists to the east and the west of the Development; only this segment is missing .

With the impact introduced by a new population of residents, the missing segment of bicycle infrastructure must be provided and must meet the ultimate standards required in the General Plan and Active Transportation Plan. The comment that the street must be widened and the bike lane added was made on the initial improvement plan revie w for the Development.

A refusal to provide the facilities to connect the proposed senior residents to their community via the active transportation network will prevent the residents from using active transportation to access the key destinations identified in this analysis and increase the number of near -distance vehicular trips, impacting vehicle miles traveled and further increasing the burden on the City to reduce vehicle miles traveled citywide.

Pedestrian Crossing Impacts
The Development proposes to introduce senior residents with slower walking speeds, which would increase intersection delay unless mitigated . The Federal Highway Administration (FHWA) Pedestrian Safety Guide and Countermeasure Selection System notes that older pedestrians generally walk significantly slower than the standard design walking speed of

3.5 feet per second, requiring adjustments to the signal timing to allow safe crossing (FHWA, 2013). To accommodate this, the Woodward Street/ Mission Road traffi c signal must be retimed to extend the pedestrian clearance interval, which would increase vehicular delay at the intersection. The increase in the pedestrian clearance time over Mission Road would decrease vehicular green time through the intersection . Further, this delay would cause extended vehicular idling at a key intersection, increasing greenhouse gas emissions impacts.

The installation of a curb return popout with the frontage improvements, as proposed by the City in its plan review comments, would mitigate at least a portion of this Development impact. According to the Institute of Transportation Engineers (ITE) Traffic Handbook and NACTO’s Urban Street Design Guide, curb extensions can reduce crossing distances, thereby lessening the amount of additional green time that is needed for pedestrian clearance, improving intersection efficiency, and enhancing pedestrian safet y (ITE, 2010; NACTO, 2013).

The crossing distance from the Development over Mission Road is approximately 112 linear feet. Therefore, the impact from the senior population could increase pedestrian crossing times by up to 6.6 seconds. For instance, it would take an average resident six seconds to travel a distance of 21 feet at the pedestrian crossing, and it would take a n average senior resident 7.2 seconds to travel the same distance. Therefore, construction of a curb popout that shortens the crossing distance by 21 feet would reduce the time of crossing, and the associated vehicular delay, by more than half a second per cycle.

Accessible Bus Stop
A bus stop exists along the Development frontage to the north side of Mission Road. The proposed senior residents are a target population for transit, and also a population in need of accessible design, as seniors are significantly more likely to be disabled. The bus stop must provide the proposed residents with Americans with Disabilities Act (ADA) compliant design to facilitate the use of transit. The ADA -compliant bus stop must not negatively impact vehicular travel, bicycle trips, or pedestrian travel continuing along Mission Road. In addition, the bus stop must consider the conflicting movements of the southbound right turns from Woodward Street onto westbound Mission into the non-standard drop lane and the new driveway the Development proposes to introduce on Mission Road, a prime arterial.

The City-proposed improvements include a curb return popout, separated bike facility, and ADA-compliant bus bay to achieve these requirements.

New Driveway on Mission Creates Conflicts
The senior residential development proposes two new driveways: one on Woodward Street and one on Mission Road.

Mission Road is already a complex arterial. The City’s Urban Streets Design Criteria (USDC) provide that new driveways on an arterial are not allowed if any other access is available.

Driveways may be provided only when “absolutely necessary.” The Development proposes a driveway on Woodward Street, a location that meets the City’s USDC, and therefore a driveway on Mission Road should not be allowed. However, staff contemplated allowing the driveway as a concession through collaboration with the developer and expected staff comments to be addressed . Unfortunately, Lanikai has persisted in proposing the Mission driveway opening while not agreeing to address the staff comments to allow it.

The new driveway on Mission would introduce two new traffic conflict points where none exist today, and it is located less than 400 feet away from the Mission/Woodward intersection, in an area with a merge lane and existing bus stop . Introduction of the new driveway poses movements that potentially conflict with:
o Right turns from Woodward to Mission.
o Cyclists traveling westbound along the bike route.
o Impaired visibility and merging issues with bus operations in the vicinity of the proposed driveway.

Without mitigation, such as a protected bikeway, the additional conflict points would expose roadway users to merging, crossing, and turning vehicles, degrading the safety of the corridor. As the National Association of City Transportation Officials (NACTO) Urban Bikeway Design Guide notes, even low-volume driveways can meaningfully affect the comfort and safety of cyclists, and protection is especially important where vulnerable users such as senior residents are expected (NACTO, 2014).

A separated bikeway is designed specifically to reduce the types of conflicts that Lanikai proposes to introduce with the creation of a new driveway on the Mission Road arterial. The separated bikeway provides a physical separation between bicyclists and moving vehicles .

Caltrans Design Information Bulletin DIB 89 recommends separated facilities in situations with driveways and the need to enhance cyclist safety. The physical protection offered by a separated bikeway allows vulnerable cyclists to safely sto p outside of the travel lane if a vehicle is entering or exiting the new driveway, thereby reducing collision risk, and improving corridor safety.

Likewise, without mitigation, the proposed Mission Road driveway introduces a more hazardous situation for bus operations. Collisions could occur as bus operators attempt to arrive or depart from the bus stop as drivers are entering and leaving the proposed Mission Road driveway and cars are simultaneously merging onto Mission Road from Woodward Street.

In order to allow the Mission Road driveway, its impacts must be mitigated. This can be done with the provision of separated bicycling facilities to remove the conflict between driveway traffic and cyclists, and adding a curb return popout to isolate the proposed driveway traffic from merging Woodward traffic.

Woodward Driveway Improvements to Prohibit Exiting Left Turns The Woodward 46 project is on the easterly side of Woodward Street, opposite the Development. Woodward 46 takes its sole access from Woodward Street and has no alternative access available. It was entitled prior to the Lanikai Development with the driveway as proposed.

The Lanikai Development also proposes a driveway on Woodward Street, opposite the Woodward 46 driveway. Vehicles exiting Woodward 46 and the Lanikai Development would need to cross oncoming traffic and travel in the opposing travel lane to avoid colliding with each other ( Figure 1). Eliminating the conflicting left turn out of the Lanikai Development avoids the conflicting movements , so t he Lanikai driveway can only be constructed as a right-in, left-in, and right-out driveway. The City Engineer and City Traffic Engineer therefore require physical improvements such as a “pork chop” to direct exiting vehicles and prevent the left turn out from the Lanikai Development ; vehicles wishing to make the northbound movement can make a U-turn at the Woodward/Mission signal.

Figure 1: Woodward Street Turning Movements, Provided by Lanikai

4. REQUIRED EXACTIONS: DEDICATION, PUBLIC IMPROVEMENTS ,

AND PUBLIC FACILITIES FEES
The City requires a dedication of 16 feet along Woodward Drive and a dedication of 14 feet along Mission Road to accommodate the ultimate public improvements. This dedication is needed to address safety and design concerns particular to this proposed Development and to comply with the City’s Active Transportation Plan and the City’s General Plan a s further discussed in Attachment 7.

The City requires that the Development construct frontage improvements including pedestrian facilities, bicycle improvements, and pavement widening for the bus stop and the proposed right turn from Mission Road into the Development . The City also requires a curb pop-out to direct right- turning traffic from Woodward around the vehicles turning into the proposed Mission driveway and to shorten the pedestrian crossing over Mission Road to accommodate the proposed senior residents . Finally, the City requires that the Wo odward driveway be constructed in a fashion to avoid conflicts from left turns exiting the Development.

5. ESSENTIAL NEXUS
A direct and essential nexus exists between the City’s requirements to dedicate and construct transportation improvements and the burden the Development will impose upon City facilities.

The nexus is the introduction of a population that will utilize the citywide transportation network, which includes roadway, pedestrian, and bicycle facilities . This impact is new, additive, and measurable . Development will contribute to citywide traffic, including increasing vehicular delay in portions of San Marcos Blvd. and Twin Oaks Valley Road. The City has a legitimate interest in mitigating the effects of the Development on the citywide traffic and reducing traffic congestion has been found to be a legitimate government interest. (Sheetz v. County of El Dorado, 2025 WL 2116363, Dolan v. City of Tigard (1994) 512 U.S. 374, 387).

By the addition of new residents, pedestrian and bicycle demand, and vehicular trips , the Development will generate a clear and direct impact on the citywide transportation network.

The right-of-way dedication and the construction of public improvements have an essential nexus to these citywide transportation impacts. The General Plan and Active Transportation Plan identify the ultimate improvements needed to accommodate growth in the c ity, which are constructed incrementally as new development is proposed.

Further, the Development proposes to cause impacts to bicycle, bus, pedestrian, and vehicular traffic locally, at the intersection of Mission Road and Woodward Street and additional impacts from the Woodward driveway design. Addressing these impacts is warranted and directly related to the impacts posed by Lanikai.

City staff have analyzed the Development and have concluded that the City’s requirements have an essential nexus to legitimate public interests . Further, the City has found that the burden of the City’s exactions are roughly proportional in nature and extent to the impact of the Development on the City’s infrastructure, as discussed below.

6. BURDEN OF THE EXACTION ON THE DEVELOPMENT
The City requires t hat Lanikai dedicate right-of-way and construct frontage improvements roughly proportional to the demand generated by the Development and to the impacts of the Development on City infrastructure and facilities. Rough proportionality refers to the “degree of connection” between the permit conditions and the projected public impacts or social costs of the Development. (Dolan, supra, 512 U.S. at p. 386; see also Sheetz v. County of El Dorado, California (2024) 601 U.S. 267, 275-276). “No precise mathematical calculation is required, but the [government] must make some sort of individualized determination that the [land-use exaction] is related both in nature and extent to the impact of the proposed development. ” (Dolan, at p. 391, italics added.) In other words, the government “must make some effort to quantify its findings ” in support of the required private property dedication beyond mere conclusory statements. (Id. at pp. 395-396, italics added.) One method by which to make an individualized determination of the burden imposed upon the Development by the required dedication and improvement construction is to consider the sum of the value of the land dedicated for public improvements plus the cost of construction of the physical improvements. This cost can then be compared to the burden the development places on citywide facilities to assess the proportionality.

Accordingly, in order to quantify its findings in this analysis, the City determines the extent of pedestrian, bicycle, and roadway improvement demand generated citywide by the Development and compares th at demand to the physical extent of the facilities needed citywide to serve this specific development. Additionally, this analysis determines the value of the land to be dedicated by Lanikai and calculates the dollar value of the improvement construction required of the development. Finally, the analysis measures the dollar value of the development’s burden against the dollar value of the citywide improvements needed to serve the development.

Land Value
The City estimates a dedication of less than 15,000 square feet with an estimated value of $369,450. The value of the land i s based on the estimated area of dedication multiplied by the average cost per square foot based on recent data for vacant property sold within the City of San Marcos over the preceding 7 months, available through Costar 2. Sales data includes similar entitled and non-entitled properties for sale or with active options resulting in an average cost of $24.63 per square foot. Source data is supplied in Attachment 4 to this letter.

Cost of Improvements
Improvement quantity takeoffs are estimated because Lanikai has not provided plans showing the proposed improvements . The estimated cost of improvements in the public

2 Commercial real estate data and analytics system.
right-of-way is calculated in Attachment 5 and is based upon City’s approved Unit Price List3.

The total sum of the property dedication and the public improvement construction is given in Table 1 below.

Table 2: Estimated Cost Burden of Required Dedication and Frontage Improvements Location Item Cost
Woodward and
Mission
Right-of-Way Dedication $369,450
Woodward Improvements to Public Right-of-Way $87,560
Mission Improvements to Public Right-of-Way $50,916
Total Impact to the Development: $507,926

7. ROUGH PROPORTIONALITY BETWEEN BURDEN ON DEVELOPMENT
AND THE DEVELOPMENT’S IMPACTS
The improvements required of the Development bear a direct and proportional relationship to the transportation impacts generated by the Development on citywide facilities.

One way to assess the rough proportionality of the burden placed on the Development is to analyze the valuation of the land and improvements required of Lanikai and compare it to the valuation of the City wide facilities necessitated by the Development . The table below sums the total value of the demand for public facilities to serve the Development.

Table 3: Total Burden Development Places on Citywide Facilities Item Cost
Pedestrian Infrastructure Burden $129,010
Bicycle Infrastructure Burden $130,368
Roadway Infrastructure Burden $2,934,835
Total: $3,194,213

Analyzing only the pedestrian and roadway facilities impacts, the valuation of Development impacts on Citywide infrastructure is $3,194,213. The approximate financial burden placed on the Development for right -of-way dedication and frontage improvements on Woodward

3 https://www.san-marcos.net/home/showpublisheddocument/28153/638405912675870000 Street and Mission Road is $507,926. Therefore, the impact of the Development on Citywide facilities exceeds the burden placed on Lanikai.

The total area of the right-of-way dedication is estimated at less than 15,000 square feet and represents less than 10% of the gross property area of 174,676 square feet.

The Development will generate a need for 3,395 linear feet each of pedestrian and bicycle facilities Citywide and has been required by the City to construct approximately 985 linear feet each of pedestrian walkway and pavement for bicycles. Similarly, the Development has generated a need for 9.65 lane miles of roadway Citywide and has been required by the City to improve approximately 1,000 linear feet of roadway , less than 0.2 miles . The City’s improvement requirements are only that the Development improv e the project frontage to the City transportation network, which is proportional to the Development and its impacts.

8. ECONOMIC VIABILITY OF THE DEVELOPMENT
Lanikai has indicated that dedication of required right-of-way will necessitate a redesign of the Development, possibly making the project infeasible . However, numerous design permutations are possible on this property.

For example, the current design does not maximize the developable density of the site . The project site has a General Plan designation of Specific Plan Area (Heart of the City Specific Plan – Commercial). Lanikai is proposing an amendment to the H eart of the C ity Specific Plan (HOCSP) to change the site to Senior Residential. Commercial uses within the HOCSP have a maximum lot coverage of 35%. The Development proposes lot coverage of approximately 16%, which is far less intense than would otherwise be allowed within the approved Specific Plan and General Plan. As Lanikai’s proposed Development uses a significantly lower percentage of the lot than what was contemplated for a commercial use of the project site, the dedication of the right of way will not prevent Lanikai from designing the Development in a viable way.

Additionally, t he Development design includes 135 parking spaces, exceeding the 115 - space requirement per the Heart of the City Specific Plan. A redesign of the Development’s site plan to include the required right -of-way dedication may reduce the space for some of these parking spaces, but it would not make the Development infeasible.

The Supreme Court has “long recognized that land-use regulation does not effect a taking if it ‘substantially advance[s] legitimate state interests’ and does not ‘den[y] an owner economically viable use of his land. ’” (Nollan v. California Coastal Commission (1987) 483 U.S. 825, 834.) Furthermore, “[o]nly when a permit is denied and the effect of the denial is to prevent ‘economically viable’ use of the land in question can it be said that a taking has occurred. ” (United States v. Riverside Bayview Homes, Inc. (1985) 474 U.S. 121, 127.) The required right-of-way dedication will not prevent any economically viable use of the land; many economically viable uses of the project site would still be available.

9. CONCLUSION: EVALUATION OF THE EXACTION
The City has analyzed the specific impacts of the proposed Development on the City’s transportation network and has found an essential nexus between the legitima te government interest of mitigating traffic congestion on the City’s transportation network and the right-of-way dedication and require d improvements imposed by the City . Further, the City has provided a financial analysis of the burden placed on the Development and the projected public impact that the Development imposes on City facilities and found that the impacts to the Development are roughly proportional to projected public impact from the Development.

The land use exactions required of the Development have been found to be consistent with the nexus and rough proportionality standards required by Nollan v. California Coastal Commission, Dolan v. City of Tigard, Sheetz v. County of El Dorado (2024) 601 U.S. 267 and Sheetz v. County of El Dorado 2025 WL 2116363.

ATTACHMENT 1: DEVELOPMENT LOCATION

ATTACHMENT 2: CONCEPTUAL SITE PLAN

ATTACHMENT 3: ACTIVE TRANSPORTATION DESTINATIONS

ATTACHMENT 4: REAL PROPERTY SALES DATA
Sale Comps Map & List Report
Sale Comparables Summary Statistics
Sale Attributes Low Average Median High
Sale Price $3,600,000 $7,742,000 $6,500,000 $13,126,000 Sale Price Per SF $464 - $464 $464
Cap Rate - - - -
Sale Price Per AC $307,956 $1,042,928 $1,669,975 $2,389,706 Property Attributes Low Average Median High
Building SF - - - -
Y ear Built 1973 1973 1973 1973
% Leased At Sale - - - -
Star Rating 0 1 1 2
Summary Statistics exclude For Sale and Under Contract listings Sale Comps List
Property Name
Address Type Built/Renovated Size
(% Leased) Sale Date Price Cap Rate
1 1023 Grand Avenue
San Marcos, CA 92078 Land - 7.86 AC 3/28/2025
$13,126,000
($1,669,972.60/-
AC)
-
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
Sale Comps List (Continued)
Property Name
Address Type Built/Renovated Size
(% Leased) Sale Date Price Cap Rate
2 1100 W San Marcos Blvd
San Marcos, CA 92078
Retail 1973 14,000 SF 2/18/2025 $6,500,000
($464.29/SF) -
3 00 La Moree Rd
San Marcos, CA 92078
Land - 11.69 AC 2/10/2025 $3,600,000
($307,955.76/AC) -
4 801 S Twin Oaks Valley Rd
San Marcos, CA 92078 Land - 159.90 AC Escrow $5,950,000 ($37,210.76/AC) -
5 San Marcos Mixed Use Land
302 N Pacific St
San Marcos, CA 92069
Land - 5.60 AC Under Con-
tract
$4,750,000
($848,214.29/AC) -
6 3600 Grand Ave
San Marcos, CA 92078
Land - 0.99 AC Escrow
$1,950,000
($1,969,696.97/-
AC)
-
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
1 1023 Grand Avenue
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Sale Summary
Sold 3/28/2025
Sale Price $13,126,000
Land Area AC 7.86
Land Area SF 342,382
Price/AC Land $1,669,973
Price/SF Land $38.34
Price Status Confirmed
Sale Comp Status Research Complete
Sale Comp ID 7117503
Parcel Numbers 219-152-74 +3
Transaction Details
Sale Date 3/28/2025 Recording Date 3/28/2025
Sale Price $13,126,000 Transfer Tax $14,439
Land Price $1,669,973/AC ($38.34/SF) Document Number 0080190 Sale Type Investment
Parcel Number 219-152-79, 219-152-74, 219-152-76, 219-152-77 Contacts
Type Name Location Phone
Recorded Buyer Paloma Townhomes Llc - -
True Buyer California Pacific Homes Irvine, CA 92617 (949) 833-6000 Recorded Seller Aoa San Marcos Llc - -
True Seller Lab Holding LLC Costa Mesa, CA 92626 (714) 966-6661 Transaction Notes
On March 28th, 2025, Community Management Corporation sold the 7.86-site to California Pacific Homes for $13,126,000, approximately $1,669,974.

The buyer is planning to develop a 102-lot SFR townhome community which will be called Paloma Townhomes.

The information provided for this sale transaction was verified by sources deemed reliable.

Sale History
Sale Date Price Sale Type Buyer Seller
3/28/2025 $13,126,000 ($1,669,973/-
AC) Investment California Pacific Homes Lab Holding LLC © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
1 1023 Grand Avenue
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
1 1023 Grand Avenue
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Transportation
Traffic Volume
8,636 on S Bent Ave (2025); 3,180 on Via Vera Cruz (2025); 9,623 on Linda Vista Dr (2025); 145,867 on W San Marcos Blvd (2025); 7,895 on N Las Posas Rd (2025); 8,108 on N Las Posas Rd (2025); 24,413 on S Las Posas Rd (2025); 4,361 on Vallecitos de Oro (2025); 14,342 on la Mirada Dr (2025); 4,361 on Ryan Dr (2025) Transit/Subway Palomar College
19 min walk
Commuter Rail Carlsbad Poinsettia
18 min drive
Airport San Diego International 47 min drive
Walk Score ® Somewhat Walkable (54)
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
2 1100 W San Marcos Blvd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Retail Sale Summary
Sold 2/18/2025
Sale Price $6,500,000 ($464.29/SF)
GLA 14,000 SF
Price Status Full Value
Built 1973
Land Area 2.72 AC/118,483 SF
Sale Comp Status Research Complete
Sale Comp ID 7069189
Parcel Numbers 219-200-47
Transaction Details
Sale Date 2/18/2025 Recording Date 2/18/2025
Sale Price $6,500,000 ($464.29/SF) Zoning C
Land Price $2,389,710/AC ($54.86/SF) % Improved 3.48%
Sale Type Investment Document Number 0039980
Hold Period 41 Months
Parcel Number 219-200-47
Property Details
Tenancy Single Building FAR 0.12
Docks None
Parking Spaces 36 Surface Spaces; Ratio of 2.57/1,000 SF Frontage 200' on West San Marcos Boulevard
Contacts
Type Name Location Phone
Recorded Buyer Sb-hs Lot Option Pool 01 Lp - -
True Buyer Hearthstone, Inc. Calabasas, CA 91302 (818) 385-0005 Recorded Seller San Marcos Development Group Llc - -
True Seller Majid Mortazavi Cardiff By The Sea, CA 92007 (858) 342-1711 Transaction Notes
A private individual sold this 14,000 square foot retail building to Hearthstone Inc. for $6,500,000 or $464.29 per square foot.

The information in this comparable has been sourced from public record. © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
2 1100 W San Marcos Blvd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Retail Amenities
• Storage Space
Previous Sale
Sale Date 9/2/2021 Comp ID 5673378
Sale Price $4,600,000 ($328.57/SF) Comp Status Research Complete Sale Type Investment Sale Conditions Redevelopment Project Sale History
Sale Date Price Sale Type Buyer Seller
2/18/2025 $6,500,000 ($464.29/SF) Investment Hearthstone, Inc. Majid Mortazavi 9/2/2021 $4,600,000 ($328.57/SF) Investment Majid Mortazavi The McDonald Group 5/13/2014 $1,700,000 ($121.43/SF) Investment The McDonald Group Sears Roebuck & Company Market Conditions at Sale
Vacancy Rates Current YOY Change Submarket Leasing
Activity Current YOY Change
Subject Property 0.0% 0.0% 12 Month Leased 66,159 SF

17.8%
Submarket 1-2 Star 3.6%
-1.5% Months on Market 12.6 -
Market Overall 4.2%
-0.1%
Market Asking Rent Per
Area Current YOY Change Submarket Sales Activity Current Prev Year Subject Property $2.20/SF

3.0% 12 Month Sales Volume $12.45M $15.14M
Submarket 1-2 Star $2.48/SF

1.9% Market Sale Price Per Area $322/SF $258/SF
Market Overall $2.98/SF

1.1%
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
2 1100 W San Marcos Blvd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Retail © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
2 1100 W San Marcos Blvd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Retail Transportation
Parking Details 36 Surface Spaces; Ratio of 2.57/1,000 SF Traffic Volume
32,333 on S Las Posas Rd (2025); 4,361 on Ryan Dr (2025); 10,363 on Linda Vista Dr (2025); 7,393 on Discovery St (2025); 7,998 on Applewilde Dr (2025); 9,623 on Linda Vista Dr (2025); 38,281 on PkPl (2025); 35,315 on S Pacific St (2025); 8,006 on Pacific St (2025); 3,180 on Via Vera Cruz (2025) Frontage 200' on West San Marcos Boulevard
Commuter Rail Carlsbad Poinsettia
16 min drive
Airport San Diego International 48 min drive
Walk Score ® Somewhat Walkable (59)
Nearby Sale Comparables
Property Name
Address Type Built/
Renovated
Size
(% Leased) Sale Date Price Cap Rate
4606 Mission Bay Dr Retail 1971/2018 10,000 SF
(100%) 10/10/2023 $5,250,000
($525.00/SF) -
Sante Fe Center
1031 S Santa Fe Ave
Retail 1991 18,886 SF
(100%) 11/9/2023 $4,387,500
($232.31/SF)

5.00%
Actual
351 E Pennsylvania Ave Retail 1964 10,000 SF
(100%) 1/22/2024 $2,250,000
($225.00/SF) -
6024 Paseo Delicias Retail 1926 9,475 SF
(90.0%) 4/19/2024 $11,247,000
($1,187.02/SF) -
Old California Restaurant Row
1020 W San Marcos Blvd
Retail - 12,000 SF
(100%) 4/12/2024 $3,000,000
($250.00/SF) -
415 N Ash St Retail 2005 14,000 SF 8/15/2024 $4,000,000 ($285.71/SF) -
7865 Balboa Ave Retail 1977 7,000 SF
(100%) 9/13/2024 $3,745,000
($535.00/SF) -
375 La Costa Ave Retail - 13,119 SF 9/25/2024 $2,800,000 ($213.43/SF) -
Tip Top Meat
6118 Paseo Del Norte
Retail 1980 10,500 SF
(28.0%) 12/31/2024 $4,600,000
($438.10/SF) -
Gerber
535 N Quince St
Retail 1980 10,980 SF 1/17/2025 $2,953,000
($268.94/SF) -
1916 S Coast Hwy Retail 1990 8,844 SF 1/15/2025 $3,060,000 ($346.00/SF) -
South Coast Center
1118-1126 S Coast Hwy
Retail 1956 10,145 SF
(100%) 3/24/2025 $3,200,000
($315.43/SF) -
305-321 N Ash St Retail 1968 7,392 SF 4/4/2025 $1,600,000 ($216.45/SF)

3.91%
Actual
237 E Valley Pky Retail 1982 7,000 SF 2/11/2025 $1,800,000 ($257.14/SF) -
360 Via Vera Cruz Retail - 7,121 SF 6/23/2025 $3,500,000 ($491.50/SF) -
2954 San Luis Rey Rd Retail 1988 7,373 SF 7/1/2025 $2,183,500 ($296.15/SF) -
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
2 1100 W San Marcos Blvd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Retail © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
3 00 La Moree Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Sale Summary
Sold 2/10/2025
Sale Price $3,600,000
Land Area AC 11.69
Land Area SF 509,216
Price/AC Land $307,956
Price/SF Land $7.07
Price Status Confirmed
Sale Comp Status Research Complete
Sale Comp ID 7052891
Parcel Numbers 220-341-02
Transaction Details
Sale Date 2/10/2025 Time On Market 7 Months 16 Days
Sale Price $3,600,000 Recording Date 2/10/2025
Land Price $307,956/AC ($7.07/SF) Zoning SFDR
Sale Type Investment Document Number 0034441
Parcel Number 220-341-02
Property Details
Topography Sloping Density Allowed 2-4du/acre
On-Sites Raw land Zoning SFDR
Proposed Use Apartment Units, Mixed Use, Single Family Development Off-Sites No Cable, No Curb/Gutter/Sidewalk, Electricity, Gas, No Irrigation, Sewer, No Streets, No Telephone, Water Zoning Description Heart of the City Specific Plan
Contacts
Type Name Location Phone
Recorded Buyer Sea Breeze Properties LLC San Diego, CA 92130 - True Buyer Sea Breeze Properties San Diego, CA 92130 (858) 205-1199 Recorded Seller Corp Of The Presiding Bishop of the Church Jesus
Salt Lake City, UT 84150 (801) 240-8619
True Seller The Church of Jesus Christ of Latter-Day
Saints
Salt Lake City, UT 84150 (801) 240-1000
Listing Broker Lee & Associates Carlsbad, CA 92008 (760) 929-9700 Transaction Notes
This 11.69 acre plot of land traded between The Church of Jesus Christ of Latter Day Saints and Sea Breeze Properties for $3,600,000 or approximately $306,000 per acre. The listing was added to market June 25, 2024 with an initial asking price of $3,100,000 and was on market for 230 days. The land is currently ungraded and will be used for development. The specifics are currently unknown.

The information in this comparable has been verified via the listing brokers. © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
3 00 La Moree Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Sale History
Sale Date Price Sale Type Buyer Seller
2/10/2025 $3,600,000 ($307,956/AC) Investment Sea Breeze Properties The Church of Jesus Christ of Latter-Day Saints
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
3 00 La Moree Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
3 00 La Moree Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Transportation
Traffic Volume
2,673 on Calli del Verano (2025); 12,795 on Walnut Hills Dr (2025); 14,156 on Redel Rd (2025); 173,597 on N Twin Oaks Valley Rd (2025); 5,725 on Woodland Pkwy (2025); 7,191 on Mata Way (2025); 14,732 on Woodland Pkwy (2025); 909 on Via del Campo (2025); 2,015 on Cam de la Cima (2025); 6,391 on Woodland Pkwy (2025) Transit/Subway Cal State San Marcos
6 min walk
Airport San Diego International 45 min drive
Walk Score ® Car-Dependent (35)
Nearby Sale Comparables
Property Name
Address Type Built/
Renovated
Size
(% Leased) Sale Date Price Cap Rate
Twain Ct Land - 21.82 AC 9/29/2023
$12,000,000
($550,002.89/-
AC)
-
Oceanside Blvd & Melrose Dr Land - 9.15 AC 12/15/2023
$13,000,000
($1,420,765.03/-
AC)
-
Valley Center
Valley Center Rd
Land - 13.98 AC
(0%) 7/15/2024
$5,500,000
($393,402.89/-
AC)
-
North Village Shopping Center
Valley Center Rd
Land - 13.51 AC 7/15/2024
$5,500,000
($407,105.57/-
AC)
-
Highway 67 Land - 8.00 AC 1/29/2025
$10,600,000
($1,325,000.00/-
AC)
-
Bella Vista Drive 10.1 Acres
000 Bella Vista
Land - 10.10 AC 3/19/2025
$11,963,000
($1,184,455.45/-
AC)
-
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
4 801 S Twin Oaks Valley Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Sale Summary
Escrow 886 Days on Market
Asking Price $5,950,000
Number of Lots 1
Lot Size 159.90 AC
Price/AC Land $37,211
Price/SF Land $0.85
Land Area AC 159.90
Land Area SF 6,965,244
Parcel Numbers 222-121-05 +7
Transaction Details
Sale Type Investment Zoning CA-6
Parcel Number 222-190-09, 222-190-11, 222-190-10, 222-180-41, 222-121-27 +3 Property Details
Topography Sloping Current Use Vacant
On-Sites Raw land Zoning CA-6
Off-Sites No Cable, No Curb/Gutter/Sidewalk, Electricity, Gas, No Irrigation, Sewer, No Streets, No Telephone, Water Transaction Notes
801 S Twin Oaks Valley Rd, also known as the "White-Attebury Specific Plan" is the largest contiguous residential specific plan in the City of San Marcos.

The Specific Plan allows 68 dwelling units. The S Twin Oaks Valley property offers builders and developers the opportunity to capture the demand for upscale housing in the City of San Marcos. The subject property is located just South of the high-end Rancho Tesoro and Village O residential communities. The elevation of the property allows for panoramic ocean, mountain, and city views. The newly constructed North City project by Sea Breeze Communities at CSU San Marcos hosts multiple new dining and entertainment options. © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
4 801 S Twin Oaks Valley Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
4 801 S Twin Oaks Valley Rd
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Transportation
Traffic Volume
15,197 on Double Peak Dr (2025); 16,527 on Village Dr (2025); 20,487 on Campus Vw (2025); 4,679 on Little Creek Rd (2025); 15,301 on Eclipse Dr (2025); 1,344 on Windriver St (2025); 15,402 on Echo Ln (2025); 5,435 on Reflection (2025); 24,124 on Discovery St (2025)
Airport San Diego International 47 min drive
Walk Score ® Car-Dependent (5)
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
5 302 N Pacific St - San Marcos Mixed Use Land
San Marcos, CA 92069 (San Diego County) - San Marcos Submarket Land Sale Summary
Under Contract 1,147 Days on Market
Asking Price $4,750,000
Number of Lots 1
Lot Size 5.60 AC
Price/AC Land $848,214
Price/SF Land $19.47
Land Area AC 5.60
Land Area SF 243,936
Transaction Details
Sale Type Investment or Owner User Zoning MU-1
Property Details
Topography Level Dimensions Irregular
On-Sites Raw land Zoning MU-1
Current Use Vacant Land
Proposed Use Apartment Units, Apartment Units - Condo, Hold for Development, Hold for Investment, Mixed Use, MultiFamily, Storefrnt Retail/Residntl, Storefront
Improvements Vacant Land
Off-Sites Cable, No Curb/Gutter/Sidewalk, Electricity, Gas, No Irrigation, No Sewer, No Streets, No Telephone, Water Frontage 883' on W Mission Rd
Contacts
Type Name Location Phone
Listing Broker Doug Ross Real Estate San Diego, CA 92191 - Transaction Notes
Seller may finance. Prime investment opportunity in the heart of San Marcos, CA. © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
5 302 N Pacific St - San Marcos Mixed Use Land
San Marcos, CA 92069 (San Diego County) - San Marcos Submarket Land © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
5 302 N Pacific St - San Marcos Mixed Use Land
San Marcos, CA 92069 (San Diego County) - San Marcos Submarket Land Transportation
Traffic Volume
14,449 on N Rancho Santa Fe Rd (2025); 16,176 on N Pacific St (2025); 12,133 on Capalina Rd (2025); 20,087 on Capalina Rd (2025); 22,032 on Palm Rd (2025); 8,662 on N Rancho Santa Fe Rd (2025); 142,869 on N Rancho Santa Fe Rd (2020); 9,162 on N Rancho Santa Fe Rd (2025); 9,205 on S Rancho Santa Fe Rd (2025) Transit/Subway Palomar College
20 min walk
Airport San Diego International 48 min drive
Walk Score ® Very Walkable (70)
Nearby Sale Comparables
Property Name
Address Type Built/
Renovated
Size
(% Leased) Sale Date Price Cap Rate
NEC Twin Oaks Valley Rd & Ri…
Twin Oaks Valley Rd
Land - 3.37 AC 11/2/2023
$5,800,000
($1,719,559.51/-
AC)
-
Oceanside Blvd & Melrose Dr Land - 9.15 AC 12/15/2023
$13,000,000
($1,420,765.03/-
AC)
-
1058 Old Taylor St Land - 3.64 AC 8/8/2024
$6,200,000
($1,703,311.74/-
AC)
-
Town Center Pkwy & Mission G… Land - 5.26 AC 1/21/2025
$10,000,000
($1,901,137.37/-
AC)
-
Highway 67 Land - 8.00 AC 1/29/2025
$10,600,000
($1,325,000.00/-
AC)
-
10650 Scripps Ranch Blvd Land - 2.98 AC 1/24/2025
$9,000,000
($3,017,874.46/-
AC)
-
Bella Vista Drive 10.1 Acres
000 Bella Vista
Land - 10.10 AC 3/19/2025
$11,963,000
($1,184,455.45/-
AC)
-
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
6 3600 Grand Ave
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Sale Summary
Escrow 818 Days on Market
Asking Price $1,950,000
Number of Lots 1
Lot Size 0.99 AC
Price/AC Land $1,969,697
Price/SF Land $45.22
Land Area AC 0.99
Land Area SF 43,124
Transaction Details
Sale Type Investment % Improved 81.36%
Zoning MU-1
Property Details
Topography Level Dimensions Irregular
On-Sites Rough graded Zoning MU-1
Current Use Vacant Land
Proposed Use Apartment Units, Commercial, Hold for Development, Hold for Investment, Mixed Use, Storefrnt Retail/Residntl Improvements Vacant Land
Frontage 238' on Grand Ave
Transaction Notes
The property is located just west of the corner of Grand Avenue and Rancho Santa Fe Road in the City of San Marcos, County of San Diego. Positioned less than 1/4 mile south of Highway 78, this site is ideally suited for commercial development adjacent to one of San Marcos’ busiest roads. With excellent ingress/egress accessibility and street visibility, this site presents developers, builders, and investors with tremendous current and future financial upside. © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
6 3600 Grand Ave
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land © 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
6 3600 Grand Ave
San Marcos, CA 92078 (San Diego County) - San Marcos Submarket Land Transportation
Traffic Volume
3,032 on Kensington Dr (2025); 29,829 on Descanso Ave (2025); 28,032 on 8th St (2025); 8,765 on Pawnee St (2025); 6,913 on Las Flores Dr (2025); 2,085 on S Rancho Santa Fe Rd (2025); 29,371 on Descanso Ave (2025); 9,205 on S Rancho Santa Fe Rd (2025); 10,001 on S Rancho Santa Fe Rd (2025) Commuter Rail Carlsbad Poinsettia
16 min drive
Airport San Diego International 47 min drive
Walk Score ® Very Walkable (77)
Nearby Sale Comparables
Property Name
Address Type Built/
Renovated
Size
(% Leased) Sale Date Price Cap Rate
W Citracado Pky & Miller - Lot A
W Citracado Pky
Land - 0.78 AC 7/27/2023
$797,500
($1,022,429.88/-
AC)
-
Vista Business Park
2232 La Mirada Dr
Land - 0.61 AC 9/5/2023
$1,125,000
($1,844,234.53/-
AC)
-
Resort View Apartments
Viejo Castillo Way
Land - 0.87 AC 1/31/2024
$3,565,000
($4,085,755.63/-
AC)
-
M54 Zoned Parcel & Business…
1339 Walnut St
Land - 0.53 AC 4/29/2024
$782,500
($1,476,402.30/-
AC)
-
N Las Posas Rd Land - 1.95 AC 12/12/2024
$3,700,000
($1,897,435.90/-
AC)
-
2608 S Escondido Blvd Land - 1.78 AC 12/20/2024
$7,650,000
($4,297,741.72/-
AC)
-
Highly Visible Commercial Land
Business Park Dr
Land - 1.00 AC 6/3/2025
$2,076,500
($2,076,500.00/-
AC)
-
10180-10190 Riverford Rd Land - 1.49 AC 5/30/2025
$2,300,000
($1,541,828.25/-
AC)
-
Retail / Hospitality Developme…
1 Bedford Ct
Land - 1.88 AC 6/10/2025
$4,400,000
($2,340,419.82/-
AC)
-
© 2025 CoStar Group - Licensed to City of San Marcos - 733729

7/14/2025
ATTACHMENT 5: IMPROVEMENT COST CALCULATIONS
The City provides the costs for various types of construction in its approved Unit Price List .

As with the calculations for the impact of the Development on City facilities, these calculations likewise n eglect grading, demolition, curb and gutter, retaining structures, utility relocations, landscaping, driveways, and other incidental work; clearing and grubbing is included in pavement costs . Land values are calculated separately, as given in Attachment 4.

Woodward Street Frontage
A 16’ dedication is required to accommodate ultimate public improvements. The frontage to Woodward Street measures approximately 550 feet long.

Table 4: Woodward Street Frontage Improvements
Item Quantity Unit Price Total Price
Sidewalk 5’ Wide 2,750 square feet $7.60/sf $20,900
Concrete pavement,
12’ wide
6,600 square feet $7.60/sf $50,160
Curb and Gutter 550 linear feet $30.00/lf $16,500
Total: $87,560

Mission Road Frontage
A 14’ dedication is needed to accommodate ultimate public improvements. The frontage to Mission Road measures approximately 435 feet long. A curb popout is required; 70 linear feet are removed from the frontage curb and gutter length to avoid double-counting.

Table 5: Mission Road Frontage Improvements
Item Quantity Unit Price Total Price
Sidewalk 5’ Wide 2,175 square feet $7.60/sf $16,530
Concrete pavement,
6’ wide
2,610 square feet $7.60/sf $19,836
Curb and Gutter 365 linear feet $30.00/lf $10,950
Curb and Gutter
Pop-out
120 linear feet $30.00/lf $3,600
Total: $50,916

ATTACHMENT 6: IMPACT OF THE DEVELOPMENT ON CITY

INFRASTRUCTURE
When new residents of the Development travel throughout the community, they will impose an incremental burden on the entire citywide transportation system of roadways, pedestrian walkways, and bicycle facilities extending well beyond the project’s immediate frontage .

Therefore, the citywide impacts of the Development are considered in this analysis.

Pedestrian Infrastructure
Based on a reasonable and individualized assessment of the specific resident population and the destinations to which that population may wish to travel, The City found the most likely pedestrian destinations from the Development as the Civic Center Sprinter Station, San Marcos Public Library, and the San Marcos Senior Activity Center. The Development has a main entrance located at the corner of Woodward and Mission. Estimated door-to-door distances are measured from this corner and traveling within the public right -of-way to the key pedestrian locations are summarized in Table 3 below.

The City constructs, at minimum, a five -foot-wide pedestrian facility. The City provides the costs for various types of construction in its approved Unit Price List . Neglecting grading, demolition, retaining structures, utility relocations, landscaping, driveways, and other incidental work, and including only the cost of clearing the area and the sidewalk pavement itself, the sidewalk would cost $7.60 per square foot.

Table 6: Estimated Cost of Pedestrian Facilities Required of City Destination Travel
Distance
(Feet)
5’ Wide
Sidewalk
Area (Square
Feet)
Sidewalk
Segment
Cost at
$7.60/ sf
Sprinter Station 480’ 2,400 $18,240
Library 850’ 4,250 $32,300
Senior Activity
Center
2,065’ 10,325 $78,470
Total 3,395 16,975 $129,010

In total 3,395 linear feet of pedestrian pathway, valued at a minimum of $129,010, are needed to support the proposed development.

Roadway Infrastructure
SANDAG current (2016) data indicates that the project location, Census Tract 200.22, will generate 19.3 vehicle miles traveled per capita. The Development population estimate is 230 residents, neglecting employees. The employees would add additional trips not calculated here. Therefore, Lanikai proposes an impact of 1,162,235 annual vehicle miles traveled (VMT) to City infrastructure.

Based upon the traffic study, the Development would generate 167,900 Estimated Annual Trips (EAT). Dividing the 1,162,235 annual vehicle miles traveled by the annual trips indicates that each trip will be an average of 9.65 miles long.

The City provides the costs for various types of construction in its approved Unit Price List .

A travel lane is typically 11 to 13 feet wide. Our calculations assume an average 12-foot lane width. Neglecting grading, demolition, curb and gutter, retaining structures, utility relocations, landscaping, driveways, and other incidental work, and including only the cost of clearing the area and placing 6 inches of aggregate base and 4 inches of asphalt concrete, the cost to the City of providing the necessary facility would be $4.80 per square foot.

The square footage of roadway needed to accommodate the Development’s VMT is:
(9.65 lane miles) x (5280 feet/ mile) x (12-foot lane width) = 611,424 square feet The cost of providing the needed roadway facility is:
(611,424 square feet) x $4.80 per square foot = $2,934,835

The cost of providing the 9.65 lane miles of roadway infrastructure to support the development is $2,934,835.

Bicycle Infrastructure
The Development will generate bicycle trips; the Development will provide one bike parking area per five residential units proposed, resulting in storage for a minimum of 23 bicycles.

Based on a reasonable and individualized assessment of the specific resident population and the destinations to which that population may wish to travel, bicycle trips generated by the Development are most likely to be to/from the active transportation destinations described in the Pedestrian Infrastructure section above. These trips result in the need for 3,395 linear feet of bicycle infrastructure.

A bicycle facility can be constructed of either asphalt or concrete, depending upon location.

This analysis assumes asphalt, which results in a lower cost of the burden placed by the Development on the City. A minimum of an eight-foot width is needed for a bicycle facility.

Neglecting grading, demolition, retaining structures, utility relocations, landscaping, driveways, and other incidental work, and including only the cost of clearing the area and placing 6 inches of aggregate base and 4 inches of asphalt concrete, the cost to the City of providing the necessary facility would be $4.80 per square foot.

The square footage of roadway needed to accommodate the Development’s bicycle miles traveled is:
(3,395 linear feet) x (8-foot width) = 27,160 square feet The cost of providing the needed roadway facility is:
(27,160 square feet) x $4.80 per square foot = $130,368

ATTACHMENT 7: CITY FEE STUDY, ACTIVE TRANSPORTATION PLAN,

AND CONFLICT WITH GENERAL PLAN
2024 Development Impact Fee Study and Nexus Study
In evaluating Lanikai’s position, City staff and consultants have also evaluated the Public Facilities Fees proposed to be assessed to the Development.

General Plan Policy LU-7.2 states: “Update and revise existing fee programs as needed, to ensure adequate funding for infrastructure improvements and community facilities are available to serve new development. Amend appropriate codes to require new projects to pay for the infrastructure and services.” [emphasis added]. The primary policy objective of the City’s Public Facilities Fee (PFF) program is to ensure that new development pays the capital costs associated with growth.

Accordingly, the 2024 Development Impact Fee Nexus Study 4 ( Nexus Study) (incorporated
here by reference) h analyzed infrastructure demands in San Marcos to support growth through the year 2040 and the development impact fees needed to support that development. City Council adopted the study and fees in the fall of 2024. The City Council’s action ensures that the costs representing future development’s share of necessary public facilities and capital improvements are imposed on that development in the form of a development impact fee or Public Facilities Fee (PFF). The fee s studied in the Nexus Study and approved by City Council represent the proportional funding required by developers for the public facilities that are required to be constructed when a property is developed. (Nexus Study p. 51.) The Nexus Study assumes that right-of-way (ROW) will be dedicated by future development as a condition of development and therefore does not consider the costs of ROW acquisition, only the costs of improvement construction.

The Nexus Study analyzes the impact fees contemplated by the City and finds a nexus with a legitimate City purpose and that the fees are reasonably related to the impact of the future development on those public improvements . In the nexus study, the five statutory findings a r e m a d e : s p e c i fi c a l l y , 1 ) t h e p u r p o s e o f t h e f e e , 2 ) u s e o f f e e r e v e n u e s , 3 ) b e n e fi t relationship, 4) burden relationship, and 5) proportionality. In the most recent Sheetz case, the C ourt found that the “Nollan/Dolan test is similar to the reasonable relationship standard employed in California to assess the validity of land-use exactions (e.g., impact fees) in the context of individualized (i.e., project specific) conditions imposed on an ad hoc basis through administrative action.” (Sheetz v. County of El Dorado, 2025 WL 2116363, *17.)

4 ttps://www.san-marcos.net/departments/development-services/planning/applications-forms-fees/fee- adjustment
Accordingly, California’s Mitigation Fee Act (Government Code Section 66000 et seq. ) has effectively incorporated the Nollan/Dolan test and as the City’s PFF was adopted pursuant the Mitigation Fee Act, the City’s PFF thus complies with the nexus and rough proportionality tests required by Nollan/Dolan and Sheetz.

Active Transportation Plan
In its July 24, 2025 letter to the City, Lanikai states that, “Lanikai will not be amending its site plan or any other element of its application to include a bike lane that requires it to dedicate to the City, without compensation, frontage property for such purpose.” However, the bicycle facility is not only appropriate in nexus and in rough proportionality to the Development; it is also required by the General Plan, as discussed below.

Developments must demonstrate consistency with the General Plan prior to approval:
“Local government land use approvals-whether for public or private projects-require general plan consistency. ” ( Corona-Norco Unified School District v. City of Corona (1993) 17 Cal.App.4th 985.) Government Code section 65302 requires cities to adopt a general plan containing specified mandatory elements.

In 2024, City Council adopted the Active Transportation Plan (ATP) as part of its General Plan Mobility Element . The City’s adoption of the ATP aligns with the Active Transportation Program created by:
• Senate Bills 99 and 101 (2013 Active Transportation Program) • Assembly Bill 1358 (California Complete Streets Act, 2008) These state laws require the City to modify circulation plans to increase biking and walking trips while increasing safety and mobility of non-motorized users and creating a balanced, multimodal transportation network that meets the needs of all users of streets, roads, and highways for safe and convenient travel . As a result of the adoption of the ATP , Developers have a role in implementing these infrastructure elements, which is well supported by the Development Impact Fee Nexus Study. This shows the esse ntial nexus between the legitimate state interest of increasing safety and mobility of non -motorized users and requiring bike lanes to be installed on Mission Road.

The ATP requirements for bicycle facilities on Mission Rd were specifically contemplated in the Nexus Study. The Planned Bike Facilities in the ATP for the City are listed in Table 3.5 on page 17 of the Nexus Study. The Nexus Study analyzed the nexus and rough proportionality of these specific ATP land use exactions using the reasonable relationship test that was upheld in the most recent Sheetz case.

The ATP has ranked Mission Road as the number one Interim Bike Prioritization Roadway, signifying the importance of these improvements being implemented in the City. Mission Road and Woodward Street facilities are included in the General Plan and ATP . The ATP clearly states that Developers will be required to i ncorporate the ultimate bicycle network recommendations when considering setbacks, frontage improvements, and design, and may be required to construct the ultimate facilities based upon roadway charac teristics, adjacent facilities, and the ability to design and construct appropriate transitions into the ultimate improvements.

The Development Impact Fee nexus study already supports the need for these facilities citywide. Without the construction of these facilities in the future, the City’s ability to ensure compliance with the goals of the General Plan and the greenhouse gas re duction goals contained in the City’s Climate Action Plan will be greatly impacted. Further, the Climate Action Plan requires the construction of the bicycle facilities identified in the Active Transportation Plan in order to achieve the required greenhous e gas reductions targets therein.

Conflict with the City’s General Plan
If the improvements associated with the ATP are not installed, the City cannot make the finding that the Development is consistent with the General Plan and approve the Development. A project is consistent with a general plan if “ ‘it will further the objectives and policies of the general plan and not obstruct their attainment. ’” ( Corona-Norco Unified School Dist. at 994.)
Accordingly, if the Development builds according to its existing site plan and does not provide the right -of-way dedication as required, the City will be obstructed from implementation of ATP improvements , which will prevent the City from meeting the City’s and State’s goals for active transportation , complete streets , and greenhouse gas reductions.

Lanikai’s development proposal would place site improvements and portions of the building within land that the City requires as right-of-way for legitimate state interests . In addition, Lanikai proposes to change the land use from Commercial to Senior Residential, which will result in a demand for a greater number and proportion of multi-modal trips than the existing Commercial land use. At the same time as it increases pedestrian and bicycle demand, the Development would prevent the City from being able to construct these bicycle and pedestrian facilities for a period of approximately 50 years, the life of the building , by constructing the building within the same area needed for active transportation improvements. Without appropriate facilities available, trips that could be made by walking or bicycling must instead be made only by vehicle . This forced mode shift would increase vehicle miles traveled (VMT) within the City and the region and reduce the City’s ability to meet greenhouse gas reductions targets adopted in the Climate Acton Plan. These effects would increase the Development’s burden on the City’s transportation network far more than what has been analyzed from a financial perspective in this memorandum.

EXHIBIT 7
From: Justin Schlaefli
To: Lanikai Management
Cc: David Hubbard; Rick Gittings
Subject: Re: Lanikai Project Mitigated Negative Declaration Date: Tuesday, July 14, 2026 7:52:11 AM
Greg,
I reviewed the City attorney's administrative decision and your summary of the four denial points. As you note, our June memo already addresses Items 1 through 3 (the bulb-out fails the Caltrans HDM 303.4 criteria on three independent grounds, the Mission driveway is required by the Fire Department's two-point access standard, and the trip generation numbers are too small to support the City's mitigation demands). Responses to your two questions on Item 4 follow.

1. Estimated cost to increase the pedestrian crossing time at Mission This is a signal timing (software) change, not a construction item. The City operates Type 2070 controllers, and pedestrian Walk and Flashing Don't Walk intervals are programmable parameters. The work consists of a timing analysis, revised timing sheets, and implementation/field verification by the City's signal technician. At a planning level, I would estimate:
- Engineering analysis and revised timing sheets: $3,000 - $5,000 - City staff implementation and field check: $500 - $1,500 (often absorbed as routine in-house work)
- Coordination plan check, if the City requires one because the intersection runs coordinated:
$1,500 - $3,000
Total: roughly $5,000 - $10,000, and potentially near zero if the City simply retimes it in- house as routine maintenance. No new poles, heads, or push buttons are required (existing equipment is assumed to remain). For contrast, the bulb-out the City proposes is a construction project - curb, gutter, drainage, and ADA ramp work typically well into six figures - to shorten the crossing by only 10-12 feet, which at standard walking speed saves about four seconds.

2. Effect of increased crossing time on intersection circulation The numbers: the Mission crossing is approximately 118 feet, with a reported existing crossing time of about 31 seconds. The California MUTCD standard walking speed is 3.5 ft/s (about 34 seconds for this crossing); the recognized speed for older/disabled pedestrians is 2.8 ft/s, which yields about 42 seconds. Retiming to the 2.8 ft/s senior walking speed would therefore add roughly 8 to 11 seconds of pedestrian clearance time.

The operational effect is negligible, for two reasons. First, the pedestrian phase only runs when the push button is actuated - per the City's own figure, about 23 pedestrian crossings per day, mostly outside peak hours. Second, the pedestrian clearance runs concurrently with the parallel vehicle green, so the added time simply extends that green when a pedestrian is present; the longer minimum is absorbed within the signal cycle. Averaged over the day, the change in delay for the intersection is a fraction of a second per vehicle and would not change the intersection's level of service. If the signal runs in coordination, the City would verify the longer pedestrian minimum fits the cycle - at the cycle lengths the City typically runs, it does.

In short, the pedestrian crossing concern in Item 4 is fully addressable through signal timing at nominal cost, without the bulb-out or roadway widening the City proposes. These are planning-level figures to be confirmed with City traffic engineering staff.

The most significant issue is the age of the traffic study numbers. However, as there has been no major change or construction in the area since the study was conducted, it is difficult to argue that there is a change in the baseline condition. Since LOS is no longer a CEQA topic, there is flexibility. However, if the data was used in OTHER studies not related to traffic (i.e. noise and AQ), you will have to ask those experts to opine on the age of the data.

I will contact David this week to set up a meeting to go through these issues and the appeal in detail. Would you like me to repackage the previous memo into a new consolidated response to the notice?
Justin P. Schlaefli, PE TE PTOE
President
Urban Systems Associates, Inc.
8451 Miralani Drive, Suite A
San Diego, CA 92126
619-818-6465
Justin P. Schlaefli, PE TE PTOE
President
Urban Systems Associates, Inc.
8451 Miralani Drive, Suite A
San Diego, CA 92126
619-818-6465
EXHIBIT 8
1 From: Isaac Etchamendy <[email protected]>
Date: March 5, 2024 at 5:35:53 PM PST
To: Justin Schlaefli <[email protected]>
Subject: FW: Lanikai- Woodward and Mission
Justin,
Thanks for sending this over. I think I more fully understand how you are approaching this and can provide you a bit more insight. While the FHWA guidance provides valuable insights, it's essential to recognize that every intersection presents unique challenges and opportunities. In the case of Woodward and Mission, I want reiterate that the use of striping elsewhere is not a justification for its use here. So while I appreciate the images and other locations you have submitted, it is critical that we focus on discussing the specifics of this intersection. Additionally, I can say it appears we may be speaking past one another regarding terminology, so I will begin by speaking of this as a merge removal or reallocation of the right of way versus bulb outs in the context of urban design on parked streets.

First, the FHWA information you provided regards the first round of safer journey information published in their library of countermeasures. While valuable information, it is far from authoritative, having been developed and based on research from the 1990’s. The home page was removed from FHWA about 10 years ago, with these sub pages appearing to never have been removed. Curb extensions and complete street research has been adapted and studied substantially by many other organizations including FHWA, NACTO and CalTrans, to name a few, over the ensuing years. Even within that same catalog of countermeasures, FHWA has identified curb extensions for intersectional use for safety countermeasures.

Regardless, I do understand your position in calling out the parking lane, which does not exist on Mission, thus my recommendation that we not refer to this work in terms of a curb extension if a change in language would facilitate our conversation. So going from that to something a bit more context sensitive, I would like to call attention to the lane merge that exists fronting your project. That lane merge is not consistent with current design requirements of the HDM. As a result, we have little desire to keep it, even as some type of an acceleration lane, given its insufficient length. Thus, we have contemplated a reallocation of the localized right-of-way along Mission to push the curb line south and establishing a bus bay. This reallocation of existing right-of-way to remove a substandard merge lane helps towards supporting this road as a complete street. Striving towards complete streets is mandated by our General Plan Mobility Element Policy M-1.7 as well as being supported by the General Plans Mode preferences for Mission Road.

Also, considering that the future proposed project will bring numerous residents that may not have the ability to drive and may need to utilize public transit directly across the street, reduction of crossing length will reduce time of ped signal cycles and interference with throughput of traffic along the mainline of Mission Road.
2 Recently, Caltrans announced their new Contextual Design Guidance for Complete Streets (DIB-94). The reallocation of right-of-way is supported by this latest design bulletin as well as its references. As the proposed curb line adjustment towards the south does not infringe on existing throughput of the roadway, reduces pedestrian crossing length, improves pedestrian visibility, improves a balance of modes, has a reasonable nexus to the development, is consistent with contemporary complete street guidance documents, removes an unnecessary merge, establishes a protected bus bay, creates longevity through hardened improvements, and facilitates signal operations- I continue to not be in support of your counter proposal. My hope is that we don’t continue to spiral on a solution that the City cannot support moving forward, but rather that we look towards getting your project approved and built. I look forward to you resubmitting your plans with the requested curbline shifted south and establishment of a bus bay consistent with what staff has requested.

ISAAC ETCHAMENDY P.E. | Director of Development Services | City Engineer City of San Marcos | 1 Civic Center Drive, San Marcos CA 92069 T: (760) 744-1050 x3273 | C: (760) 912-9949 | F: (760) 591-4135 [email protected] | www.san-marcos.net

Helpful Links:

Report a Concern | Standard Special Provisions | Bids and RFPs |

From: Justin Schlaefli <[email protected]>
Sent: Wednesday, February 21, 2024 1:15 PM
To: Isaac Etchamendy <[email protected]>
Subject: Lanikai- Woodward and Mission

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Mr. Etchamendy,

My apologies for missing you with my previous email. I realized that I left an "I" off the email when I typed it out.

Thank you very much for your consideration of our proposed improvement at Woodward and Mission. The latest iteration does indeed not deviate from the November proposal. We had some concerns with the City's request for a curb bulb-out which were raised in our previous correspondence. These concerns remain. Only a few of these concerns have to do with cost effectiveness. Our most significant concerns relate to safety for pedestrians and bicyclists.

I will reiterate our concerns related to safety as those are paramount in considering a request such as the City has made in this case. This should build on our previous correspondence and concerns raised. We too are concerned about longevity and efficacy.

In the case for the proposed bulb-out, I refer you to the FHWA guidance from the FHWA safety office which can be found here: (Curb Extensions (dot.gov)). Please note that curb extensions are specifically not warranted in locations such as Woodward and Mission. FHWA states, "Curb extensions are only appropriate where there is an on-street parking lane. Curb extensions must not extend into travel lanes, bicycle lanes or shoulders)". There are several other publications which repeat this guidance and which You don't often get email from [email protected]. Learn why this is important 3 recommend against having a bulb-out or curb extension on high-speed roadways similar to Mission Road. In-fact, there have been court cases which recognize the hazard inherent in such situations where you require pedestrians to encroach into the street on high-speed roadways. This hazard for pedestrians and bicyclists would indicate that a curb extension is not warranted in this situation. Specifically, a car in the right turn trap lane may travel straight through the intersection at high speed and hit a pedestrian on the curb extension where the new signal pole would need to be placed to meet ADA requirements for proximity to a crosswalk. Putting the pedestrian out on a curb extension which is not mirrored on the near side of the street and which is at the end of the extension for a trap lane on a high-speed roadway such as Mission is a clear potential hazard and a significant design concern. Similarly, eliminating the shoulder and pushing bicyclists further into the street at this location can increase the hazard and "pinch" bicyclists. These concerns are why FHWA specifically does not recommend curb extensions in similar situations.

A similar situation exists on Railroad Canyon Road as shown below. This striping was created in the past five years to improve the existing situation where a lane was trapped without a corresponding visual queue on the far side of the intersection. This is proper design as shown in other examples in San Marcos.

I have also attached several other examples found where the curb line is kept but striping is either left for a wide shoulder or there is alternatively colored pavement or striping which is implemented to support bus stops and trap lanes in similar situations. Please note that this situation is distinguished from an actual turn pocket. If the development on the east side of the intersection had created an actual turn pocket instead of trapping a through lane, this may be a different situation. However, that is not the case. In our case, we have a thru lane which is trapped at the intersection. Traveling at high speed, a vehicle could go through the intersection, jump the curb and hit signal equipment, bikes or pedestrians on the far side. This is an alignment issue combined with the high speed of Mission which should be considered.

I strongly recommend not resetting the curb line from a situation which has been present for many years in the past. I believe there are ample examples of a striping solution in such a situation (including Barham in the City of San Marcos and most applicably, Railroad Canyon in Canyon Lake). This solution is not only the safest but it follows FHWA guidance in this situation and eliminates the need for major signal modifications and drainage/grade changes at the intersection. We refer not only to precedence 4 but also history with similar situations, pedestrian safety concerns, bicycle safety concerns and importantly, FHWA guidance in such a situation. Please notify us if these examples and this information is worth discussion and perhaps consideration of the design alternative to the City request is warranted.

Thank you,

Justin P. Schlaefli, PE TE PTOE
President
Urban Systems Associates, Inc.
8451 Miralani Drive, Suite A
San Diego, CA 92126
619-818-6465

EXHIBIT 9

EXHIBIT 10
Lanikai Senior Residential Apartments
Draft Initial Study/ Mitigated Negative Declaration
GPA17-0003 / SP17-0004/ MFSDP19-0001

Prepared For:

City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
Contact: Chris Garcia, Senior Planner

Prepared By:

Sophia Mitchell & Associates
PO BOX 1700
Gualala, CA 95445
Contact: Sophia Habl Mitchell

April 2026

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 i

TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................. i LIST OF TABLES ......................................................................................................................................... ii LIST OF FIGURES ...................................................................................................................................... iii LIST OF APPENDICES ............................................................................................................................... iii

1.0 Introduction ............................................................................................................................ 1

2.0 Draft Mitigated Negative Declaration ...................................................................................... 2

3.0 Project Description .................................................................................................................. 3

4.0 Initial Study Checklist ............................................................................................................ 16

4.1 Aesthetics .................................................................................................................................... 16

4.2 Agriculture and Forestry Resources ............................................................................................ 19

4.3 Air Quality .................................................................................................................................... 21

4.4 Biological Resources .................................................................................................................... 29

4.5 Cultural Resources ....................................................................................................................... 50

4.6 Energy .......................................................................................................................................... 58

4.7 Geology and Soils ........................................................................................................................ 60

4.8 Greenhouse Gas Emissions ......................................................................................................... 64

4.9 Hazards and Hazardous Materials ............................................................................................... 69

4.10 Hydrology and Water Quality ...................................................................................................... 74

4.11 Land Use and Planning ................................................................................................................ 80

4.12 Mineral Resources ....................................................................................................................... 96

4.13 Noise 96

4.14 Population and Housing ............................................................................................................ 110

4.15 Public Services ........................................................................................................................... 111

4.16 Recreation ................................................................................................................................. 113

4.17 Transportation ........................................................................................................................... 114

4.18 Tribal Cultural Resources........................................................................................................... 119

4.19 Utilities and Services Systems ................................................................................................... 121

4.20 Wildfire ...................................................................................................................................... 127

4.21 Mandatory Findings of Significance .......................................................................................... 128

5.0 Preparers ............................................................................................................................. 131

6.0 References ........................................................................................................................... 133

7.0 Mitigation Monitoring and Reporting Program .................................................................... 136

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 ii

LIST OF TABLES
Table 1. Project Design Features ................................................................................................................ 12 Table 2. Attainment Status of Criteria Pollutants in San Diego Air Basin ................................................... 22 Table 3. Screening-Level Thresholds for Criteria Pollutants ....................................................................... 23 Table 4. Construction Emissions (lbs/day) .................................................................................................. 24 Table 5. Operations Emissions (lbs/day) ..................................................................................................... 25 Table 6. Intersections LOS E or Worse ........................................................................................................ 26 Table 7. Expected Carbon Monoxide Hot Spot Concentration Levels ........................................................ 27 Table 8. Existing Vegetation Communities/Land Use ................................................................................. 37 Table 9. Impacts to Vegetation Communities/Habitat ............................................................................... 39 Table 10. Proposed Project Construction-Related GHG Emissions (MT/Year) ........................................... 67 Table 11. Proposed Project Operational Emissions Summary (MT/Year) .................................................. 67 Table 12. General Plan Buildout Scenario Construction-Related GHG Emissions (MT/Year) ..................... 68 Table 13. General Plan Buildout Scenario Operational Emissions Summary (MT/Year) ............................ 68 Table 14. Project Trip Generation ............................................................................................................... 82 Table 15. Existing Roadway Segment LOS .................................................................................................. 83 Table 16. Existing Intersection LOS ............................................................................................................. 84 Table 17. Existing + Project Roadway Segments LOS .................................................................................. 84 Table 18. Existing + Project Intersections LOS ............................................................................................ 85 Table 19. Existing and Existing Plus Project Intersection Comparison ....................................................... 87 Table 20. Near Term Without Project Roadway Segments LOS ................................................................. 86 Table 21. Near Term Without Project Intersections LOS ............................................................................ 88 Table 22. Near Term + Project Roadway Segments LOS ............................................................................. 88 Table 23. Near Term + Project Intersections LOS ....................................................................................... 89 Table 24. Near Term and Near Term Plus Project Intersection Comparison .............................................. 91 Table 25. Horizon Year 2035 Without Project Roadway Segments ............................................................ 92 Table 26. Horizon Year 2035 Without Project Intersections ...................................................................... 92 Table 27. Horizon Year 2035 + Project Roadway Segments ....................................................................... 93 Table 28. Horizon Year 2035 + Project Intersections .................................................................................. 93 Table 29. Horizon Year 2035 and Horizon Year 2035 Plus Project Intersection Comparison ..................... 95 Table 30. Construction Noise Levels ........................................................................................................... 99 Table 31. Measured Ambient Noise Levels ............................................................................................... 101 Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 iii
Table 32. Future Traffic Parameters ......................................................................................................... 101 Table 33. Combined Future Exterior Noise Levels (Ground Floor) ........................................................... 103 Table 34. Combined Future Exterior Noise Levels (Upper Floors) ............................................................ 103 Table 35. Existing Noise Levels .................................................................................................................. 106 Table 36. Existing + Project Noise Levels .................................................................................................. 106 Table 37. Existing vs. Existing + Project Noise Levels ................................................................................ 107 Table 38. Existing + Project + Cumulative Noise Levels ............................................................................ 108 Table 39. Existing vs. Existing + Project + Cumulative Noise Levels .......................................................... 108 Table 40. Vibration Levels from Construction Activities (Nearest Receptors) ......................................... 109 Table 41. Estimated Water Demand ......................................................................................................... 122 Table 42. Existing Reservoir Storage Capacity and Requirements............................................................ 123 Table 43. Estimated Wastewater Flows .................................................................................................... 123

LIST OF FIGURES
Figure 1. Project Vicinity ............................................................................................................................... 4 Figure 2. Project Site ..................................................................................................................................... 5 Figure 3. Site Plan .......................................................................................................................................... 6 Figure 4a. Exterior Elevations - South and West ........................................................................................... 9 Figure 4b. Exterior Elevations - North and East .......................................................................................... 10 Figure 5. Vegetation and Sensitive Species on the Project Site .................................................................. 32 Figure 6. Vegetation Impacts ...................................................................................................................... 41 Figure 7. Vegetation Impacts ...................................................................................................................... 47 Figure 7. Ambient Monitoring Location .................................................................................................... 100 Figure 8. Modeled Receptor Locations ..................................................................................................... 102 Figure 9. Patio and Balcony Mitigation Locations ..................................................................................... 105

LIST OF APPENDICES
Appendix A.1 Project Plans
Appendix A.2 Landscape Plan
Appendix B Air Quality Report
Appendix C Biological Resources Report
Appendix D Cultural Resources Report
Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 iv
Appendix E Geotechnical Investigation
Appendix F.1 Greenhouse Gas Report
Appendix F.2 CAP Consistency Review Checklist
Appendix G Phase 1 Environmental Site Assessment
Appendix H Stormwater Quality Management Plan
Appendix I Noise Report
Appendix J.1 Traffic Impact Study
Appendix J.2 Vehicle Miles Traveled Analysis
Appendix J.3 Vehicle Miles Traveled Analysis - Supplemental Appendix J.4 Sight Distance Memorandum
Appendix J.5 Driveway Queue Analysis Memorandum
Appendix K Water/Sewer Study

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 1 1.0 Introduction
This Initial Study/Mitigated Negative Declaration (IS/MND) has been prepared in accordance with relevant provisions of the California Environmental Quality Act (CEQA) of 1970, as amended, and the CEQA Guidelines, as revised. This IS/MND evaluates the environmental effects of the Lanikai Senior Residential Apartments Project (project).

The IS/MND includes the following components:
• A Draft MND and the formal findings made by the City of San Marcos (City) that the project would not result in any significant effects on the environment, as identified in the CEQA Initial Study Checklist (IS Checklist).
• A detailed project description.
• The CEQA IS Checklist, which evaluates the potential for significant environmental impacts from the project, is adapted from Appendix G of the CEQA Guidelines. The project is evaluated in 20 environmental issue categories to determine whether the project’s environmental impacts would be significant in any category. Brief discussions are provided that further substantiate the project’s anticipated environmental impacts in each category.

Because the project fits into the definition of a “project” under Public Resources Code Section 21065 requiring discretionary approvals by the City, and because it could result in a significant effect on the environment, the project is subject to CEQA review.

The IS Checklist was prepared to determine the appropriate environmental document to satisfy CEQA requirements: an Environmental Impact Report (EIR), a Mitigated Negative Declaration (MND), or a Negative Declaration (ND). The analysis in this IS Checklist supports the conclusion that the project would not result in significant environmental impacts with incorporation of mitigation measures . The City Council will consider any comments received on the IS/MND when deciding whether to adopt the IS/MND.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 2 2.0 Draft Mitigated Negative Declaration
Project Name: Lanikai Senior Residential Apartments
Project Location: The 3.96-acre project site is located in the City of San Marcos in North San Diego County.

The Assessor Parcel Number (APN) is 220 -063-04. The project site is located on the northwest corner of E. Mission Road and Woodward Street. Specifically, the project site is bounded by Woodward Street on the east, E. Mission Road on the south, and undeveloped land on the north. The project site is currently vacant. Vegetation on the project site includes Diegan coastal sage scrub, Baccharis scrub, southern cottonwood-willow riparian forest , and non -native grassland. There are also areas categorized as disturbed and developed on the project site (Helix 2026). Twin Oaks Valley Creek runs along the western portion of the project site. The project site is relatively flat with elevations of approximately 571 to 611 feet above mean sea level (amsl). Per the Federal Emergency Management Agency (FEMA), portions of the project site are located within Zone X and Zone AE and a regulatory floodway. Proposed grading activities would raise building pad elevations above the flood zone.

Project Description: The project applicant is requesting approval of a General Plan Amendment, Specific Plan Amendment, and Multi-Family Site Development Plan to construct a four-story 115-unit senior (age 55+) residential development and associated infrastructure improvements to support the development.

Access to the project site would be via Woodward Street and E. Mission Road. The project w ould include a single phase of construction. The project requires 2,825 cubic yards (cy) of cut and 26,079 cy of fill, for a net import of 23,254 cy. This additional material is required to raise the site above base flood elevations.

Findings: Pursuant to the provisions of CEQA (Public Resources Code, Section 21000 et seq.) and based on information contained in the attached IS Checklist, the City of San Marcos has determined that the project would not have a significant effect on the environment.

___________________________________ ___________________ Signature of Lead Agency Representative Date

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 3 3.0 Project Description

1. Project Title:

Lanikai Senior Residential Apartments

2. Lead Agency:

City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069

3. Contact Person and Phone Number:

Chris Garcia, Senior Planner
760-744-1050 ext. 3237
[email protected]

4. Project Location: The 3.96 -acre site is located at the northwest corner of E. Mission Road and Woodward Street in the City of San Marcos (Figure 1 and Figure 2).

5. Project Applicant/Sponsor:

Lanikai Corporation
P.O. Box 372
Santa Ynez, CA 93460

6. General Plan Designation:

Specific Plan Area (SPA)

7. Zoning:

Specific Plan Area (SPA)

8. Description of Project: The project applicant is requesting approval of a General Plan Amendment (GPA17-0003), Specific Plan Amendment (SP17 -0004) and a Multi-Family Site Development Plan (MFSDP19-0001) to construct a four -story 115-unit senior residential development. The General Plan Amendment would be for a graphical change to modify graphics in the General Plan Land Use Element including Figure 2-3 (Specific Plan Areas) and Figure 2-5 (Land Use Plan). The Specific Plan Amendment would amend the Heart of the City Specific Plan (HOCSP) to allow for a Senior Residential use within the HOCSP. A Multi-Family Site Development Plan would be required to construct 115 senior residential units and address the details of the architectural style, building elevation, fencing, and landscaping, among other criteria, within the development (Figure 3).

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 4 Figure 1. Project Vicinity

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 5 Figure 2. Project Site

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 6 Figure 3. Site Plan

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 7 Project Components
The project proposes to construct a 115 -unit senior residential development with a proposed density of 29 units per acre. The four-story building would have a total of 106,300 square feet ( s.f.) with 27,700 s.f. on the first floor, and a 26,200 s.f. on the second, third and fourth floors. The project plans are included as Appendix A.1.

The project includes a mix of residential unit sizes including 21 studio units, 72 one-bedroom units, and 22 two-bedroom units. Unit sizes range from 435 s.f . for a studio and up to 990 s.f . for a two -bedroom unit. All of the residential units would have either a ground floor patio or a balcony. There are also interior community spaces in the project design including a library/TV room, fitness room, and a great room with kitchen and storage. Exterior community spaces include a patio area with lap pool, jacuzzi, and barbeque.

Open Space/Natural Areas – The project has been designed to avoid the riparian area associated with Twin Oaks Valley Creek and the associated sensitive vegetation within the western portion of the project site. The project incorporates a buffer of at least 12 feet between the project development and the existing California Department of Fish and Wildlife (CDFW) jurisdictional riparian canopy. A buffer ranging from 27 feet to over 100 feet would be maintained between the project impact footprint and United States Army Corps of Engineers (USACE) and Regional Water Quality Control Board (RWQCB) jurisdictional resources.

Architectural Design - The building would be four stories and 50 feet in height. Architectural detailing/enhancements are incorporated into the project design to break up the bulk and scale of the building. The project proposes the use of a composite tile room, fiber cement siding, stone veneer, and wood rafters and trim detailing. Complimentary paint colors have also been incorporated into the project design to provide visual interest. Figures 4a and 4b provide an overview of the exterior elevations and overall architectural concept.

Landscape Concept Plan – The proposed landscape plan includes a mix of trees, shrubs, vines and groundcover and the plant selection emphasizes very low, low and moderate water use species. Proposed tree species included standard arbutus, red crape myrtle, California sycamore, Brisbane box and pink dawn chitalpa. The project would be irrigated with potable water and would comply with the City’s Model Water Efficient Landscape Ordinance (WELO). Landscaping would cover 40,120 s.f. (29 percent) of the project site. The landscape concept plan, including the proposed plant selection, is included as Appendix A.2.

Project Access and Improvements – Access to the project site would be from two 30-foot-wide driveways, one on Woodward Street and one on E. Mission Road. The driveway on Woodward Street would allow full access, and the driveway on E. Mission Road would be right-in/right-out access only. The project would restripe a portion of Woodward Street to provide for a left turn into the project site.

Parking – The project design includes 13 5 parking spaces. According to the HOCSP, parking for Senior Residential calls for one parking space per unit for projects located within a half -mile of a major transit stop, including visitor spaces. Since the project is within a half -mile of a major transit stop (San Marcos Civic Center SPRINTER station), the project would be required to provide 115 spaces. As currently designed, the project is providing 20 additional parking spaces beyond the minimum per the HOCSP.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 8 Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 9 Figure 4a. Exterior Elevations - South and West

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 10 Figure 4b. Exterior Elevations - North and East

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 11 Utility Improvements – The project site is within the Vallecitos Water District (VWD) water and sewer service boundaries and VWD has indicated they can serve the project. The domestic water and fire water connections would be to the existing VWD water main on E. Mission Road. Sewer connection would be to the existing sewer line that also runs along E. Mission Road. No upsizing of off-site water or sewer lines or facilities would be needed to serve the project. The project would pay Water Capital Facility Fees and Waste Water Capital Facility Fees consistent with VWD Ordinance No. 175 and No. 176.

The project would receive electric service from San Diego Gas & Electric (SDG&E). One existing power pole on Woodward Street would be relocated and three would be removed. Dry utilities along the Woodward Street project frontage would be undergrounded as part of the project. The project will install rooftop photovoltaic solar.

Off-site Improvements - The project would restripe a portion of Woodward Street to provide for a left turn into the project . The project would also expand the E. Mission Road right-of-way by approximately four feet along the project frontage, remove an acceleration lane and add a painted buffered bicycle lane.

Stormwater Management –The project site does not currently have an underground storm drain system.

Under current conditions, the site surface drains from the east to west towards the existing culvert box that drains to San Marcos Creek. In the developed condition, site surface drains would drain from east to west towards a 48-inch x 48 -inch inlet that captures the runoff which an 18-inch PVC underground pipe would then direct to the proposed underground 45 -inch chambers. The storm drain system in the landscape areas around the building would also direct runoff to the chambers. Additionally, the concrete brow ditch on top of the proposed retaining wall would capture the r unoff produced on the slopes and direct it to the chambers. At the proposed driveway on E. Mission Road the project design incorporates a surface of permeable pavers as pollutant control and hydromodification BMP which allows percolation through void spaces into surface layers.

The project owner w ould be responsible for the maintenance of the underground detention and infiltration facility.

Grading – Grading and earthwork activity would be required to prepare the site for development. Based upon the proposed grading concept, the project requires 2,825 cubic yards (cy) of cut and 26,079 cy of fill, for a net import of 23,254 cy. Soils import is expected to take approximately 55 days . Assuming a 20- cy hauling truck, this results in approximately 21 truck trips per day for soils import.

The project has been designed to be elevated above the 100 -year storm event base flow elevation . The project applicant would be required to process a full Conditional Letter of Map Revision/Letter of Map Revision (CLOMR/LOMR) application through FEMA.

Construction Schedule - Assuming receipt of all necessary approvals, construction is expected to start in 2027 and would have an opening date of 2028.

Project Design Features - The project includes design features which would reduce potential impacts and the project would adhere to applicable regulatory requirements, as identified in Table 1.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 12 Table 1. Project Design Features
Aesthetics
• Implementation of the landscape plan.

Air Quality
• Compliance with SDACPD Rule 55 (Fugitive Dust) and Rule 67.0 (Architectural Coatings).
• All heavy diesel construction equipment shall be rated Tier IV or better.

Greenhouse Gas
• Installation of seven EV parking stalls.
• Implementation of the Transportation Demand Management Plan. • Electric heat pump water heaters and/or electric tanks would be installed. • Installation of a photovoltaic system with a minimum capacity of two watts per square foot of gross floor area.
• Compliance with the City’s Water Efficient Landscape Ordinance (WELO). • Shade trees are included as part of the project’s landscape plan.

Hazards
• 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.

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:
• Maintaining natural drainage pathways and hydrologic features. • Conserving natural areas, soils, and vegetation.
• Minimizing impervious areas.
• Minimizing soil compaction.
• Runoff collection.
• 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

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 13 • Compliance with Section 17.32.180 of the San Marcos Municipal Code that limits grading activities to between 7:00 AM and 4:30 PM Monday through Friday.

Grading extraction or related earth moving is not allowed in the City on weekends or holidays.
• Compliance with Chapter 10.24 of the San Marcos Municipal Code which limits construction activities to between 7:00 AM and 6:00 PM Monday through Friday and between 8:00 AM or after 5:00 PM on Saturdays.
• All construction equipment shall be properly fitted with mufflers and all staging and maintenance shall 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 and Recreation
• 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). • Payment of Public Facility Fees, a portion of which go towards park development.

Transportation
• Restripe a portion of Woodward Street to provide for a left turn into the project. • Expand the E. Mission Road right-of-way by approximately four feet along the project frontage, remove an acceleration land and add a painted buffered bicycle lane. Implementation of the project’s Transportation Demand Management Plan.
• 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).

Utilities and Services Systems - Water and Wastewater
• Pay Water Capital Facility Fees per VWD Ordinance No. 175. • Pay Wastewater Capital Facility Fees per VWD Ordinance No. 176.

9. Surrounding Land Uses and Project Setting: The project site is bounded by E. Mission Road to the south, Woodward Street to the east, Twin Oaks Creek to the west , and undeveloped land to the north and west. Zoning in the project vicinity includes a mix of Specific Plan Area (SPA) associated

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 14 with the Heart of the City Specific Plan, Public -Institution (PI), and Commercial (C). Development in the project area includes a multi -family residential project to the east (Mission 316 West) and to the south; across E. Mission Road is the San Marcos Civic Center SPRINTER station and San Marcos Civic Center. To the west of the project site, is the Twin Oaks Valley Creek and an undeveloped parcel that was approved for the Creekside project, an assisted living and memory care facility. Northeast of the project site, on the opposite side of Woodward Street is an undeveloped parcel that is approved for development for a 46-unit residential project (Wooward 46).

10. Other Public Agencies Whose Approval is Required:
• Federal Emergency Management Agency (FEMA)
• United States Fish and Wildlife Service (USFWS)
• Vallecitos Water District

11. Have California Native American tribes traditionally or culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc .? The City sent out AB 52 letters and two Tribes requested consultation (Rincon Band and San Luis Rey Band). The City is currently in consultation with these Tribes.

12. Summary of Environmental Effects Potentially Affected The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “ Mitigated to Below a Level of Significance ,” as indicated by the checklist on the following pages.
□ Aesthetics □ Land Use and Planning
□ Agriculture and Forestry Resources □ Mineral Resources □ Air Quality X Noise
X Biological Resources □ Population and Housing
X Cultural Resources □ Public Services
□ Energy □ Recreation
X Geology and Soils □ Transportation
□ Greenhouse Gas Emissions X Tribal Cultural Resources □ Hazards and Hazardous Materials □ Utilities and Service Systems □ Hydrology and Water Quality □ Wildfire
X Mandatory Findings of Significance

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 15 DETERMINATION:

On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect: 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 16 4.0 Initial Study Checklist
The following Initial Study checklist provides a preliminary analysis to determine if a project may have a significant effect on the environment and aids in determining what type of environmental document to prepare.

4.1 Aesthetics
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect on a scenic
vista?
X
b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
X
c) 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 points). If the project
is in an urbanized area, would the project
conflict with the applicable zoning and other
regulations governing scenic quality?
X
d) Create a new source of substantial light or glare,
which would adversely affect day or nighttime
views in the area?
X
a) Have a substantial adverse effect on a scenic vista? Less than Significant Impact A scenic vista is typically defined as a panoramic view or vista from an identified view/vista point, public road, public trails, public recreational areas, or scenic highways. The City’s General Plan does not identify any designated scenic vistas; however, the General Plan aims to protect the City’s scenic resources such as the San Marcos, Merriam, and Double Peak Mountains, creek corridors, mature trees, rock outcroppings, and ocean views (City of San Marcos 2012a).

The project site is undeveloped. The site includes a mix of Diegan coastal sage scrub, baccharis scrub, southern riparian forest, nonnative grassland, and disturbed/developed areas (Helix 2026 ). The site is generally flat. The project site is not identified as a protected scenic vista on any local plans. The proposed development would be surrounded by existing development including multi-family residential to the east,

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 17 San Marcos SPRINTER rail station and the San Marcos Civic Center to the south, and a future assisted living and memory care facility to the west, on the opposite side of the creek.

While the project site is not identified as a scenic vista in the San Marcos General Plan, the General Plan does include policies regarding the protection of scenic resources (City of San Marcos 2012a) . Below is a summary of the proposed project’s consistency with applicable scenic resource preservation policies.

Policy COS-3.1 of the Conservation and Open Space Element of the City’s General Plan calls for the preservation of 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 (City of San Marcos 2012a) . The project site is not located on or adjacent to any of these landforms.

Views of the project site could potentially be afforded from these prominent landforms, as they are at a higher elevation than the site and allow for broad and expansive views of the lower elevation areas across the City . Although views of the project site may be possible, the proposed project would blend with existing development in the project vicinity and appear as part of the overall fabric of the developed landscape in the Richland neighborhood . The project would not substantially change views from these prominent landforms. Further, the project would not result in development within any of the areas listed in this policy, therefore the proposed project would be consistent with this policy.

Policy COS-3.2 encourages high -quality architectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character of San Marcos (City of San Marcos 2012a) . The project is not located on a prominent hillside, ridgeline, canyon, or view corridor.

The project includes a landscape plan that includes a mix of trees, shrubs, vines, and groundcover. The project would plant street trees along Woodward Street and E. Mission Road. Additional landscaping in the form of trees, shrubs and groundcover is proposed along the boundaries of the site as well as within the development. The project would be consistent with Policy COS-3.2.

Additionally, the City has a Ridgeline Protection and Management Overlay Zone to protect natural viewsheds and unique natural resources, minimize physical impacts to ridgelines, and to establish innovative sensitive architectures standards. The project site is not located in the Ridgeline Protection and Management Overlay Zone. Further, the project site does not include any primary or secondary ridgelines, as identified in Figure 4-5 of the Conservation and Open Element of the General Plan (City of San Marcos 2012a). Therefore, the project’s impact scenic vistas would be less than significant. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway? No Impact The project site is located approximately 0.4 miles north of State Route 78 (SR- 78). A portion of SR -78 is recognized as a Scenic Highway by Caltrans; however, that portion is not in the project vicinity. The portion identified as a Scenic Highway is approximately 50 miles east of the project site near Anza Borrego (Caltrans 2020).

At a local level, SR-78 is designated by the City as a view corridor. The highway corridor provides views of the Merriam Mountains, Mount Whitney, and Double Peak. The project would not impact views to these peaks from SR-78 since there is intervening deve lopment between the project and SR -78. Development

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 18 of the proposed project is not proposed on any area identified as a primary or secondary ridgeline in the City’s Ridgeline Protection and Management Overlay Zone.

Per the cultural resources report prepared for the project the project site does not support any historic buildings (ASM 2023). The site does not support any significant trees, rock outcroppings, or historic buildings as identified in or protected by the City’s General Plan. In summary, the project would not damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. No impact would occur.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surrounding? (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 the applicable zoning and other regulations governing scenic quality ? Less than Significant Impact
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 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. 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 is what applies to the project.

A significant impact would occur if the project conflicts with the applicable zoning and other regulations that govern scenic quality. The project site is zoned Specific Plan Area (SPA) and is associated with the Heart of the City Specific Plan. The project includes a Specific Plan Amendment to allow for Senior Residential Use on the project site. With approval of the amendment, the project would not conflict with the applicable zoning for the site . The project has been designed to meet grading requirements. As detailed under the first aesthetics threshold [4.1( a)], the project would not conflict with any regulations that govern scenic quality and impacts would be less than significant. d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area? Less than Significant Impact
Lighting
Lighting in the project vicinity is associated with roadway lighting along E. M ission Road and Woodward Street and with development in the project vicinity. Development of the proposed project would introduce lighting to a site that is currently undeveloped and has no existing source of lighting.

All lighting within the proposed project would be designed to minimize glare and light pollution and would comply with the City’s Municipal Code Section 20.300.080, Light and Glare Standards, and any other applicable sections . Compliance with these requirements would minimize and restrict nighttime light

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 19 pollution and light trespass on adjacent properties . Thus, new sources of day or nighttime lighting associated with the proposed project would not be considered substantial . Impacts associated with project lighting would be less than significant.

Glare
Glare typically occurs from reflective building materials and finishes, as well as reflective lighting structures and metallic surfaces. The project does not propose to use any materials or finishes that would be glare-inducing. The project proposes the use of a composite tile room, fiber cement siding, stone veneer, and wood rafters and trim detailing. Reflective materials are not proposed. Therefore, the project does not propose any features that would be characterized as creating a substantial new source of glare that would adversely affect daytime or nighttime views in the area. Impacts would be less than significant.

4.2 Agriculture and Forestry Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to non-
agricultural use?
X
b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract?
X
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g)), timberland
(as defined in Public Resources Code Section
4526), or timberland zoned Timberland
Production (as defined by Government Code
Section 51104(g))?
X
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
X
e) Involve other changes in the existing
environment that, due to their location or
nature, could result in conversion of Farmland,
to non-agricultural use or conversion of forest
land to non-forest use?
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 20 a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact The Farmland Mapping and Monitoring Program (FMMP) of the California Department of Conservation produces maps and statistical data used for analyzing impacts on California’s agricultural resources .

Agricultural land is rated according to soil quality and irrigation status; the best quality land is called Prime Farmland. The maps are updated every two years with the use of a computer mapping system, aerial imagery, public review, and field reconnaiss ance. The project site is not mapped as prime farmland, unique farmland, or farmland of statewide importance, as determined by the Farmland Mapping and Monitoring Program, as shown on Figure 4 -4 (Agricultural Areas) in the San Marcos General Plan (San Marcos 2012 a). Therefore, the project would not result in the conversion of prime farmland, unique farmland, or farmland of statewide importance. No impact is identified. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact The project site has a General Plan designation of Specific Plan Area (SPA) and a zoning designation of SPA (Specific Plan Area). The project site does not support zoning for an agricultural use.

The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space use. In return, landowners receive property tax assessments which are much lower than normal because they are based upon farming and open space uses as opposed to full market value. The project site is not located within a Williamson Act contract area. Therefore, the project would not conflict with existing zoning for agricultural use or a Williamson Act contract. No impact is identified.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined in Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)) ? No Impact
The project site has a General Plan designation of Specific Plan Area (SPA) and a zoning designation of SPA (Specific Plan Area). A General Plan Amendment is proposed for a graphical change to modify graphics in the General Plan Land Use Element including Figure 2-3 – Specific Plan Areas and Figure 2 -5 – Land Use Plan. The project proposes a Specific Plan Amendment to allow for a Senior Residential use within the Heart of the City Specific Plan. Therefore, the proposed project is not located in an area that is zoned for forest land, timber land or for timber production. Implementation of the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. No impact is identified.
d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact The project site does not support forests, nor is there any forest land adjacent to the project site. The project site is dominated by Diegan coastal sage scrub and baccharis scrub with riparian vegetation associated with Twin Oaks Valley Creek. Therefore, the proposed project would not result in the loss of forest land or the conversion of forest land to non-forest use. No impact is identified for this issue area.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 21 e) Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non- forest use? No Impact
There are no other aspects of the proposed project that would involve other changes in the existing environment that, d ue to its location or nature, could result in a conversion of Farmland to non- agricultural use or conversion of forest land to non-forest use. As discussed in threshold 4.2(c) and 4.2(d), above, the project site is not adjacent to any forest lands or timberlands. As discussed in thresholds 4.2.a and 4.2.b, above, the project vicinity is primarily developed. The proposed project would not directly or indirectly impact any existing agricultural activities. No impact is identified for this issue area.

4.3 Air Quality
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct implementation of the
applicable air quality plan?
X
b) Result in a cumulatively considerable net increase
of any criteria pollutant for which the project
region is non -attainment under an applicable
federal or state ambient air quality standard?
X
c) Expose sensitive receptors to substantial
pollutant concentrations?
X
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial
number of people?
X
Air quality modeling was conducted for the project by Ldn Consulting (LDN) (20 24a) and is included as Appendix B of this document.
a) Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact
The proposed project is related to the Regional Air Quality Strategy (RAQS) and/or State Implementation Plan (SIP) through the land use and growth assumptions that are incorporated into the air quality planning process. Both air quality plans contain strat egies for the region to attain and maintain the ambient air quality standards. Projects that are consistent with existing General Plan documents and subsequent San Diego Association of Government ( SANDAG) population projections, which are used to develop air emissions budgets for air quality planning and attainment demonstrations, would be consistent with the San Diego Air Basin’s (SDAB) air quality plans, including the RAQS and SIP. Provided a project proposes the same or less development as accounted for in the General Plan, and provided the project is in compliance

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 22 with applicable Rules and Regulations adopted by the San Diego Air Pollution Control District (SDAPCD) through their air quality planning process, 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 a zoning designation of Specific Plan Area (SPA). The project applicant is requesting approval of a General Plan Amendment (GPA17-0003), Specific Plan Amendment (SP17-0004) and a Multi -Family Site Development Plan (MFSDP19-0001) to construct a four-story 115-unit senior residential development. The General Plan Amendment would be for a graphical change to modify graphics in the General Plan Land Use Element including Figure 2-3 (Specific Plan Areas) and Figure 2 -5 (Land Use Plan). The Specific Plan Amendment would amend the Heart of the City Specific Plan to allow for a Senior Residential use within the Heart of the City Specific Plan. A Multi -Family Site Development Plan would be required to construct 115 senior residential units and address the details of the architectural style, building elevation, fencing, and landscaping, among other criteria, within the development.

The existing land use of the project site is Commercial, as identified in the HOCSP. The project is proposing an amendment to the HOCSP to change the site to Senior Residential. Commercial uses within the HOCSP have a maximum lot coverage of 35%. The project is proposing a lot coverage of approximately 16%, so the project would be less intense than would otherwise be allowed within the approved Specific Plan and General Pla n and the project would be considered to be consistent with the SDAB air quality plans, including the RAQS and SIP. Therefore, the project would not conflict with or obstruct implementation of the applicable air quality plan. Impacts would be less than significant.

Criteria Pollutant Analysis
Air quality emissions were calculated as part of the air quality study prepared by LDN (202 4a). Table 2 shows the state and federal attainment status for criteria pollutants in the SDAB. As shown, the SDAB is a nonattainment area for the state and federal O3 standards and for the state PM10 and PM2.5 standards.

The SDAPCD establishes significance criteria for air quality emissions through Rule 20.2. The screening thresholds are shown in Table 3 . These criteria can be used as numeric indicators that demonstrate whether a project’s emissions would result in a significant impact to air quality. Any project with daily construction- or operation-related emissions that exceed any of the following screening-level thresholds would be considered to have a significant air quality impact and modeling would be required to demonstrate that the project’s total air quality impacts result in ground -level concentrations that are below State and Federal Ambient Air Quality St andards, including appropriate background levels. For nonattainment pollutants (O
3, with ozone precursors NOx and VOCs, and PM 10), if emissions exceed the thresholds shown below, the project could have the potential to result in a cumulatively considerable net increase in these pollutants.

Table 2. Attainment Status of Criteria Pollutants in San Diego Air Basin Pollutant Federal State
Ozone (8-Hour) Nonattainment Nonattainment
Ozone (1-Hour) Attainment (1) Nonattainment
Carbon Monoxide (CO) Attainment Attainment

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 23 Pollutant Federal State
Particulate Matter−10 microns (PM10) Unclassified (2) Nonattainment Particulate Matter−2.5 microns (PM2.5) Attainment Nonattainment Nitrogen Dioxide (NO2) Attainment Attainment
Sulfur Dioxide (SO2) Attainment Attainment
Lead Attainment Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Visibility No Federal Standard Unclassified
Source: SDAPCD 2020.

Notes: (1) The federal 1 -hour standard of 12 ppm was in effect from 1979 through June 15, 2005 . The revoked standard is referenced 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.

Table 3. Screening-Level Thresholds for Criteria Pollutants Pollutant Total Emissions (lbs per day)
Construction Emissions
Respirable Particulate Matter (PM10) 100
Fine Particulate Matter (PM2.5) 55
Oxides of Nitrogen (NOx) 250
Carbon Monoxide (CO) 550
Volatile Organic Compounds (VOCs)1 75
Reactive Organic Gases (ROG) SCAQMD 75
Operational Emissions
Respirable Particulate Matter (PM10) 100
Fine 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 (VOC) 75
Reactive Organic Gases (ROG) SCAQMD 75
Note: (1) SDAPCD does not have an air quality impact threshold for VOCs. The South Coast Air Quality Management District threshold for the Coachella Valley is used for this analysis.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 24 Construction Emissions
Construction-related emissions for the project would include emissions from site grading, preparation, and paving. Proposed earthwork activities include 2,825 cy of cut and 26,079 cy of fill with a net import of 23,254 cy.

The project would start grading in 20 27 with utility infrastructure and construction to start shortly thereafter. Project occupancy is anticipated in 202 8. The project’s air quality analysis assumed a 2024 construction time, which would actually result in a more conservative air quality analysis. If construction is delayed, emissions could be reduced since moving the start date for project construction later would cause the project to use more modern and cleaner-burning construction equipment and it would be likely that stricter regulations would govern the construction activities.

Consistent with SDAPCD’s fugitive dust rules/fugitive dust control measures outlined in Section 87.426 of the City’s Grading Ordinance, the project would implement fugitive dust control measures during grading, which would include watering the site a minimum of twice daily to control dust, as well as reducing speeds on unpaved surfaces to 15 miles per hour (mph) or less, replacing ground cover in disturbed areas quickly, and reducing dust during loading/unloading of dirt and other materials. The project would also require that all heavy diesel construction equipment be rated Tier IV or better. These requirements have been identified as project design features for the project in Table 1.

Anticipated equipment for project construction includes graders, rubber-tired dozers, excavators, pavers, paving equipment, rollers, cranes, forklifts, generator sets, tractors/loaders/backhoes, welders, and air compressors. Hauling trucks for the import of grading material would also be required. See Table 3.1 of the air quality report (Appendix B of this document ) for a more detailed breakdown of construction equipment quantities and anticipated duration of use.

Table 4 presents the anticipated construction emissions for the project, incorporating the identified project design features.

Table 4. Construction Emissions (lbs/day)
Year ROG NOx CO SO2 PM10
(Total)
PM2.5
(Total)
2024 9.08 16.62 22.55 0.10 15.89 7.50
2025 9.06 3.47 22.36 0.04 1.23 0.34
Screening Level
Thresholds (lbs/day) 75 250 550 250 100 55
Significant Impact? No No No No No No
Source: LDN Consulting, 2024a.

As shown in Table 4, maximum daily emissions would be below the screening level thresholds for all criteria pollutants and construction emissions impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 25 Operational Emissions
The expected operational emissions were calculated and the results are presented in Table 5 . As shown in Table 5, anticipated daily emission in both the summer scenario and the winter scenario are well below the screening thresholds. Therefore, operational emissions would be less than significant.

Table 5. Operations Emissions (lbs/day)
ROG NOx CO SOx PM10 PM2.5
Summer Scenario
Area Source Emission
Estimates

3.17 0.11 9.49 0.00 0.05 0.05
Energy Emission Estimates
Mitigated

0.04 0.32 0.13 0.00 0.03 0.03
Mobile Emission Estimates
Mitigated 1.14 1.06 9.63 0.02 2.36 0.64
Total 4.34 1.48 19.26 0.02 2.44 0.72
Screening Level Thresholds 75 250 550 250 100 55
Significant? No No No No No No
Winter Scenario
Area Source Emission
Estimates

3.17 0.11 9.49 0.00 0.05 0.05
Energy Emission Estimates 0.04 0.32 0.13 0.00 0.03 0.03 Mobile Emission Estimates 1.10 1.14 9.97 0.02 2.36 0.64 Total 4.31 1.57 19.59 0.02 2.44 0.72
Screening Level Thresholds 75 250 550 250 100 55
Significant? No No No No No No
Source: LDN 2024a.

Note: Daily pollutant generation assumes trip distances within CalEEMod.

As shown in Table 5, operational emissions associated with the project would be below the significance thresholds for all criteria pollutants.

Micro-Scale Operational Findings
Air pollutant emissions related to project -generated traffic have the potential to create new, or worsen existing, localized air quality violations with respect to carbon monoxide (CO). These increased carbon monoxide “Hot Spots” are determined through the utilization of the Institute of Transportation Studies (ITS) Transportation Project-Level Carbon Monoxide Protocol.

In the event project traffic adds vehicular trips to an intersection that operates at Level of Service (LOS) E or F, or the addition of project trips re- classify an intersection from an acceptable LOS to LOS E or F, and when total intersection peak-hour trips exceed 3,000 vehicles, it is recommended that projects within the

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 26 County of San Diego conduct a CO “Hot Spot” analysi s. The City of San Marcos also suggests using the County’s screening thresholds to conduct CO hot spot analyses.

The ITS Transportation Project-Level Carbon Monoxide Protocol recommends running the EMFAC model to determine emission rates for the project year as well as conduct dispersion modeling utilizing CALINE to determine worst-case emission concentrations. The EMFAC model is provided as Attachment D to the air quality report (Appendix B of this document).

The project traffic study identified that the intersection of Twin Oaks Valley Road and San Marcos Boulevard currently operates at LOS E for the Existing Condition and would operate at LOS E or worse through Year 2035 (USA 2019). As shown in Table 6, this intersection would operate at LOS F in the AM and PM Peak Hour in the Year 2035. The project would add vehicular trips to this intersection though would not significantly alter the delays at this intersection.

Table 6. Intersection Operating at LOS E or Worse
Intersection Peak Hour Number of peak-hour
Vehicles LOS
Twin Oaks Valley Road /
San Marcos Boulevard
AM 4,854 F
PM 5,422 F
Source: LDN 2024a.

Micro-Scale operations during these conditions show that the proposed project would have a potential to generate CO emissions in excess of the CAAQS. For purposes of this analysis, the CAAQS would be considered the most stringent air quality standard with CO limits of 9 parts per million (PPM) for the one- hour standard and 20 PPM CO for the 8-hour standard and are used within this analysis. Additionally, the CALINE model incorporated the highest 8 -hour and 1-hour air quality data as collected at the Escondido monitoring station, which was 3.1 PPM and 3.8 PPM, respectively.

The CALINE model was set up to show a typical intersection with a north, east, south, and west segment extending a typical 50 meters in every direction. Peak-Hour volumes were taken from the peak -hour turning movements within the proposed project traffic impact study (USA 2019) for the worst -case intersection identified and CALINE was updated accordingly. Sensitive receptors were assumed to be roughly 25 feet from each roadway, which represents a worst-case environment.

The CALINE model results are shown in Attachment E to the air quality report (Appendix B of this document) and Table 7 identifies both the 1 -hour emission concentration predictions and the 8 -hour average after utilizing the carbon dioxide persistence factor of 0.7.

As shown in Table 7, the CO concentrations at the intersection of Twin Oaks Valley Road/San Marcos Boulevard would 3.3 PPM for the one-hour standard and 2.3 PPM for the 8-hour standard. Both of these CO concentrations would be below the respective CAAQS significance threshold and impact would be less than significant. Based on this calculation, since all other remaining intersections have lower traffic volumes, it can be concluded that all other remaining intersections would also have a less than significant impact.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 27 Table 7. Expected Carbon Monoxide Hot Spot Concentration Levels Intersection Vehicles Per Hour Predicted Concentration PPM PM 1 HR 8 HR
Twin Oaks Valley Road/San Marcos
Boulevard (PM)(1) 5,422 3.3 2.3
CAAQS-Significant Thresholds 20 9
Significant? No No
Source: LDN 2024a.

Notes: Emission levels taken from EMFAC 2014
(1) Traffic Volumes obtained from Project Traffic Study (USA 2019) The project would also add trips to the intersections of Woodward Street and E . Mission Road as well as Twin Oaks Valley Road and Borden Road. The intersection of Twin Oaks Valley Road and San Marcos Boulevard would be worst-case and was analyzed for the micro-scale analysis. b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? Less Than Significant Impact
The project would generate air emissions during project construction and operation. As identified above, the SDAB is a non-attainment area for state and federal O 3 standards and for state PM 10 and PM 2.5
standards. Evaluating whether the project could result in a cumulatively considerable impact on air quality relies on both the project’s consistency with the RAQS and the SIP, which address attainment of the O 3 standards, and the potential for the project to result in a cumulatively considerable impact due to particulate emissions.

As part of the RAQS and SIP planning process, the SDAPCD develops an emission inventory, based on projections from SANDAG, of growth in the region as well as on information maintained by the SDAPCD on stationary source emissions within the SDAB. The SDAPCD then uses the emission inventory to conduct airshed modeling, to demonstrate that the SDAB will attain and maintain the O 3 standards. 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.

With regard to emissions of O3 precursors NOx and VOCs during construction, the SIP includes emissions associated with construction in its emissions budget and therefore within its attainment demonstration.

As identified in Table 4, the O
3 precursor emissions associated with project construction are well below the screening level thresholds. Therefore, the project would not result in additional emissions of O 3 precursors above those projected in the attainment demonstration for O 3. The project would therefore not result in a cumulatively considerable impact to O 3 levels within the SDAB. In summary, the project would not result in a cumulatively considerable net increase of O3, PM10, or PM2.5 standards, for which the project region is non-attainment.
c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant Impact Sensitive receptors are defined as schools, hospitals, resident care facilities, and day-care centers, as well as residential receptors. The AERSCREEN dispersion model was used to determine the concentration for

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 28 air pollutants at any location near the pollutant generator. Additionally, the model will predict the maximum exposure distance and concentrations. The AERSCREEN input/output file for the project is shown in Attachment B of the air quality report (Appendix B of this document). The worst -case exhaust emissions generated from the project from construction equipment was utilized and calculated within the CalEEMod model.

The Office of Environmental Health Hazards Assessment (OEHHA) recommends that an exposure duration (residency time) of 30 years be used to estimate individual cancer risk for the Maximally Exposed Individual Resident. OEHHA also recommends that the 30-year exposure duration be used as the basis for public notification and risk reduction audits and plans.

Exposure durations of 9 years and 70 years are also recommended to be evaluated for the Maximally Exposed Individual Resident to show the range of cancer risk based on residency periods. If a facility is notifying the public regarding cancer risk, the 9 - and 70-year cancer risk estimates are useful for people who have resided in their current residence for periods shorter and longer than 30 years. Cancer risk calculations are provided as Attachment C to the air quality report (Appendix B of this document).

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 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 Health Haza rd Assessment (OEHHA, 2014). Diesel Exhaust has a REL of 5 micrograms per cubic meter (μg/m 3) and targets
the respiratory system.

Based upon the air quality modeling and assuming Tier 4 equipment with diesel particulate filters as a design feature to the proposed project, worst -case onsite PM 10 from onsite construction exhaust would
cumulatively produce 0.00099 tons over the construction duration (454 working days) or an average of

2.29X10-5 (0.0000229) grams/second.

Utilizing the AERSCREEN dispersion model, the air quality analysis determined the peak maximum 1-hour (hr) concentration is 0.041 µg/m 3 during the worst -case construction period. Converting the peak 1 -hr concentration to an annual concentration by multiplying it by 0.08 (US EPA 1992) yields an annual concentration of 0.00328 µg/m3, which translates to a worst-case inhalation cancer risk of 0.72 per million exposed at the point of maximum exposure 75 meters (245 feet). One of the project’s design features and condition of approval for the project would be to utilize Tier 4 diesel equipment with a diesel particulate filter (DPF) attached inline to the exhaust system . Since the threshold is 10 per million exposed with T - BACT installed, the project would have a less than significant impact under CEQA and would be in compliance with the City’s thresholds.

It should be noted that sensitive residential receptors are adjacent to the project site. Since the maximum risk is 0.72 per million exposed (and the threshold is 10 per million), all sensitive receptors would have cancer risks at or less than 0.72 per million exposed which would also represent a less than significant impact.

There are known acute and chronic health risks associated with diesel exhaust which are considered non- cancer risks and are determined by the hazard index. The hourly concentration of 0.041 µg/m3 divided by the REL of 5 µg/m3 yields a Health Hazard Index o f 0.0082, Since the project’s diesel exhaust emissions

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 29 are less than the Non-Cancer REL of 5 μg/m3, non-cancer risks both acute and chronic would be less than significant.
d) Result in other emissions such as those leading to odors affecting a substantial number of people? Less Than Significant Impact
For operations, according to the South Coast Air Quality Management District (SCAQMD) CEQA Air Quality Handbook (SCAQMD 1993), land uses associated with odor complaints are agricultural operations, wastewater treatment plants, food processing plants, chemical plants, composting facilities, refineries, landfills, dairies, and fiberglass molding plants. The project is not in any of these categories, and is not proposing any of these uses.

Potential onsite odor generators would include short -term construction odors from activities such as paving and possibly painting. Given this, short -term construction odors would not be considered an impact. Also, since the project is a senior residential development, no operational odor sources are expected.

Because the project would not generate objectionable odors or place sensitive receptors near existing odor sources that would affect a considerable number of persons or the public during project construction or operation, odor impacts are less than significant.

4.4 Biological Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) 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?
X
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations, or by the California Department of
Fish and Wildlife or U.S. Fish and Wildlife
Service?
X
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 30 Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
through direct removal, filling, hydrological
interruption, or other means?
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use
of native wildlife nursery sites?
X
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
X
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
X

A Biological Resources Technical Report was prepared for the proposed project by Helix Environmental Planning (Helix) in January 2026 and is includ ed as Appendix C of this document . The biology report included an on-site resources assessment, analyzed potential impacts on biological resources, analyzed the project’s consistency with CEQA, the Multiple Habitat Conservation Program (MHCP) and the Draft Natural Community Conservation Plan for the City of San Marcos (Draft San Marcos Subarea Plan), and included a database query, literature review, and field survey.

Helix biologist Larry Sward conducted an initial general biological field survey on May 19, 2015. Vegetation was mapped on a 1"=200' scale aerial of the site. The project site was surveyed on foot and with the aid of binoculars. Plant and animal species observed or otherwise detected were recorded in field notebooks.

Animal identifications were made in the field by direct, visual observation or indirectly by detection of calls, burrows, tracks, or scat. Plant identifications were made in the field or in the lab through comparison with voucher specimens or photographs. The locations of special status plant and animal species incidentally observed or otherwise detected were mapped. The project site was examined for evidence of potential jurisdictional waters and wetlands, including vernal pools, during the general biological survey. Additionally, HELIX biologists , Thomas Liddicoat and Jason Kurnow conducted an updated biological survey and delineation on October 21, 2020, to confirm existing conditions and biological resources mapping, including jurisdictional aquatic resources. Additionally, Rocks Biological Consulting/City of San Marcos conducted a site visit on May 10, 2023, to confirm vegetation mapping by HELIX.

In addition to the general biological surveys, HELIX conducted rare plant surveys, protocol -level surveys for coastal California gnatcatcher ( Polioptila californica californica) in 2015, 2021, and 2025, least Bell’s

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 31 vireo (Vireo bellii pusillus) surveys in 2015, 2021 and 2025, and Crotch’s bumble bee (Bombus crotchii) in 2025.

The general biological survey and vegetation mapping were conducted within the project site and a 250- foot survey buffer. Only the project site information is included in report calculations and tables, while the 250-foot buffer is illustrated within the figures for informational purposes and edge effects analysis. a) 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? Less than Significant with Mitigation Incorporated Sensitive Wildlife Species
HELIX conducted protocol-level surveys for coastal California gnatcatcher and least Bell’s vireo in 2015 2021, and 2025.

California Coastal Gnatcatcher
HELIX biologists conducted focused surveys for the coastal California gnatcatcher at the project site in 2015, 2021, and 2025. Surveys were completed in accordance with the cur rent protocol (USFWS 1997).

Because the project site is located outside of an adopted Natural Community Conservation Planning (NCCP) Area, the United States Fish and Wildlife Service (USFWS) requires that a minimum of six surveys be conducted, at least one week apart, during the period between March 15 and June 30. Surveys targeted potential coastal California gnatcatcher habitat on the project site, which consisted of Diegan coastal sage scrub and baccharis scrub vegetation. The surveys were conducted by walking through the vegetation or on adjacent paths, and birds were viewed with the aid of binoculars, where necessary. If the coastal California gnatcatcher was not detected passively, a digital coastal California gnatcatcher call-prompt was briefly played. Coastal California gnatcatcher locations were mapped (if present) on an aerial photograph.

Coastal California gnatcatcher were not detected during focused surveys in 2015 and 2025; however, one pair of coastal California gnatcatcher was detected during focused surveys in 2021 . Nesting was not observed (Figure 5).

Coastal California gnatcatcher is federally listed as threatened, is a California Species of Special Concern, and is a covered species under the MHCP. Direct impacts to 2.1 acres of Diegan coastal sage scrub habitat (including disturbed) occupied by coastal California gnatcatcher would result from project grading and construction. These impacts to habitat would be considered significant (Impact BIO-1a) and mitigation is required.

Additionally, if project construction activities are implemented during the breeding season for coastal California gnatcatcher (February 15 to August 30), nesting could also be directly impacted and would also be significant (Impact BIO-1b). Nesting coastal California gnatcatcher within habitat outside of the project, adjacent to the construction area, could be adversely affected by construction -generated noise ; these indirect impacts would also be significant (Impact BIO-1c) and mitigation is required. Implementation of mitigation measures MM-BIO-1 and MM-BIO-2, which would be required as conditions of project approval, would reduce Impact BIO-1b and Impact BIO1c to below a level of significance.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 32 Figure 5. Vegetation and Sensitive Species on the Project Site

Source: Helix 2026.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 33 MM-BIO-1 Coastal California Gnatcatcher Mitigation. Prior to land disturbance, clearing, grubbing, and/or the issuance of a grading permit for the project site , the project proponent shall demonstrate to the City that off -site mitigation has been provided for project impacts to 2.1 acres of Diegan coastal sage scrub habitat occupied by coastal California gnatcatcher. Mitigation shall occur at no less than a 1:1 ratio through the purchase of no less than 2.1 acres of coastal sage scrub Mitigation Bank credits, occupied by coastal California gnatcatcher at the Red Mountain Conservation Bank or another CDFW approved mitigation bank with available credits, unless otherwise required by the City or Wildlife Agencies.

Prior to the issuance of a grading permit, the project proponent shall demonstrate to the City that consultation with the United States Fish and Wildlife Service for an evaluation of proposed project impacts to Coastal California gnatcatcher in accordance with the Federal Endangered Species Act has been completed (e.g., Section 10 consultation) or is not required.

Least Bell’s Vireo
HELIX biologists conducted focused surveys for the least Bell’s vireo in accordance with the current protocol (USFWS 2001). The surveys consisted of eight site visits made from April 20 through July 7, in 2015, between April 13 to and July 1, in 2021, and between April 10 and June 26, 2025. The survey area consisted of potential least Bell’s vireo riparian habitat on site (i.e., southern cottonwood-willow riparian forest) located along Twin Oaks Valley Creek. The surveys were conducted by walking along the edges of, as well as within, potential least Bell’s vireo habitat while listening for least Bell’s vireo vocalizat ions and viewing birds with the aid of binoculars. All least Bell’s vireo , special-status riparian bird species , and brown-headed cowbird (Molothrus ater; a nest parasite) locations were mapped on an aerial photograph.

No least Bell’s vireo w as detected during focused surveys in 2015 , 2021, or 2025. Therefore, the project would not impact this species.

Crotch’s Bumble Bee
A HELIX biologist conducted focused surveys for the Crotch’s bumble bee in 2025. Surveys were completed in accordance with the current California Department of Fish and Game guidelines ( CDFW 2023). The initial habitat assessment and first survey were conducted on the same day and all three surveys were conducted within the Crotch’s bumble bee colony active period (April to August). Surveys were conducted by walking line transects throughout and at the perimeter of the project site, accounting for foraging bumble bee activity and suitable Crotch’s bumble bee nesting locations, pollen , and nectar sources. ,The survey area included all areas of the project site with potential for Crotch’s bumble bee occupancy.

Surveys covered approximately three acres per biologist per hour. Surveys were conducted with binoculars and a camera to aid in insect detection and later identification.

Bee species observed during the survey effort were honey bee ( Apis mellifera), California bumble bee (Bombus californicus ), and yellow -faced bumble bee ( Bombus vosnesenskii). Crotch’s bumble bee or Crotch’s bumble bee nests were not detected during the survey effort and are presumed to be absent from the project site.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 34 Cooper’s Hawk
Cooper’s hawk was observed to the north and west of the project site during surveys (Figure 5). No active or inactive nests belonging to any raptor species were observed within the project site during the 2015 and 2021 surveys. Cooper’s hawk is not federally or state -listed as endangered, or threatened. It was recently demoted to a Watch List species, having previously been designated a California Species of Special Concern. Cooper’s hawk is covered by the MHCP and the Draft San Marcos Subarea Plan. Cooper’s hawk has the potential to forage over the site, and could potentially nest within riparian forest habitat along Twin Oaks Valley Creek, or in similar habitat outside the project site. Direct impacts to Cooper’s hawk are not expected because the project would avoid impacts to riparian habitat. Indirect impacts to Cooper’s hawk could occur if the project construction activities are implemented during the raptor breeding season (January 15 through September 15) and Cooper’s hawk is found nesting on or adjacent to the project site. Such impacts to nesting Cooper’s hawk would be significant ( Impact BIO -2a) and mitigation would be required.

Implementation of mitigation measure MM-BIO-2, which would be required as a condition of project approval, would reduce Impact BIO-2a to a level below significance.

MM-BIO-2 Nesting Bird and Raptor Avoidance. If initial grading and vegetation removal activities (i.e., earthwork, clearing, and grubbing) must occur during the nesting season for coastal California gnatcatcher (February 15 through August 30), the project applicant shall retain a qualified biologist to conduct pre -construction surveys to determine the presence or absence of this species. Additionally, a pre -construction survey for migratory birds and raptors during the general bird breeding season (January 15 through September 15) shall also be conducted if applicable. The survey shall consist of searching for nesting birds within the proposed work area and surrounding 300 feet, where feasible, and the final survey shall not be completed more than three days prior to the beginning of impacts. If the surveys conclude no active nesting, the work shall resume as planned without further requirements. If the results of the survey identify nesting birds (including raptors), no -work species- dependent disturbance buffers shall be implemented as follows : 100 feet around non-listed active passerine (perching birds and songbirds) nests, 300 feet around listed passerine nests (e.g., coastal California gnatcatcher), and 300 feet around active raptor nests (e.g., Cooper’s hawk). The buffers may be reduced, if appropriate, and as directed by a qualified biologist. The reduction in no -work buffers shall be approved by the City prior to implementation. The qualified biologist will regularly monitor active nest during work hours to monitor chick development and parent stress to mitigate indirect effects to nesting birds (i.e., noise, dust, human presence, etc.) and accurately determine when the juveniles have fledged. The buffers shall be respected and maintained until the qualified biologist has determined that all juveniles have fledged.

If coastal California gnatcatcher is determined to be nesting on the project site or within the 300-foot survey buffer, no construction activities that would result in noise levels exceeding 60 A-weighted decibel ( dBA) hourly Energy Equivalent Noise Level (Leq) at the nest site shall be allowed. Ambient background noise shall be excluded from the 60 dBA calculation. Noise barriers or other noise attenuation measures shall

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 35 be implemented to reduce noise impacts to occupied coastal California gnatcatcher habitat to below 60 dBA hourly L eq and/or the activities shall be suspended. Noise monitoring shall be conducted weekly, to confirm noise levels remain at or below 60 dBA hourly Leq. The results of weekly noise monitoring will be submitted to the City.

Yellow-breasted Chat and Yellow Warbler
Yellow-breasted chat was observed in the western portion of the project site in the 2015 survey but was not detected in the 202 0/21 surveys. Yellow warblers were observed within the western portion of the project site in riparian forest habitat along Twin Oaks Valley Creek during the 2015 and 2020/21 surveys (Figure 5). These species are not federally or state -listed as endangered or threatened but are California Species of Special Concern, and yellow-breasted chat is a covered species under the MHCP. Direct impacts to these species are not expected because the project would avoid impacts to riparian habitat. In direct impacts to these species could occur if the project construction activities are implemented during the breeding season (February 15 through September 15) and these species are found nesting on or adjacent to the project site. These potential indirect impacts to nesting yellow -breasted chat or yellow warbler would be significant (Impact BIO -2b). Implementation of mitigation measure MM -BIO-2, as detailed above, would reduce this impact to below a level of significance.

Coronado Skink and Blainville’s Horned Lizard
Although not detected during biological surveys across the site, Coronado skink and Blainville’s horned lizard were determined to have moderate potential to occur within the riparian and upland habitats on site. All of the on-site riparian habitat associated with Twin Oaks Valley Creek would not be impacted. The remaining on-site suitable habitat for these species that would be impacted includes grasslands and coastal sage scrub, some of which would be retained on site within the biological buffer area along Twin Oaks Valley Creek, contiguous with off-site habitats. Because Coronado skink is a State Watch List Species and Blainville’s horned lizard is a CDFW Species of Special Concern and MHCP Covered Species, project impacts would be potentially considered significant (Impact BIO-2c). Potential project impacts to these species are expected to be a result of habitat impacts; individual skinks/lizards are not expected to be impacted due to their high mobility and ability to disperse into the adjacent habitat. These species are relatively widespread throughout the County and region, and project impacts to their habitat and possibly one individual or two (although not anticipated) would not likely jeopardize the status of these species in the region and would not directly contribute to the future elevated listing of these species. Habitat retention on site as well as other habitat-based mitigation (see MM-BIO-1, MM-BIO-3, and MM-BIO-4a), would result in no-net loss of habitat for these species. Therefore, the potential impacts to Coronado skink and Blainville’s horned lizard would be reduced to below a level of significance.

Western Yellow Bat
Western yellow bat has a moderate potential to occur on site within the southern cottonwood -willow riparian forest habitat. Although suitable roosting habitat is present on site, this species has not been recorded within the vicinity of the project site. Because the project would not impact on -site southern cottonwood-willow riparian forest habitat, no impacts to western yellow bat individuals are expected.

Potential indirect impacts to this species could occur as a result of construction -generated noise if this species is present roosting in the riparian habitat on site. However, roosting immediately adjacent to the site is unlikely, given the unauthorized trespassing and encampments, as well as the larger expanse of riparian habitat associated with the Twin Oaks Valley Creek corridor beyond the project site. This species

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 36 is relatively widespread throughout the County and region, and potential indirect impacts from construction noise would not likely jeopardize the status of the species in the region and would not directly contribute to the future elevated listing of the species. Thus, the potential indirect impacts to western yellow bat are considered less than significant.

Nesting Birds
The project site contains trees, shrubs, and other vegetation that provide suitable nesting habitat for common birds, including raptors, protected under the Migratory Bird Treaty Act ( MBTA) and California Fish and Game (CFG) Code. Construction of the proposed project includes vegetation clearing, which could result in direct impacts to nesting birds. These potential impacts to nesting would be in violation of the MBTA and CFG Code and would be considered significant under CEQA. Additionally, construction activities could result in indirect impacts through disturbance to nesting from noise, vibration, dust, and physical presence/activity.

Mitigation measure MM-BIO-2 would require pre-construction surveys for coastal California gnatcatcher, nesting birds, and raptors and the establishment of no -work buffers, as applicable, to avoid impacts to nesting birds prior to and during construction activities . Mitigation measure MM-BIO-1 requires compensatory mitigation for impacts to occupied coastal California gnatcatcher habitat and consultation with the USFWS for take authorization for coastal California gnatcatcher. With the implementation of mitigation measures MM-BIO-1 and MM -BIO-2, impacts to listed and sensitive nesting birds would be reduced to a level less than significant.

Special-Status Plants
Special status plant species have been afforded special status and/or recognition by the USFWS, CDFW, and/or the City (e.g., MHCP Covered Species) and may also be included in the California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants. Their status is often based on one or more of three distributional attributes: geographic range, habitat specificity, and/or population size. A species that exhibits a small or restricted geographic range (such as thos e endemic to the region) is geographically rare. A species may be more or less abundant but occur only in very specific habitats. Lastly, a species may be widespread but exists naturally in small populations.

HELIX biologist Larry Sward conducted a rare plant survey on May 26, 2015. Opportunistic inspections for target rare plant species were also made during the other biological surveys performed to date. Searches were made for those species that are listed as threatened or endangered by the USFWS or CDFW; those with a Rare Plant Rank 1 through 4 designated by the CNPS; and those that are covered under the MHCP (SANDAG 2003) and Draft San Marcos Subarea Plan (San Marcos 2001). The surveys were conducted on foot and included 100 percent visual coverage of the majority of the site. Dense riparian vegetation within the Twin Oaks Valley Creek impeded access to portions of this area. Special -status plant species encountered were mapped using a hand -held Global Positioning System (GPS) unit and/or on an aerial photograph.

HELIX identified a total of 50 plant species on the project site, of which 25 (50 percent) are native species and 25 (50 percent) are non-native species. The complete list of plants is included in Appendix F of Appendix C of this document . No federally , state-listed, or otherwise sensitive plants, including MHCP covered species, were identified on the project site. Therefore, the project would not have an impact on special-status plant species.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 37 Summary
In summary, t he project would result in potentially significant impacts to sensitive wildlife species.

Specifically, the project would directly impact suitable habitat for coastal California gnatcatcher (Impact BIO-1a). In addition, potentially direct and indirect impacts to coastal California gnatcatcher nesting could also occur (Impact BIO-1b and 1c). Potential indirect impacts to Cooper’s hawk (Impact BIO-2a), yellow- breasted chat, yellow warbler, and other birds nesting adjacent to the project construction could also occur if present during construction (Impact BIO-2b). Additionally, although not detected during surveys, Coronado skink, Blainville’s horned lizard, and western yellow bat have moderate potential to occur on - site and could be impacted during construction, if present (Impact BIO-2c). These potential impacts could be minimized and reduced to less than significant levels through the implementation of mitigation measures MM-BIO-1 and MM-BIO-2. Habitat-based impacts for all aforementioned species would be minimized to a level below significance with implementation of MM-BIO-1, MM-BIO-3, and MM-BIO-4. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Less than Significant with Mitigation Incorporated Vegetation Communities
Six vegetation communities or land use types were identified within the project site: Diegan coastal sage scrub, baccharis scrub, southern cottonwood-willow riparian forest, non-native grassland, disturbed land, and developed land. These vegetation communities are summarized in Table 8 and depicted in Figure 5.

Table 8. Existing Vegetation Communities/Land Use
Vegetation Community/Habitat Acres(1)
Diegan Coastal Sage Scrub(2) 2.1
Baccharis Scrub 0.7
Southern Cotton-Willow Riparian Forest 0.58
Non-native Grassland 0.4
Disturbed Land 0.2
Developed Land 0.3
Total 4.28
Source: Helix 2026.

Notes: (1) Rounded to the nearest 0.01 for wetlands/riparian and the nearest 0.1 for uplands. (2) Includes disturbed phase.

Diegan Coastal Sage Scrub
Coastal sage scrub is one of the two major shrub types that occur in southern California, occupying xeric sites characterized by shallow soils (the other is chaparral). Four distinct coastal sage scrub geographical associations (northern, central, Venturan, and Diegan) are recognized along the California coast. Diegan coastal sage scrub may be dominated by a variety of species depending on soil type, slope, and aspect.

Typical species found within Diegan coastal sage scrub include California sagebrush (Artemisia californica), California buckwheat ( Eriogonum fasciculatum ssp. fasciculatum ), laurel sumac ( Malosma laurina), and

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 38 black sage (Salvia mellifera). Coastal sage scrub is the dominant vegetation community on site, occurring primarily within the eastern and central portions of the site. The disturbed phase of this community was mapped in the southeast portion of the site, which consisted of a higher (greater than 20 percent) cover of non-native annual species, such as: black mustard (Brassica nigra), ripgut grass (Bromus diandrus), and tocalote (Centaurea melitensis). A total of 2.1 acres of Diegan coastal sage scrub occur s on the project site, including both disturbed and undisturbed subcategories. According to the Draft San Marcos Subarea Plan, coastal sage scrub is sensitive (San Marcos 2001).

Baccharis Scrub
Baccharis scrub is dominated by coyote brush ( Baccharis pilularis ) and/or broom baccharis ( Baccharis sarothroides) and can include mule fat ( Baccharis salicifolia) as a sub -dominant. Goldenbush ( Isocoma menziesii) is often co -dominant, with weedy native species such as telegraph weed ( Heterotheca grandiflora) and horseweed (Erigeron canadensis) making up a sparse herbaceous understory. Baccharis scrub is associated with early succession after disturbance, and often occurs at the disturbed margins of coastal sage scrub habitat or in nutrient -poor, alkaline soils such as are found in graded areas, detention basins, and along constructed drainages. Within the project site, dominant species include coyote brush and California sagebrush. A total of 0.7 acre of baccharis scrub occurs within the southwestern portion of the site. Baccharis scrub is considered a sub -type of coastal sage scrub; thus, is considered sensitive per the Draft San Marcos Subarea Plan (San Marcos 2001).

Southern Cottonwood-Willow Riparian Forest
Southern cottonwood-willow riparian forest consists of tall, open, broad -leaved, winter -deciduous riparian species and is dominated by cottonw ood species (e.g., Populus fremontii and Populus trichocarpa), with willow species (Salix spp.) comprising the main understory. This vegetation community is structurally diverse, with several trees, willow, as well as an understory of shrubby willows . Dominant species in this vegetation community on site include arroyo willow ( Salix lasiolepis ), red willow ( Salix laevigata), black willow ( Salix gooddingii), and blue elderberry ( Sambucus nigra). A total of 0.58 acre of this vegetation community occurs in the western portion of the site along Twin Oaks Valley Creek.

Southern cottonwood -willow riparian forest is a riparian community; thus, it is considered a sensitive habitat per the Draft San Marcos Subarea Plan (San Marcos 2001).

Non-native Grassland
Non-native grassland typically supports a sparse to dense cover of annual grasses often associated with numerous species of showy-flowered native annual forbs. This association occurs on gradual slopes with deep, fine-textured, usually clay soils. Most of the annual, introduced species that comprise the majority of species the taxa and biomass within the non -native grassland originate d from the Mediterranean region, an area with a long history of agriculture and a climate similar to California. Within the project site, dominant species in this community include red brome ( Bromus madritensis ssp . rubens), black mustard (Brassica nigra), ripgut grass ( Bromus diandrus), and rattail six weeks grass ( Festuca myuros). A total of 0.4 acre of non -native grassland occur s within the eastern portion of the project site. Although dominated by non-native species, grasslands are considered a sensitive habitat by the Draft San Marcos Subarea Plan (San Marcos 2001).

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 39 Disturbed Land
Disturbed land is either unvegetated or is dominated by non-native, weedy species that are adapted to a regime of frequent disturbance (ruderal). Species occurring within this vegetation community o n the project site include black mustard, tocolate ( Centaurea melitensis), white stemmed filaree ( Erodium moschatum), and horehound ( Marrubium vulgare). Approximately 0.2 acre of disturbed land occurs in patches in the eastern portion of the site.

Developed Land
Urban/developed land includes areas that have been constructed upon or otherwise covered with a permanent, unnatural surface and may include, for example, structures, pavement, irrigated landscaping, or hardscape to the extent that no natural land is evident. Developed lands that occur in the southern portion of the site and are composed of paved walkways and the road shoulders of E . Mission Road and Woodward Street, as well as the bank protection riprap/concrete associated with the box culvert for Twin Oaks Valley Creek. A total of 0.3 acre of developed area are located on the project site.

Vegetation Communities Impact Analysis
The proposed project would have a direct impact to sensitive vegetation communities, all of which would occur within an MHCP designated Focused Planning Area (FPA). Specifically, the project would directly impact 2.1 acres of Diegan coastal sage scrub, 0.7 acre of baccharis scrub, and 0.3 acre of non -native grassland ( Table 9 and Figure 6). The project would not impact southern cottonwood-willow riparian forest. The impacts to Diegan coastal sage scrub, baccharis scrub, and non -native grassland would be considered significant (Impact BIO-3) and mitigation would be required.

MM-BIO-3 Sensitive Vegetation Mitigation. Prior to land disturbance, clearing, grubbing, and/or the issuance of a grading permit for the project site , impacts to 2. 1 acres of Diegan coastal sage scrub and 0.7 acre of baccharis scrub shall be mitigated at a 2:1 ratio, for a total of 5.6 acres of coastal sage scrub (Table 9). Impact s to 0.3 acre of non -native grassland shall be mitigated at a 0.5:1 mitigation ratio (Table 9). Of the 5.6 acres of coastal sage scrub mitigation required, a minimum of 2.1 acres shall be occupied by coastal California gnatcatcher (see MM -BIO-1). The remaining 3.5 acres of coastal sage scrub mitigation, as well as the 0.15 acre of non-native grassland mitigation, shall be provided through the total purchase of 3.65 acres of coastal sage scrub at the Red Mountain Conservation Bank or another California Department of Fish and Wildlife approved mitigation bank, unless otherwise required by the City or Wildlife Agencies.

Table 9. Impacts to Vegetation Communities/Habitat
Vegetation Community or Habitat Impact
(Acres)(1)
Mitigation
Ratio(2)
Required
Mitigation
(Acres)(3)
Southern Cottonwood-Willow Riparian Forest -- 3:1 --
Diegan Coastal Sage Scrub (including disturbed) 2.1 2:1 4.2 Baccharis Scrub 0.7 2:1 1.4
Non-native Grassland 0.3 0.5:1 0.15

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 40 Vegetation Community or Habitat Impact
(Acres)(1)
Mitigation
Ratio(2)
Required
Mitigation
(Acres)(3)
Disturbed Land 0.2 -- --
Developed Land <0.1 -- --
Total 3.3 -- 5.75
Source: Helix 2026.

Notes: ( 1) Acreages are rounded to the nearest 0.1 acre. Impacts include both permanent and temporary. (2) Mitigation ratios are consistent with those listed in Tables 4 -6 and 4 -7 of the MHCP ( SANDAG 2003) and Section

5.2.1 of the Draft San Marcos Subarea Plan (San Marcos 2001) for projects located inside designated FPAs. (3) Mitigation for impacts to Diegan coastal sage scrub, baccharis scrub, and non -native grassland would be provided through purchasing of credit from either Red Mountain Conservation Bank or other location deemed acceptable by the City of San Marcos, USFWS, and CDFW.

Project construction would occur immediately adjacent to sensitive southern cottonwood-willow riparian forest habitat. Inadvertent intrusion into this adjacent sensitive habitat by construction vehicles, equipment, and personnel could result in additional impacts. This represents a significant impact (Impact BIO-4) and mitigation is required. Implementation of mitigation measures MM-BIO-4 and MM -BIO-5 would ensure that inadvertent impacts to sensitive riparian habitat located immediately adjacent to construction work areas are avoided.

MM-BIO-4 Best Management Practices. The project applicant shall ensure the construction contractor implements Best Management Practices (BMPs) including but not limited to: flagging/fencing the limits of construction adjacent to sensitive habitats; maintaining the project area free of trash and debris which will not only keep the habitat clean but reduce the potential of attracting predator/scavenger species; locating stagin g and refueling areas at least 50 feet from jurisdictional waters; employing appropriate standard spill prevention practices and clean -up materials; installing and maintaining sediment and erosion control measures in accordance with an approved Storm Water Pollution Prevention Plan (SWPPP); maintaining effective control of fugitive dust; properly storing, handling, and disposing of all toxins and pollutants, including waste materials; and shielding and directing lighting (if work to be conducted at night) away from habitats along the Twin Oaks Valley Creek, and the native habitats (coastal sage scrub) in the vicinity.

MM-BIO-5 Biological Construction Monitoring. A qualified biologist shall be retained to oversee initial clearing/grubbing efforts as well as site grading and other construction activities that have the potential to impact native vegetation communities and other sensitive biological resources which occur outside of the development footprint.

Monitoring frequency will be determined by the qualified biologist and shall be based on the type of activity and proximity to sensitive biological resources. Other responsibilities shall include verification of boundary fencing/staking prior to the start of construction, site inspections to confirm the project boundary remains clearly defined, and attending a pre-construction meeting. At the pre-construction meeting, the qualified biologist shall discuss the project’s biological mitigation measures and familiarize construction personnel with the surrounding sensitive biological resources.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 41 Figure 6. Vegetation Impacts
Source: Helix 2026.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 42 c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Less than Significant Impact A preliminary jurisdictional delineation was conducted by Helix on October 21, 2020, to identify and map areas under potential U.S. Army Corps of Engineers (USACE) jurisdiction pursuant to Section 404 of the Clean Water Act (33 USC 1344), Regional Water Quality Control Board (RWQCB) jurisdiction pursuant to Section 401 of the Clean Water Act, and CDFW jurisdiction pursuant to Section 1600 of the CFG Code.

Based on the jurisdictional delineation and verification of the ordinary high -water mark conducted in 2020, the project site supports areas considered to be potentially jurisdictional waters and wetlands, including associated riparian habitat, subject to r egulation by the USACE, RWQCB, and CDFW. On -site potentially jurisdictional resources include Twin Oaks Valley Creek and its associated riparian habitat corridor (e.g., southern cottonwood-willow riparian forest) in the western portions of the site (Figure 5).

However, t he proposed project would not result in impacts to federally -protected wetlands or other jurisdictional resources (Figure 6). The project was specifically designed to avoid impacts to USACE, RWQCB, and CDFW jurisdictional resources. Inadvertent impacts to jurisdictional resources immediately adjacent to the project would be avoided through the implementation of mitigation measures MM-BIO-4 and MM -BIO-5. In addition, a buffer of at least 12 feet will be maintained between the project development and the existing CDFW jurisdictional riparian canopy. A buffer ranging from approximately 27 feet to over 100 feet will be maintained between the project development impacts and USACE jurisdictional resources. Impacts would be less than significant. The buffer widths were designed to maximize the amount of open space while providing a feasible project design. With implementation of the aforementioned avoidance and mitigation measures, impacts to potentially jur isdictional features would be less than significant.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less than Significant Impact Wildlife corridors can be local or regional in scale. Their functions may vary temporally and spatially based on conditions and species presence. Wildlife corridors represent areas where wildlife movement is concentrated due to natural or anthropogenic con straints. Local corridors provide access to resources such as food, water, and shelter. Animals use these corridors to move between different habitats.

Regional corridors provide these functions and link two or more large habitat areas. They provide avenues for wildlife dispersal, migration, and contact between otherwise distinct populations.

Twin Oaks Valley Creek runs through the western portion of the site and is an identified local movement corridor in the City’s General Plan (See Figure 4 -2; San Marcos 2001). Wildlife present in the area would most likely move through the riparian corridor along the Creek towards undeveloped lands to the north of the site since connections to the south have been eliminated by existing development. Wildlife movement on a regional scale is currently restricted because of the presence of commercial and residential development within the project vicinity; the limited size of native habitat surrounding the site, which is fragmented by development, roadways, and transportation corridors; narrow riparian corridor along Twin Oaks Valley Creek; and relatively small size of the project site. As a result of these factors, the portion of Twin Oaks Valley Creek that occurs on the site provides limited function as a local wildlife movement corridor and does not serve as a linkage between habitat areas.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 43 Construction of the project would not result in substantial interference with wildlife movement because the proposed project would avoid all direct impacts to the Creek and the associated habitat and because of the existing ambient noises and disturbances due to the proximity of transportation corridors and existing development. Impacts to wildlife movement are not expected, and no mitigation is required.

Mitigation measure MM-BIO-4 would help ensure there are no indirect impacts (e.g., light spillover, construction noise, etc.) to adjacent habitat that may facilitate wildlife movement or provide nursery sites.

Therefore, impacts would be less than significant.
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? No Impact.

The project would be developed in compliance with the City’s General Plan. Listed below in italics are applicable policies from the City’s General Plan (2012) pertaining to biological resources, and following each policy is a summary discussion of project consistency with that policy.

Policy COS-1.1: Support the protection of biological resources through the establishment, restoration, and conservation of high-quality habitat areas.

The project was designed to avoid impacts and conserve all sensitive wetland riparian habitat on site associated with Twin Oaks Valley Creek. Impacts to Diegan coastal sage scrub and baccharis scrub on site would be mitigated at a 2:1 ratio, and unavoidable impacts to non-native grassland would be mitigated at a 0.5:1 ratio. High-quality habitats on site, consisting of the wetland riparian corridor of Twin Oaks Valley Creek, plus an adjacent upland buffer of sensitive habitat , would be conserved. Project mitigation would result in additional habitat being conserved at an off-site location approved by the City. Thus, the project is consistent with General Plan Policy COS-1.1.

Policy COS-1.2: Ensure that new development, including Capital Improvement Projects, maintains the biotic habitat value of riparian areas, oak woodlands, habitat linkages, and other sensitive biological habitats policy.

No riparian areas, oak woodlands, or habitat linkages would be removed as a result of the proposed project. The project was specifically designed to avoid impacts to wetland riparian habitat on site associated with Twin Oaks Valley Creek, including a buffer of sensitive upland habitat. The existing on-site habitat linkage provided by the Twin Oaks Valley Creek corridor would be retained. The project is consistent with COS-1.2.

Policy COS-1.3: Continue to work with other federal, State, regional, and local agencies to implement the MHCP.

Per the MHCP, the project is located within a Hardline Preserve area. Conservation goals for Hardline Preserve areas are between 90 and 100 percent. The MHCP states that subarea plans will determine the ultimate preserve boundaries and conservation levels. Within the D raft San Marcos Subarea Plan, the project is located within the Northern FPA in a Habitat Linkage Area. Per the Draft San Marcos Subarea Plan, the overall goal for all areas in the Northern FPA falling within a Habitat Linkage Area is 30 percent conserved with a net acreage committed to the Preserve of 20.54 acres. Although this project would result in permanent impacts on native vegetation, it w ould also place 0.98 acre of habitat into open space.

Although the project includes development within an MHCP Hardline Preserve a rea, the project is consistent with the Biological Preserve Design Objectives of the draft San Marcos Subarea Plan , as

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 44 discussed in section 4.4(f) below. Therefore, the project would not preclude the City from implementing COS-1.3.

Policy COS-2.1: Provide and protect open space areas throughout the City for recreational, agricultural, safety, and environmental value.

There are no recreational or agricultural uses currently on the property, and none are proposed by the project. On-site undeveloped open space was intentionally avoided during project design to preserve its ecological function as a wetland riparian corridor and northern linkage within the greater City landscape.

Therefore, the project is consistent with COS-2.1.

Policy COS-2.2: Limit, to the extent feasible, the conversion of open space to urban uses and place a high priority on acquiring and preserving open space lands for recreation, habitat protection and enhancement, flood hazard management, water and agricultural resources protection, and overall community benefit.

This project site is not currently designated or zoned as Open Space, . The project site is designated as a Specific Plan Area for urban use; however, the project was purposefully designed to retain and protect the wetland riparian habitat corridor and an adjacent upland buffer of Twin Oaks Valley Creek along the western portions of the project site. Project impacts to sensitive habitats would be mitigated through the preservation of equivalent or higher-value habitats at an off-site location approved by the City. The project includes the installation of two biofiltration/detention basins on site, which would help protect water quality adjacent to and downstream of the site within Twin Oaks Valley Creek. The project would also provide social and economic benefits to the community of San Marcos in the form of additional housing for senior citizens and employment opportunities at the facility.

Policy COS-2.6: Preserve healthy mature trees where feasible; where removal is necessary, trees shall be replaced at a ratio of 1:1.

The project was specifically designed to avoid impacts to mature trees on site. No tree removal is planned as part of the project. Therefore, the project is consistent with COS-2.6.

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.

Existing topography, landforms, viewsheds, wildlife corridors, and open space areas of the site were all considered during project design. This project was designed purposefully to avoid the corridor and open space areas of Twin Oaks Valley Creek along the western portions of the site. The creek corridor and an adjacent upland buffer would be retained by the project and continue to provide a corridor for wildlife movement, although within a highly urbanized environment. Additionally, the views of the creek and riparian corridor would be retained for future residents of the development. The topography of the site was also considered during the design of the project, and the proposed development was planned in the most feasible locations to minimize alteration in site topography. Therefore, the project is consistent with COS-3.3.

Twin Oaks Valley Creek runs through the western portion of the site. Wildlife present in the area would most likely move through the riparian corridor along the Creek towards undeveloped lands north of the site since connections to the south have been eliminated by existing development. Wildlife movement on a regional scale is currently restricted because of the presence of commercial and residential development

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 45 within the project vicinity; the limited size of native habitat surrounding the site, which is fragmented by development, roadways, and transportation corridors; narrow riparian corridor along Twin Oaks Valley Creek; and the relatively small size of the project site. As a result of these factors, the portion of Twin Oaks Valley Creek that occurs on the site provides limited function as a local wildlife movement corridor and does not serve as a linkage between habitat areas. De velopment of the project site would avoid impacts to Twin Oaks Valley Creek and adjacent habitat, which w ould allow for continued wildlife movement throughout the project site. Thus, the project is consistent with General Plan Policy COS-3.3.

Policy COS-3.4: Evaluate potential impacts to visual and aesthetic resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

Lighting on the project site has been designed to meet the standards prescribed by the City. No project lighting would be directed towards the open space habitats associated with Twin Oaks Valley Creek to protect nocturnal wildlife and their activities within and around the creek. The riparian corridor of the creek itself is also a visual resource and would be retained; no impacts to riparian habitat are proposed.

The project is consistent with COS-3.4.

Policy COS-8.4: Require new development and redevelopment to protect the quality of water bodies and natural drainage systems through site design, source controls, storm water treatment, runoff reduction measures, BMPs, low impact development (LID), hydromodification strategies consistent with the Current San Diego RWQCB Municipal Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, and all future municipal stormwater permits.

The project design includes two biofiltration/detention basins to assist in the protection of water quality adjacent to and downstream of the project, including Twin Oaks Valley Creek. BMPs would also be installed and maintained throughout construction to protect water quality resources beyond the site.

Thus, the project would comply with COS-8.4.

Summary
As demonstrated, the project would not conflict with any adopted local policies or ordinances protecting biological resources. This includes wildlife corridors and linkages identified in the City’s General Plan. The wildlife corridor identified in the City’s General Plan oc curs within Twin Oaks Valley Creek and would be avoided by the project, along with an upland buffer. The project also complies with the City’s tree preservation policy COS-2.6 because impacts would occur within the scrub and grassland habitats on site, avoiding impacts to the trees within the riparian area. f) 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
The MHCP Subregional Plan for the northwestern portion of San Diego County encompasses the Cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista ( SANDAG 2003). Each of the seven jurisdictions within the MHCP planning area is required to implement their respective portion of the MHCP via city -wide subarea plans if they are to participate and benefit from take authorization provided through the MHCP.

A Draft MHCP San Marcos Subarea Plan was prepared in 2001 and, although it has not yet been approved, the plan is being used as a policy document to guide development and open space design within the City.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 46 The intent of the Draft San Marcos Subarea Plan is to identify a City-wide preserve system that meets local and regional biological goals while minimizing fiscal and economic effects to the City and adverse effects on private property owners.

The project site is located within the MHCP and D raft San Marcos Subarea Plan, specifically in a Hardline Preserve area of the MHCP and Northern FPA of the Subarea Plan (Figure 7). The MHCP Hardline Preserve areas identify target areas that may be designated by City subarea plans to be conserved land or developed. Conservation goals for Hardline Preserve areas are between 90 and 100 percent.

According to the D raft San Marcos Subarea Plan , the focus on habitat conservation and linkages in the Northern FPA, north of Highway 78, are lands north of Borden Road, west of Twin Oaks Valley Road, east of Los Posas Road, and south of Buena Creek Road.

Although the Draft Subarea Plan is not adopted, t he project considered the Biological Preserve Design Objectives, which are summarized in below, along with a description of project consistency. The following analysis discussion demonstrates the project would not conflict with the preserve planning or conservation goals of the Draft San Marcos Subarea Plan.

Objective 1: Conserve the full range of extant vegetation communities with a focus on habitats considered sensitive, rare, or declining. Riparian habitats should be preserved in their entirety. Larger patches of coastal sage scrub, especially those essential to regional habitat connectivity, should also be preserved.

The project was specifically designed to avoid the riparian habitat on site in its entirety. Additionally, the avoidance of riparian habitat also incorporates an adjacent upland habitat, thereby providing a natural buffer. These avoidance of native riparia n and upland habitats are contiguous with larger expanses of similar habitats off site to the north of the project site. This aspect of the project is consistent with the objective of the Draft San Marcos Subarea Plan.

Per the MHCP, the project is located within a Hardline Preserve a rea. Conservation goals for Hardline Preserve areas are between 90 and 100 percent. The MHCP states that subarea plans will determine the ultimate preserve boundaries and conservation levels. The SMMHCP is not approved, meaning that there is no established conservation level for the project site. However, the project meets this objective because it preserves riparian habitat in its entirety along with a buffer of native upland habitat. The whol e site is less than five acres and is surrounded by development with no connectivity to the south; thus, it does not constitute a larger patch of coastal sage scrub, nor is it essential to regional habitat connectivity. Within the Draft San Marcos Subarea Plan, the project is located within the Northern FPA in a Habitat Linkage Area. Per the Draft San Marcos Subarea Plan , the overall goal for all areas in the Northern FPA falling within a Habitat Linkage Area is 30 percent conserved with a net acreage committed to the Preserve of

20.54 acres. Although th e proposed project would result in permanent impacts on native vegetation, it would also place 0.98 acre of habitat into open space and the habitat to be preserved maintains the best wildlife movement potential on site, meaning that the project does not preclude the City from meeting the goals of the Draft San Marcos Subarea Plan.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 47 Figure 7. Regional Context

Source: Helix 2026.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 48 Objective 2: Maintain functional wildlife corridors and habitat linkages between critical biological resource areas. Wildlife habitat should be linked by functional corridors to minimize habitat fragmentation. Where possible, corridors should be of high -quality habitat and of the same habitat as they connect.

As stated above, the project would avoid the entire riparian habitat corridor, which is contiguous with similar habitats off site, and includes an adjacent upland buffer varying in width from 27 to over 100 feet.

The buffer widths were designed to maximize the amount of open space while providing a feasible project.

Thus, the project would not result in habitat fragmentation or preclude wildlife use of the riparian corridor. A primary linkage identified in the Draft San Marcos Subarea Plan in the northern FPA is a “floating corridor” located east of “P” M ountain, west of Twin Oaks Valley Road, and north of Borden Road. Although the project site is located south of this target corridor area, and the project site reflects the southern end of the habitat associated with Twin Oaks Valley Creek, the project fun ctions as a local wildlife corridor; thus, the existing riparian habitat corridor would be avoided and retained for wildlife use. Therefore, the project is consistent with this objective of the Draft San Marcos Subarea Plan.

Furthermore, the project site is located within an urban/suburban portion of San Marcos. San Marcos’s General Plan indicates wildlife movement occurs along riparian creeks and drainage corridors within urban and suburban parts of the City. This includes Tw in Oaks Valley Creek. Twin Oaks Valley Creek provides a narrow riparian corridor that is important in allowing wildlife to move through the core of urban and suburban areas. The Twin Oaks Valley Creek corridor is depicted on Figure 4 -2 of the City’s General Plan (corridor located adjacent to Twin Oaks Valley Road) (San Marcos 2012). The project avoids impacts to Twin Oaks Valley Creek, therefore complying with the General Plan’s linkage requirements and facilitation of wildlife movement through the project site.

Objective 3: Maintain viable populations of sensitive plant species. Populations of extant native plant species proposed for coverage under the San Marcos Subarea Plan should be conserved and their habitats managed to ensure the continued viability of the species in the region.

No Draft San Marcos Subarea Plan covered species or other sensitive plant species were detected on site during focused rare plant surveys for the project. Thus, no populations of plants would need protection on site, and the project is consistent with this objective of the Draft San Marcos Subarea Plan.

Objective 4: Maintain viable populations of sensitive animal species and species that are indicators of important habitats. Populations of animal species covered by the S an Marcos Subarea Plan should be conserved and their habitat managed in a manner that ensures continued viability of the species in the region.

Three sensitive animal species (all birds) listed as Covered Species by the Draft San Marcos Subarea Plan were detected on site or adjacent to the site during biological surveys conducted for the project. These three species include: coastal California gnatcatcher, Cooper’s hawk, and yellow-breasted chat. Of these, Cooper’s hawk and yellow-breasted chat are primarily associated with riparian habitat, although they may also utilize native uplands as well. Due to project planning avoidance of preferred suitable habitat for these two species (i.e., Twin Oaks Valley Creek riparian corridor and adjacent upland buffer), the proposed project would contribute to maintaining viable populations and continued viability of these species in the region.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 49 Although 2015 and 2025AND 205 focused surveys for coastal California gnatcatcher at the project site were negative (i.e., coastal California gnatcatcher was absent from the project site during 2015 and 2025 surveys), focused surveys conducted in 2021 detected coastal California gnatcatcher on site. It should be noted that the 2021 surveys were conducted after habitat occupied by coastal California gnatcatcher was removed from an adjacent property, and as such, gnatcatcher birds from that adjacent site likely flushed into the on -site habitat of the proposed project. Thus, ultimately the proposed project would result in impacts to habitat occupied by coastal California gnatcatcher. Project avoidance, minimization , and mitigation measures would be implemented to mitigate project impacts to coastal California gnatcatcher and its habitat. In accordance with the federal Endangered Species Act ( ESA), the project would also be required to consult with the USFWS under Section 10 of the ESA to offset impacts to coastal California gnatcatcher. In the context of species viability, the project site is not part of the core conservation areas targeted by the MHCP for the protection and management of coastal California gnatcatcher in the region and is not a critical habitat linkage for this species. Given this, and that the project would fully mitigate for impacts to coastal California gnatcatcher, the project is considered consistent with this objective of the Draft San Marcos Subarea Plan.

In addition to the Draft San Marcos Subarea Plan Biological Preserve Design Objectives, all properties within an FPA should implement the following: minimize edge effects where edge effects impact sensitive habitats, assure connectivity to other lands in the FPA, limit direct impacts by regulating clearing of native habitat, limit chemical use of fertilizers and pesticides, control non-native competitive species, and protect against frequent or catastrophic fires. The project was designed in a manner to be consistent with the Draft San Marcos Subarea Plan Biological Preserve Design Objectives to the extent feasible.

To reduce potential edge effects by the development, the project includes the following design features:
retaining walls would be installed along the western and northern edges of the impact footprint, adjacent to native habitats proposed for avoidance, no trails or public access gates into these adjacent biological habitats would be provided by the project, and no invasive plant materials would be used in the landscaping of the project. Additionally, th e retaining walls along the western and northern boundaries of the project would protect the adjacent habitats in a development fire scenario. Because the project is residential in nature, domestic artificial lighting may be introduced to the surrounding a reas. However, the site is adjacent to existing roadways and developments; therefore, it is already exposed to some level of lighting disturbance. To minimize potential edge effects, lighting associated with the project would be selectively placed for human safety purposes only. No lighting would be placed within or directed toward the adjacent proposed biological open space retained by the project. Furthermore, the retaining walls proposed along the western and northern boundaries of the development would prevent spillover lighting into these adjacent habitats.

The proposed project occurs in an undeveloped parcel in the Northern FPA of the Draft San Marcos Subarea Plan (Figure 7) and would impact approximately 77 percent of the property. The highest value biological resources on site (i.e., wetland riparian corridor of Twin Oaks Valley Creek and an adjacent upland habitat buffer) would be avoided and retained as a result of the project. Consistent with the Draft San Marcos Subarea Plan Policy, the proposed project would not preclude connectivity of habitats with the FPA and would not result in fragmentation of habitat. Additionally, the project complies with the City’s no net loss policy for creeks and wetlands. Lastly, mitigation ratio s for project impacts to biological resources are consistent with those listed in Section 5.2.1 of the Draft San Marcos Subarea Plan (San Marcos 2001) for projects located inside FPAs. Therefore, project impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 50 Summary
The Draft San Marcos Subarea Plan has not been adopted, therefore the MHCP is advisory in nature only, and the project does not conflict with an adopted or approved habitat conservation plan. The Draft San Marcos Subarea Plan is used as a policy document to guide development in the City. Implementation of the project would not preclude or prevent finalization and adoption of the Draft San Marcos Subarea Plan.

As discussed, t he project is consistent with the Biological Preserve Design Objectives. The project is located within a Hardline Preserve area, also known as the Northern FPA (Figure 7). Based on the project’s small size and placement of riparian habitat into open space it is anticipated that it would not significantly conflict with conservation goals within the Northern FPA of the MHCP or the Draft San Marcos Subarea Plan, should it be adopted in the future. Less than significant impacts are identified for this issue area.

4.5 Cultural Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change in
the significance of a historical resource
pursuant to §15064.5?
X
b) Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to §15064.5?
X
c) Disturb any human remains, including
those interred outside of dedicated
cemeteries?
X

A cultural resources study was prepared for the project by ASM Affiliates (ASM 2023). The complete report is included as Appendix D of this document.

Records Search
As part of the cultural resources study, a records search request of the archives at the South Coastal Information Center, San Diego State University, of the California Historical Resources Information System (CHRIS) for San Diego County, was requested and completed on May 31, 2023 by ASM. The record search area encompasses the project area and a search radius of one mile around it. The California Register of Historic Resources and the National Register of Historic Places were also examined to identify any additional resources within one mile of the project area.

The CHRIS records identified 46 previously recorded archaeological sites within a one-mile radius of the project area. Five resources have been previously recorded immediately adjacent to the project site: SDI-

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 51 21254; SDI-23161; P-37-15578; P-37-33557; and SDI -23456. Each of these resources is briefly described below.
• SDI-23161was recorded in 2018 as a multi -component site consisting of four bedrock milling features, sixteen historic features , and historic debris. No subsurface deposits were identified during testing and the site was recommended not eligible to the California Register of Historical Resources (CRHR).
• SDI-21254 was recorded in 2014 as the ruins of a historic structure and was recommended not eligible to the CRHR. During construction monitoring in 2015 a prehistoric cultural deposit was identified consisting of a scatter of lithic artifacts, marine shell, and historic artifacts. One piece of possible human remains was identified during monitoring. The City of San Marcos and the San Luis Rey Band of Mission Indians consulted and further testing at the site identified 157 prehistoric artifacts. The site was recommended not eligible to the CRHR . However, due to the possible human remains, the site was considered significant under CEQA. • SDI-23456 was recorded in 2023 as a bedrock milling site consisting of two granitic bedrock milling outcrops each with a single milling slick. Six shovel test pits were excavated to evaluate the site and all were negative. The site was recommended not eligible to the CRHR. • P-37-33557 is the historic alignment of Highway 395, which was the primary inland transportation route in the 1910s that connected Linda Vista, Miramar, Poway, Bernardo (Rancho Bernardo), Escondido, Richland, San Marcos, Buena Vista, Bonsall, Fallbrook, Rainbow, and Temecula with one another as well as downtown San Diego, Riverside, and San Bernardino. The historic alignment of P-37-33557 within the vicinity of the project area is the current alignment of West Mission Road.
• P-37-15578 is an isolated granitic mano, recorded in 1996.

Additionally, three historical addresses were identified as occurring within the one -mile radius. These resources include:
• San Marcos Forest Fire Station Gas & Oil House located at236 Pico Avenue. • Single family residence located at 341 Richmar Avenue. • Single family residence located at 358 Fitzpatrick Road.

All three of these resources are located outside of the project area.

Native American Heritage Commission Search
On May 17, 2023, a Sacred Lands File search request was sent to the California Native American Heritage Commission (NAHC) to inquire about known areas of cultural concern, such as traditional cultural places, sacred sites, archaeological sites, or cultural landscapes that may exist within or within one mile of the originally proposed Project. ASM received a response from the NAHC dated June 17, 2023 stating that a record search was negative and NAHC provided a list of 33 tribal contacts which may have information about the project area. ASM sent information requests letters to the Tribal contacts on June 22, 2023. To

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 52 date responses ha ve been received from the Pechanga Band of Indians , the Jamul Indian Village, and Rincon Band of Luiseño Indians.

On June 22, 2023, Lisa Cumper, Tribal Historic Preservation Officer, Jamul Indian Village, responded that they have cultural concerns on the project and would like to discuss the project further. On June 23, 2023, Paul Macarro, Cultural Coordinator, Pechanga Band of Indians responded that the project site is within an Ancestral Placename Village and close to known human remains and wished to participate in the proposed project. Pechanga requested government to government consultation for the proposed project. On July 21, 2023, Shuuluk Linton, Tribal Historic Preservation Coordinator, Rincon Band of Luiseño Indians, responded that the Rincon Band had specific concerns that the project may impact tangible Tribal Cultural Resources, Traditional Cultural Landscapes and potential Traditional Cultural Properties. Rincon recommended an archaeological study and a professional Rincon Tribal Monitor. Rincon wished to consult directly with the lead agency regarding project impacts to cultural resources.

Site Survey
An intensive -level survey of the project area was conducted on May 26, 2023, by ASM Associate Archaeologist Michelle Hamilton. Cami Mojado from Saving Sacred Sites provided Native American monitoring for the survey.

The project area was surveyed in transects spaced approximately 15 meters apart wherever possible .

Ground surface visibility was poor due to thick vegetation and all exposed soil s were visually examined, but these areas were limited to small, discontinuous patches of soil and nearly all of these areas appeared to be previously disturbed. The project area is primarily a flat undeveloped parcel with a drainage present along the eastern edge. Modern trash was identified across the project area and an encampment was present along the southern and western portion of the project area near the drainage. No cultural resources were identified during the archaeological survey. a) Would the project cause a substantial adverse change in the significance of a historical resource as defined in §15064.5? No Impact
As detailed in Section 15064.5(a) of the CEQA Guidelines, the term "historical resources" shall include the following:
(1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 14 CCR, Section 4850 et seq.)
(2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code, or identified as significant in an historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. (3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency's determination is supported

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 53 by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code, § 5024.1, Title 14 CCR, Section 14 CCR, Section 4852) including the following:
(A) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage;
(B) Is associated with the lives of persons important in our past; (C) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or
(D) Has yielded, or may be likely to yield, information important in prehistory or history. (E) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k) of the Public Resources Code), or identified in an historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code sections 5020.1(j) or 5024.1.

A cultural resources study was prepared for the project by ASM (2023). The report presents the results of a cultural and historical resources inventory conducted within the project site and within a one-mile radius. No unique historical addresses were identified as overlapping with the project site. Three historical addresses were identified as occurring within a one-mile radius however none of these sites overlap with the project site. No historical resources were identified during the cultural resources site visit. Therefore, the project would not cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5 and no impact is identified. b) Would the project c ause a substantial adverse change in the significance of an archae ological resource pursuant to §15064.5? Less Than Significant with Mitigation Incorporated Based upon the cultural resources study prepared for the project, no archaeological resources are known to occur on the project site and none were observed during the field work (ASM 20 23), however, the project site is within an identified Traditional Cultural Landscape.

In general, the archaeological sites that occur within a one -mile radius of the project site consist predominantly of prehistoric resources. Many of these prehistoric archaeological sites contain bedrock milling components and most are associated with lithic scatters. A small number of archaeological sites also contain occupation debris indicating a more intensive use of those locations. In general, most of these archaeological sites have been disturbed by modern activities and are characterized by sparse surficial, as well as sparse and relatively shallow, subsurface deposits. A small number also contain dense subsurface deposits in the form of middens.

The intensive visual inspection of the accessible portions of the project site provided no evidence for the presence of cultural resources in those areas. Although the likelihood of subsurface deposits is low, it is possible that subsurface cultural deposits are still presents under the surface and construction activities

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 54 could impact these resources if they are present. This represents a significant impact ( Impact CR-1) and mitigation is required.

The following mitigation measures apply to grading and construction activity that occurs within areas of previously undisturbed soil. Once construction excavation has exposed soil to a sufficient depth that precludes the potential for cultural resources, t ypically greater than 1 meter, cultural resources monitoring may be ceased.

MM-CR-1 Pre-Excavation Agreement : Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall enter into a Tribal Cultural Resources Treatment and Repatriation Agreement (Pre-Excavation Agreement) with a Traditionally and Culturally Affiliated Native American Tribe (TCA Tribe), identified in consultation with the City. The purpose of the Pre-Excavation Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the TCA Tribe for the protection, treatment, and repatriatio n of 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 acti vities. 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 Pre-Excavation 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 Pre-Excavation Agreement. If the TCA Tribe does not accept the return of the cultural resources, then the cultural resources will be subject to curation.

MM-CR-2 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 a Qualifi ed Archaeologist and Traditionally and Culturally Affiliated Native American monitor (TCA Native American monitor) have been retained at the Applicant/Owner or Grading Contractor’s expense to implement the construction monitoring program, as described in the Pre-Excavation Agreement.

The Qualified Archaeologist and 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 Qualified Archa eologist and TCA Native American monitor shall be present onsite during grubbing, grading, trenching, and/or other ground disturbing activities that

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 55 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 Qualified Archaeologist and 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 more than six inches below the original pre -project ground surface to identify any evidence of potential archaeological or tribal cultural re sources. 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 Qualified Archaeologist and TCA Native American monitor.

The Qualified Archaeologist 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 Tribe, preferably through e -mail, of the start and end of all ground disturbing activities.

Prior to the release of any grading bonds, or prior to the issuance of any project Certificate of Occupancy, an archaeological monitoring report, which describes the results, analysis, and conclusions of the construction monitoring shall be submitted by the Qualified Archaeologist, along with any TCA Native American monitor’s notes and comments received by the Qualified Archaeologist, to the Planning Division Manager for approval. Once approved, a final copy of the archaeological monitoring report shall be retained in a confidential City project file and may be released, as a formal condition of Assembly Bill (AB) 52 consultation, to San Luis Rey Band of Mission Indians, Rincon Band of Luiseño Indians, or any parties involved in the project specific monitoring or consultation process. A final copy of the report, with all confidential site records and appendices, will also be submitted to the South Coastal Information Center after approval by the City.

MM-CR-3 Unanticipated Discovery Procedures : Both the Qualified Archaeologist and the TCA Native American monitor may temporarily halt or divert ground disturbing activities if potential archaeological resources or tribal cultural resources are discovered during construction activities. Ground distur bing 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. Isolates and clearly non - significant archaeological resources (as determined by the Qualified Archaeologist, in consultation with the TCA Native American monitor) will be minimally documented in the field. All unearthed archaeological resources or tribal cultural resources will be collected, temporarily stored in a secure location (or as otherwise agreed upon by the Qualified Archaeologist and the TCA Tribe), and repatriated according to the terms of

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 56 the Pre-Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

If a determination is made that the archaeological resources or tribal cultural resources are considered potentially significant by the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor, then the City and the TCA Tribe shall deter mine, in consultation with the Applicant/Owner and the Qualified Archaeologist, the culturally appropriate treatment of those resources.

If the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor cannot agree on the significance or mitigation for such resources, these issues will be presented to the Planning Division Manager for decision. The Planning Division Manager shall make a determination based upon the provisions of CEQA and California Public Resources Code Section 21083.2(b) with respect to archaeological resources and California Public Resources Section 21704 and 21084.3 with respect to tribal cultural resour ces, and shall take into account the religious beliefs, cultural beliefs, customs, and practices of the TCA Tribe.

All sacred sites, significant tribal cultural resources, and/or unique archaeological 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, such as, but not limited to, the funding of an ethnographic study and/or a data recovery plan, as determined by the City in consultation with the Qualified Archaeologist and the TCA Tribe. The TCA Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation and the drafting and finalization of any eth nographic study and/or data recovery plan, and/or other culturally appropriate mitigation. Any archaeological isolates or other cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a sec ure location on site (or as otherwise agreed upon by the Qualified Archaeologist and TCA Tribe), and repatriated according to the terms of the Pre-Excavation Agreement, unless ordered to do otherwise by 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.

If a data recovery plan is authorized as indicated above and the TCA Tribe does not object, then an adequate artifact sample to address research avenues previously identified for sites in the area will be collected using professional archaeological collection methods. If the Qualified Archaeologist collects such resources, the TCA Native American monitor must be present during any testing or cataloging of those resources. Moreover, if the Qualified Archaeologist does not collect the cultural resources that are unearthed during the ground disturbing activities, the TCA Native American monitor may, at their discretion, collect said resources for later reburial or storage at a local curation facility, as described in the Pre-Excavation Agreement.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 57 In the event that curation of archaeological resources or tribal cultural 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 TCA Tribe or the curation facility, whichever is most applicable, that the repatriation and/or curation have been completed.

MM-CR-4 Human Remains: As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excav ation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.

If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two working days of being notified if the remains are subject to his or her authority. If the Medical Examiner recognizes the remains to be Native American, and not under his or her jurisdiction, then he or she shall contact the Native American Heritage Commission by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding culturally appropriate treatment.

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

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 58 from future disturbance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

Senate Bill 18
Sente Bill (SB) 18 approved in 2004, amends the California Civil Code and the California Government Code, requiring cities and counties to contact and consult with California Native American tribes prior to adopting or amending any general plan or specific plan, or designating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within the city’s or county’s jurisdiction. SB 18 also requires cities and counties to hold in strict confidence any information about the specific identity, location, character, or use of these resources. In 2005, OPR published Tribal Consultation Guidelines to guide cities and counties on the process of engaging in consultation in accordance with SB 18. The NAHC maintains a list of California Native American Tribes with whom cities and counties must consult pursuant to SB 18. Outreach to local tribes by the City, consistent with SB 18, was initiated as part of the preparation of this environmental document. c) Would the project disturb any human remains, including those interred outside of formal cemeteries? Less Than Significant with Mitigation Incorporated The cultural resource study prepared for the project did not indicate the likelihood of human remains on the site (ASM 2023). Additionally, existing regulations through the California Health and Safety Code Section 7050.5 state that if human remains are discovered during project construction, no further disturbance shall occur until the San Diego County Coroner has made the necessary findings as to origin.

Further, pursuant to California Public Resources Code Section 5097.98(b), remains shall be left in place and free from disturbance until a final decision as to the treatment and disposition has been made. If the San Diego County Coroner determines the remains to be Native American, the NAHC shall be contacted within a reasonable timeframe. Subsequently, the NAHC shall identify the Most Likely Descendant. The Most Likely Descendant shall then make recommendations and engage in consultation concerning the treatment of the remains as provided in Public Resources Code Section 5097.98. Furthermore, while there is no evidence of human remains on the project site, as provided by mitigation measures MM -CR-1 through MM-CR-3, an archaeological monitor and a Native American monitor shall be present during the earth moving and grading activities to assure that any resources found during project grading would be protected. Mitigation measure MM -CR-4 further details the requirements should human remains be encountered during project construction. With mitigation, the project would not disturb any human remains, including those interred outside of formal cemeteries. Impacts would be less than significa nt with the incorporation of mitigation

4.6 Energy
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 59 a) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources
during project construction or operation?
X
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
X
a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction, or operation? Less than Significant Impact
Construction activities for the project would include grading of the project site, building construction and application of architectural coatings to the proposed buildings, and paving of the proposed parking lot and driveways. The project would consume energy resources during construction in three general forms:
1) petroleum ‐based fuels used to power off ‐road construction vehicles and equipment on the site, construction worker travel to and from the project site, as well as delivery and haul truck trips (e.g. soils import); 2) e lectricity associated with the conveyance of water that would be used during project construction for dust control (supply and conveyance) ; and 3) electricity to power any necessary lighting during construction, electronic equipment, or other construction activities necessitating electrical power.

Operational energy use would include, but not be limited to heating/ventilating/air conditioning (HVAC), refrigeration, lighting, appliances, and electronics. Energy would also be consumed during operations related to water usage, solid waste disposal, landscape equipment and vehicle trips.

The project would comply with regulatory compliance measures outlined by the State and City related to air quality, GHG emissions, transportation/circulation, and water supply. Additionally, the project would be constructed in accordance with all applicable City Building and Fire Codes which require energy efficiency and conservation.

The project does not propose any excessive or unnecessary energy consumption beyond what would be typical of this type of development. Therefore, potential impacts associated with the wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation would be less than significant.
b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less than Significant Impact
The project would comply with all Federal, State, and City requirements related to the consumption of electricity, including but not limited to, CCR Title 24, Part 6 Building Energy Efficiency Standards and CCR Title 24, Part 11: California Green Building Standards. The CCR Title 24, Part 6 and Part 11 standards require numerous energy efficiency measures to be incorporated into the proposed buildings, including enhanced insulation, use of energy efficient lighting and appliances as well as requiring a variety of other energy‐efficiency measures to be incorporated into all of the proposed structures. Therefore, the project would be designed and built to minimize electricity use and existing and planned electricity capacity and electricity supplies would be enough to support the project’s electricity demand. Impacts related to electrical supply and infrastructure capacity would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 60 The Conservation Element of the General Plan includes local policies related to energy conservation. These are primarily related to the incorporation of energy efficient features in a project and the use of renewable energy. As previously stated, the project would comply with state energy efficiency standards.

4.7 Geology and Soils
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving: Rupture of a known
earthquake fault, as delineated on the most
recent Alquist-Priolo Earthquake Fault Zoning
map, issued by the State Geologist for the area
or based on other substantial evidence of a
known fault? Refer to Division of Mines and
Geology Special Publication 42.

X
b) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving: Strong seismic ground
shaking?
X
c) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving: Seismic-related ground
failure, including liquefaction?
X
d) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving: Landslides?
X
e) Result in substantial soil erosion or the loss of
topsoil?
X
f) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in on-
or off-site landslide, lateral spreading,
subsidence, liquefaction, or collapse?
X
g) Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994),
creating substantial risks to life or property?
X
h) Have soils incapable of adequately supporting
the use of septic tanks or alternative wastewater
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 61 Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
disposal systems where sewers are not available
for the disposal of wastewater?
i) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
X

A geotechnical investigation was prepared for the project site by NorCal Engineering (NCE) in 2018. The complete report is included as Appendix E of this document. a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. No Impact
The project site is located within a seismically active region, as is all of southern California; however, the project site not located on or adjacent to any known active faults. According to California Earthquake Hazard Zone Application, the City of San Marcos is not identified as a jurisdiction affected by Alquist-Priolo Earthquake Fault Zones (California Department of Conservation 2019).

According to the geotechnical investigation, there are no known active or potentially active faults transecting the project site (NCE 2018). Further, the project site is not located within any State Mapped Earthquake Fault Zone or County of San Diego mapped fault zone. The nearest known active fault to the project site is the Newport-Inglewood -Rose Canyon Fault Zone, located approximately 12.6 miles southwest of the project site. Therefore, the project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault. No impact is identified for this issue area. b) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Strong seismic ground shaking? Less Than Significant Impact The proposed project is located in seismically -active southern California. The type and magnitude of seismic hazards affecting the site are dependent on the distance to causative faults, the intensity, and the magnitude of the seismic event. Per the soils report prepared for the project site (NCE 2018), the Rose Canyon Fault is considered to have the most significant effect at the site from a design standpoint. The fault is located approximately 12.6 mi les to the southwest from the site. The project site is not located within an Alquist-Priolo Earthquake Fault Zone. All structures on the site would be designed in accordance with seismic parameters of the latest California Building Code. Therefore, the project would not expose people or structu res to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking. Impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 62 c) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Seismic -related ground failure, including liquefaction? Less than Significant Impact
Seismic-related Ground Failure
The geotechnical investigation indicated that there are no active faults are mapped on the project site and the site is not located within a mapped Alquist -Priolo Earthquake Fault Zone. The nearest known active fault to the project site is the Newport-Inglewood-Rose Canyon Fault Zone, located approximately

12.6 miles southwest of the project site. Shallow ground rupture due to shaking from distant seismic events is not considered to be a significant hazard for the project site. No impact is identified for this issue area.

Liquefaction
The project site is identified as having Zero Susceptibility for liquefaction per Figure 6 -1 of the Safety Element of the City’s General Plan. Additionally, per the County of San Diego Department of Planning and Land Use “Liquefaction Map – County of San Diego Hazard Mitigation Planning Map (2009) the site is not situated in an area of historic occurrence of liquefaction to indicate a potential for permanent ground displacement. No impact is identified for this issue area . The geotechnical investigation for the project (NCE 2018) noted the site is not within an Alquist -Priolo Earthquake Fault Zone, that no active or potentially active faults are present at the project site, so the site is not considered susceptible to surface rupture or seismic-related ground failure. Impacts would be less than significant. d) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Landslides? No Impact
The project site is generally flat and is located in a generally flat portion of the City. The project site is identified as having Zero Susceptibility for soil slip, surficial landslides, or debris flow per Figure 6-1 of the Safety Element of the City’s General Plan. No impact is identified for this issue area. e) Result in substantial soil erosion or the loss of topsoil? Less than Significant Impact The project site is relatively flat with elevations of approximately 571 to 611 feet amsl. Proposed site improvements require grading and soils import of 23,254 cy to prepare the site for development and to raise the site above base flood elevation. The project would be under the State Water Resources Control Board (SWRCB) General Construction Permit, which prohibits sediment or pollutant release from the project site and requires preparation of a Stormwater Pollution Prevention Plan (SWPPP) and implementation of best management practices (BMPs) that would incorporate erosion and sediment control measures during and after grading operations to stabilize these areas. Permanent vegetation would also be required to stabilize graded areas. The project would not result in substantial soil erosion or the loss of topsoil. Impacts would be less than significant. f) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? Less than Significant Impact The project site is not located on or adjacent to any known active faults nor is the site underlain by soils that are conducive to landslides. The project would not be located on a geologic unit or soil that is

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 63 unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. Per the geotechnical report prepared for the project site, surficial fill and disturbed top soils classifying as a brown, fine to medium grained, silty sand with gravel underlay the site and are loose to medium dense and dry to moist (NCE 2018) .

Underlaying the fill is an undisturbed colluvium soil classifying as a light brown to brown, silty to clayey sand with gravel and was observed to be medium dense to dense and dry to very moist. Also, a bedrock material classifying as a basalt and sandstone sand were encountered directly beneath the colluvium and observed to be dense to very dense and impenetrable in some trenches. Some large boulders can be anticipated to be encountered during site grading. These soil types were not identified as having a high risk of liquefaction. Additionally, per the County of San Diego Department of Planning and Land Use “Liquefaction Map – County of San Diego Hazard Mitigation Planning Map” (2009) the site is not situated in an area of historic occurrence of liquefaction to indicate a potential for permanent ground displacement. Therefore, the potential for adverse impacts from liquefaction is considered low. Impacts would be less than significant.
g) Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Less Than Significant Impact with Mitigation Incorporated
According to the geotechnical report prepared for the project site ( NCE 2018), the majority of the onsite material is expected to have very low to medium expansion potential. However, higher expansive soils may be encountered during the grading of the site. This represents a significant impact ( Impact GEO-1) and mitigation is required. As a condition of project approval, implementation of the following mitigation measure (MM-GEO-1) would be required, and would reduce the impact to below a level of significance:

MM-GEO-1 The project applicant shall implement the geotechnical recommendations identified beginning on pages 7 – 17 of the Geotechnical Investigation Report and follow the Expansive Soil Guidelines provided on pages 18 -21 prepared by Norcal Engineering for the project site.
h) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? No Impact The project does not propose any septic tanks or alternative wastewater disposal systems. The project would be served by VWD and VWD has indicated that they can serve the project for wastewater service (VWD 2020). Therefore, no impact is identified for this issue area. i) Directly or indirectly destroy a unique paleontological resource or site or unique geologic features? Less Than Significant Impact with Mitigation Incorporated The project area is located in the Peninsular Ranges Geomorphic Province. The province is characterized by mountainous terrain on the east composed mostly of Mesoz oic igneous and metamorphic rocks, and relatively low-lying coastal terraces to the west underlain by late Cretaceous, Tertiary, and Quaternary age sedimentary rocks.

According to the geotechnical report prepared for the project ( NCE 2018), the geologic conditions underlying the site consist of surficial fill. An undisturbed colluvium soil classifying as a light brown to brown, silty to clayey sand with gravel was encountered beneath the fill. Bedrock material was classified

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 64 as a basalt and sandstone were encountered directly below the colluvium. Basalt, due to its volcanic nature, does not typically have a potential for paleontological resources. However, sandstone is a sedimentary rock and can have the potential for paleontological resources. B ecause the potential for fossils from sedimentary rock exists, there is a potential that the site could contain paleontological resources that could be disturbed during grading activities for the project . This represents a potentially significant impact (Impact GEO-2) and mitigation is required. Implementation of mitigation measure MM- GEO-2 would reduce this impact to below a level of significance.

MM-GEO-2 Prior to project grading the project applicant shall retain a qualified paleontologist to review the proposed project area to determine the potential for paleontological resources to be encountered. If there is a potential for paleontological resources to occur, the paleontologist shall identify the area(s) where these resources are expected to be present, and a qualified paleontological monitor shall be retained to monitor the initial cut in any areas that have the potential to contain paleontological resources.

4.8 Greenhouse Gas Emissions
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
X
b) Conflict with any applicable plan, policy or
regulation of an agency adopted for the purpose
of reducing the emissions of greenhouse gases?
X

A Greenhouse Gas technical study was prepared for the project by Ldn Consulting (LDN) (2024b) and is included as Appendix F.1 of this document. Additionally, consistent with AB 32, the City adopted its Climate Action Plan (CAP) in September 2013. An updated CAP was adopted on December 8, 2020. A CAP Consistency Review Checklist (CAP Checklist) was prepared for the project and is included as Appendix F.2 of this document, which details the GHG-related design features of the project.

The CAP outlines strategies and measures that the City would undertake to achieve its proportional share of State GHG emissions reduction targets. The CAP is a plan for the reduction of GHG emissions in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183.5. Pursuant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b), a project’s incremental contribution to a cumulative GHG emissions effect may be determined not to be cumulatively considerable if it complies with the requirements of the CAP (City of San Marcos 2020).

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 65 The CAP set the following citywide targets:
• 4 percent below 2012 levels (575,000 MTCO2e) by 2020. • 42 percent below 2012 levels (347,000 MTCO2e) by 2030.

The City has also developed a Climate Action Plan Consistency Review Checklist (CAP Checklist), in conjunction with the CAP, to provide a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA. The CAP Consistency Guidance Memo dated July 15, 2020 summarizes the methodology and application of a GHG screening threshold which is set at 500 metric tons carbon dioxide equivalent [MTCO 2e] per year as
outlined in the CAP. Projects that are projected to emit fewer than 500 MTCO2e annually would not make a considerable contribution to the cumulative impact of climate change and would not need to provide additional analysis to demonstrate consistency with the CAP. This screening threshold is for new development projects consistent with the City’s General Plan. When such a project exceeds the screening threshold, the project would be required to demonstrate consistency with the CAP through the CAP Checklist.

In most cases, compliance with the CAP Checklist would provide the CEQA streamlining path to allow project specific environmental documents, if eligible, to tier from and/or incorporate by reference the CAP’s programmatic review of GHG impacts. Projects th at are consistent with the General Plan and implement CAP Checklist GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified pla n for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects.

If a project is consistent with the existing General Plan land use designation(s), it can be determined to be consistent with the CAP projections and can move forward to Step 2 of the CAP Checklist.

For projects seeking a General Plan Amendment, such as the proposed project, the CAP Checklist requires a comparative analysis to determine if the General Plan Amendment results in an equivalent or less GHG- intensive project when compared to the existing d esignations. In addition to providing evidence to support the conclusion that the project would generate fewer emissions than existing designations, these projects would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist.

If a General Plan Amendment results in a more GHG -intensive project, the project is required to prepare a quantitative GHG analysis based on applicable sections of the CEQA Guidelines.

Project Analysis
GHGs related to construction and daily operations were calculated. The purpose of this analysis is to complete a comparison between the proposed project and the General Plan (GP) Buildout scenario. The GP Buildout scenario assumes the site would be developed with 37,000 s.f. commercial and 185 parking spaces. The construction module in CalEEMod was used to calculate the emissions associated with the construction of the project. The CalEEMod input/output model is shown in Attachments A and B of the GHG report (Appendix F.1 of this document).

Grading would consist of approximately 2,825 cy of cut and 26,079 cy of fill, for a net import of 23,254 cy.

Emissions generated by earthwork activities associated with grading were analyzed within CalEEMod

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 66 using a “Grading Equipment Passes” methodology which has been approved by the SCAQMD. As noted in the CalEEMod documentation, this methodology was approved by the California Air Pollution Control Officers Association (CAPCOA 2021). Since CalEEMod was used for GHG emissions estimation from construction, this methodology was assumed.
j) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Less Than Significant Impact Projected Emissions for Proposed Project
The proposed project would generate GHG emissions through short-term construction activities and long- term operational activities. Construction-related GHG emissions include emissions from heavy construction equipment for grading, paving, truck traffic, and worker trips. Operational GHG emissions associated with the project include emissions from area sources include vehicular traffic and electricity.

Construction Emissions – Proposed Project
Construction-related GHG emissions include emissions from construction equipment, truck traffic, and worker trips. Construction activities for the project would include site grading, preparation, and paving.

Grading and earthwork activity would be required to prepare the site for development. Based upon the proposed grading concept, the project requires 2,825 cubic yards (cy) of cut and 26,079 cy of fill, for a net import of 23,254 cy. Soils import is expected to take approximately 55 days . Assuming a 20 -cy hauling truck, this results in approximately 21 truck trips per day for soils import. Also, as a design feature of the project, the construction contractor would use Tier IV rated heavy diesel construction equipment to minimize diesel particulates from construction equipment. The construction contractor would also comply with SDAPCD/s fugitive dust rules and fugitive dust control measures outlined in Section 87.426 of the City’s Grading Ordinance.

The project would start grading in 202 7 with utility infrastructure and construction to start shortly thereafter. Project occupancy is anticipated in 2028. The project’s air quality and greenhouse gas analysis assumed a 2024 construction time, which would actually result in a more conservative air quality analysis.

If construction is delayed, emissions could be reduced since moving the start date for project construction later would cause the project to use more modern and cleaner -burning construction equipment and it would be likely that stricter regulations would govern the construction activities.

Anticipated equipment for project construction includes graders, rubber -tired dozers, excavators, tractors/loaders/backhoes, pavers, rollers, cranes, forklifts, generator sets, welders, and air compressors.

Table 10 presents the anticipated construction emissions for the proposed project. As shown in Table 10, anticipated construction-related GHG emissions for the project are estimated at 635.39 MT/year of CO 2e
over the construction life of the project. Per SCAQMD guidance, these emissions are amortized over 30 years and added to operational emissions. This amortized figure estimates project construction would contribute 21.18 MT/year of CO
2e.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 67 Table 10. Proposed Project Construction-Related GHG Emissions (MT/Year) Year Bio-CO2 NBio-CO2 Total CO2 CH4 N2O
Total CO2e
(metric
tons/year)
2024 0.00 508.54 508.54 0.08 0.02 516.55
2025 0.00 117.63 117.63 0.02 0.00 118.84
Total Construction Emissions 635.39
Yearly Average Construction Emissions (Metric Tons/year over 30 years) 21.18 Source: LDN 2024b.

Operational Emissions – Proposed Project
The project would generate GHG emissions from daily operations which would include sources such as Area (or onsite emissions like landscaping), energy usage from electricity and natural gas, mobile sources from vehicular traffic, municipal waste and from water uses, which are calculated within CalEEMod.

This analysis is driven by the CAP and since this project seeks to change the use on the site within the Heart of the City Specific Plan from Commercial to Senior Residential, the proposed project is analyzed in comparison with existing designations to determine if it would be less intense than what would otherwise be approved under the existing designation. If a project’s proposed amendment results i n lower GHG emissions than development under the current use contemplated in the Heart of the City Specific Plan, the project would be required to implement the applicable CAP Measures identified in Step 2 of the CAP Checklist.

Table 11 indicates that the project operations would generate 609.55 MT CO 2e per year without
incorporating any CAP measures. When amortized construction emissions are added in, the project would generate 630.73 MT CO 2e per year. The project would however be required to implement all CAP measures and these measures would further reduce GHG emissions. Since the intent of this analysis is to compare the proposed project with the GP Buildout scenario, CAP measures were not calculated.

Table 11. Proposed Project Operational Emissions Summary (MT/Year) Source Bio-CO2 NBio-CO2 Total CO2 CH4 N2O CO2e
(MT/Yr)
Area 0.00 1.40 1.40 0.00 0.00 1.43
Energy 0.00 191.03 191.03 0.01 0.00 191.89
Mobile 0.00 350.65 350.65 0.03 0.02 356.03
Waste 8.05 0.00 8.05 0.48 0.00 19.95
Water 1.90 31.97 33.87 0.20 0.00 40.25
Total Proposed Project Operational Emissions 609.55
Amortized Construction Emissions (Table 10 above) 21.18 Total Operational Emissions 630.73

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 68 Source: LDN 2024b.

Note: Data is presented in decimal format and may have rounding errors.

Construction Emissions – General Plan Buildout Scenario The GP Buildout scenario would have a smaller construction footprint when compared to the proposed project. A construction model was prepared based on default settings within CalEEMod. The equipment list as well as durations are provided in Attachment B of the air quality report (Appendix F.1 of this document). Table 12 shows the construction emissions from the GP Buildout Scenario. As noted, the construction emissions are not the same since the building land uses and building areas are different.

Table 12. General Plan Buildout Scenario Construction-Related GHG Emissions (MT/Year) Year Bio-CO2 NBio-CO2 Total CO2 CH4 N2O
Total CO2e
(metric
tons/year)
2024 0.00 360.94 360.94 0.07 0.01 364.76
2025 0.00 2.64 2.64 0.00 0.00 2.64
Total Construction Emissions 367.40
Yearly Average Construction Emissions (Metric Tons/year over 30 years) 12.25 Source: LDN 2024b.

Operational Emissions – General Plan Buildout Scenario
Once construction is completed the GP Buildout scenario would generate GHG emissions . Under this scenario, since it is non-residential, not all the same CAP measures would apply but implementation of CAP measures would be required.

Table 13 indicates that the GP Buildout scenario would generate 907.69 MT CO 2e per year with
construction included and without incorporating any CAP measures.

Table 13. General Plan Buildout Scenario Operational Emissions Summary (MT/Year) Source Bio-CO2 NBio-CO2 Total CO2 CH4 N2O CO2e
(MT/Yr)
Area 0.00 0.00 0.00 0.00 0.00 0.00
Energy 0.00 121.47 121.47 0.01 0.00 121.93
Mobile 0.00 724.25 724.25 0.06 0.04 736.88
Waste 7.89 0.00 7.89 0.47 0.00 19.54
Water 0.87 13.31 14.18 0.09 0.00 17.09
Total Proposed Project Operational Emissions 895.44
Amortized Construction Emissions (Table 12above) 12.25
Total Operational Emissions 907.69
Source: LDN 2024b.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 69 Comparison of the Proposed Project and the General Plan Buildout Scenario The proposed project would generate 630.73 MT CO 2e and the GP Buildout scenario would generate 907.69 MT CO2e using similar modeling methodology representative of the expected projects. When the proposed project’s GHG emissions are compared to the GHG emissions estimated under the GP Buildout scenario, the project would have an estimated 31% less intense carbon footprint than would otherwise be assumed under the buildout assumed in the Heart of the City Specific Plan. This is driven largely by the reduced number of vehicle trips that would occur under the proposed project compared to buildout under the existing commercial designation in the Heart of the City Specific Plan.

The project would also implement all of the CAP Checklist measures that are applicable to multi -family housing. Projects that propose a General Plan Amendment and have GHG emissions that are less than would be anticipated for a project that would be consistent with the General Plan and implement CAP GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects. The CAP Checklist provides a streamlined review process for the GHG emissions analysis of proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA. As such, the proposed project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Impacts would be less than significant. b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases? Less Than Significant Impact The proposed project was found to emit 630.73 MT CO2e per year and the GP Buildout scenario would generate 907.69 MT CO2e per year. The project would therefore result in a less intense carbon footprint by 31% when compared to what would otherwise be assumed in the City’s General Plan. CAP consistency can be assumed as long as the amendment results in an equivalent or less GHG -intensive project when compared to the existing designations. In addition to providing evidence to support the conclusion that the project would generate fewer emissions than existing designations, these projects would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist. Step 2 of the CAP Checklist is the CAP Measures Consistency. The proposed project would implement all of the CAP Checklist measures that are applicable to multi-family housing. Based on this, impacts would be less than significant.

4.9 Hazards and Hazardous Materials
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Create a significant hazard to the public or the
environment through the routine transport, use
or disposal of hazardous materials?
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 70 Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
X
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
X
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
X
e) For a project located within an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public airport or
public use airport, would the project result in a
safety hazard or excessive noise for people
residing or working in the project area?
X
f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
X
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
X

A Phase 1 Environmental Site Assessment (ESA) was prepared for the project site by Marc Boogay Consulting Engineer (MBCE) (2017). The complete report is included as Appendix G of this document. a) Create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials? Less Than Significant Impact Hazardous materials include solids, liquids, or gaseous materials that, because of their quantity, concentration, or physical, chemical, or infectious characteristics could pose a threat to human health or the environment. Hazards include the risks associa ted with potential explosions, fires, or release of hazardous substances in the event of an accident or natural disaster, which may cause or contribute to an increase in mortality or serious illness or pose substantial harm to human health or the environment.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 71 The proposed project would involve the transport of fuels, lubricants, and various other liquids needed for operation of construction equipment at the site on an as -needed basis by equipment service trucks.

In addition, workers would commute to the project site via private vehicles and would operate construction vehicles and equipment on both public and private streets. Materials hazardous to humans, wildlife, and sensitive environments, including diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets, would be present during project construction. The potential exists for direct impacts to human health from accidental spills of small amounts of hazardous materials from construction equipment; however, the proposed project would be required to comply with Federal, State, and City Municipal Code restrictions which regulate and control those materials handled onsite. Compliance with these restrictions and laws would ensure that potentially significant impacts would not occur during project construction.

In addition, as a multi-family senior residential project, the only hazardous materials anticipated for transport or disposal associated with the proposed project during operation are routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries, and garden maintenance products. It is anticipated that the use, handling, and disposal of these products would be addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan of the County of San Diego and other Federal, State, and City Municipal Code regulations.

In summary, the project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impacts would be less than significant. b) Create a significant hazard to the public or the environment through reasonabl y foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Less Than Significant Impact
Based on a review of historical information, as detailed in the Phase 1 ESA for the project (MBCE 2017), the project site has been vacant since at least 1939.

Recognized Environmental Conditions
A recognized environmental condition (REC) is defined by ASTM E1527 -13 as the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment.

The Phase 1 ESA report determined that there was no evidence of recognized environmental conditions (REC) in relation to the project site for past or current use (MBCE 2017).

Site Observations
As part of the Phase I ESA performed for the project site, MBCE performed a site visit and characterized the site as vacant with heavy brush in the creek area. Minor quantities of inert debris were observed on the project site. No indications of materials release were identified and no RECs were inferred (MCBE 2017).

In summary, there are no identified conditions on the project site that would create a scenario whereby the project would create a significant hazard to the pub lic or the environment through reasonabl y

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 72 foreseeable upset and accident conditions involving the release of hazardous materials. Impacts would be less than significant.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No Impact The project site is not located within a one-quarter mile of an existing or proposed school. The closest schools to the project site are San Marcos Elementary School, which is located approximately 0.40 miles to the southwest, San Marcos Middle School, located approximately 0.80 miles to the west , and Mission Hills High School, located approximately one mile to the east. The project does not propose uses that would emit hazardous emissions or handle hazardous or acutely hazardous materials or substances and no schools are located within 0.25 miles of the project s ite. No hazards emissions impact to the adjacent school are anticipated and no impact is identified.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact
A comprehensive records and database search was conducted in conjunction with the preparation of the Phase 1 ESA. The records search was completed by EDR and the project site was not listed in any of the hazardous sites databases. The project site is not identified on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. As described above, there were no RECs identified for the project site.

Surrounding properties within a one- mile radius were included in the database search. The Phase 1 ESA focused on those listings that were within 1/3 -mile radius of the project site. These listings , and their states are described as follows:
• United States Postal Service at 420 North Twin Oaks Valley Road was found listed on 1) the Leaking Underground Storage Tank (LUST) database with a “completed -case closed”; and 2) in the San Diego County Site Assessment and Mitigation Program (SAM) database with a soils-only “closed case” and with a history of undergrounds tanks with regular unleaded motor vehicle fuel. • Timothy Chatton at 204 W . Mission Road was found listed in the 1) LUST database base with a “completed-case closed” for a gasoline contamination; 2) San Diego County SAM database with a “closed case” status for drinking water aquifer impacted; and 3) Spills, Leaks, Investigations and Cleanups (SLIC) database with a “completed-case closed” status for a gasoline contamination. • CRLLC #2705250 at 190 W . San Marcos Boulevard was found listed on the LUST database with a “completed-case closed” status for a gasoline contamination dated 12/10/2013. • City of San Marcos at 256 W. Mission Road was found on the US BROWNSFIELDS database for contamination found during a Phase II Environmental Assessment. The contaminants descriptions were reportedly: Methyl tert-butyl ether (MTBE), benzoapyrene, acetophenone, benzobfluoranthene, dibenzoa and hanthracene. The description of operations w as residential, hardware store, service station and auto repair station. • Foreign Car Specialists at 256 W. Mission Road was found on the 1) LUST database with a “completed-case closed” status for a gasoline, benzene, toluene, xylene, and diesel

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 73 contamination; 2) the San Diego County SAM database with a “closed case” status; and 3) the SLIC database with a “completed-case closed” status for a gasoline contamination. • San Marcos Forest Fire Station at 236 Pico Ave was found on the 1) San Diego County SAM database with a “remedial investigation” with preliminary site assessment work plan submitted for an unleaded gasoline contamination dated 5/14/1997 and 2) LUST database with a “completed-case closed” status for a gasoline contamination.

All of these identified sites were closed cases and with consideration of groundwater flow and distance , they were deemed environmental concerns not rising to the level of a recognized environmental condition. As mentioned, the project site is not identified on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Any of the listed sites identified in the vicinity of the project site have been determined to be low risk to the project site. Therefore, implementation of the proposed project would not create a significant hazard to the public pursuant to Government Code Section 65962.5. No impact is identified.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact The nearest airport is the McClellan-Palomar Airport in Carlsbad, which is located approximately seven miles west of the project site. While the proposed project is not within two miles of a public airport or public use airport, according to Figure 6-5 of the Safety Element of the City’s General Plan, the project site is located within Review Area 2 of the airport influence area. This influence area is regulated by the Airport Land Use Commission, which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and overflight factors. Review Area 2 limits the heights of structures in areas of high terrain. The project site would not be characterized as high terrain. Therefore, the project would not result in a safety hazard for people residing or working in the project area. No impact would occur. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Less than Significant Impact The project does not propose any development that would impair implementation of or physically interfere with any adopted emergency response plan or evacuation plan. Construction of the project would not result in any road closures. In addition, the San Ma rcos Fire Department (SMFD) has reviewed the project and has not identified any issues related to emergency response planning or emergency evacuation planning. Impacts would be less than significant. g) Expose people or structures , either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? Less than Significant The project site is located in an urbanized area of the City. The western portion of the project site contains denser vegetation associated with Twin Oaks Valley Creek. The Fire Marshal has reviewed the project and standard City fire conditions have been a pplied to the project. The project site is identified as being in a non-Very High Fire Hazard Severity Zone per CalFire (20 24). Therefore, the project would not expose people or structures to a significant risk of loss, injury or death involving wildland fires. Impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 74 4.10 Hydrology and Water Quality
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?
X
b) Substantially deplete groundwater supplies or
interfere substantially with groundwater
recharge such that there the project may impede
substantial groundwater management of the
basin?
X
c) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river or
through the addition of impervious surfaces, in a
manner which would result in substantial
erosion or siltation on- or off-site?
X
d) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river or
through the addition of impervious surfaces, in a
manner which would substantially increase the
rate or amount of surface runoff in a manner
which would result in flooding on- or off-site?
X
e) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river or
through the addition of impervious surfaces, in a
manner which would exceed the capacity of
existing or planned stormwater drainage
systems or provide substantial additional sources
of polluted runoff?
X
f) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
X
g) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 75 Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
h) Result in significant alteration of receiving water
quality during or following construction?
X
i) Result in an increase in pollutant discharges to
receiving waters? Consider water quality
parameters such as temperature, dissolved
oxygen, turbidity, and other typical storm water
pollutants (e.g., heavy metals, pathogens,
petroleum derivatives, synthetic organics,
sediment, nutrients, oxygen-demanding
substances, and trash).

X
j) Be tributary to an already impaired water body
as listed on the Clean Water Act Section 303(d)
list? If so, can it result in an increase in any
pollutant for which the water body is already
impaired?
X
k) Be tributary to environmentally sensitive areas
(e.g., MSCP, RARE, Areas of Special Biological
Significance, etc.)? If so, can it exacerbate
already existing sensitive conditions?
X
l) Have a potentially significant environmental
impact on surface water quality, to either
marine, fresh or wetland waters?
X

A preliminary storm water quality management plan (SWQMP) was prepared for the project by K&S Engineering (2025) and is included as Appendix H.

Existing Site Conditions
The existing site condition surface drains from the east to the west side towards the existing culvert box that drains to San Marcos Creek, project does not have an underground storm drain system. The site is undeveloped and with grown vegetation. There is no off-site contribution to the site.

Proposed Conditions
T
he project has been designed to be elevated above the 100- year storm event base flow elevation. The
project applicant would be required to process a full CLOMR/LOMR application through FEMA.

In
the developed condition, site surface drains would drain from east to west towards a 48-inch x 48-inch inlet that captures the runoff and then an 18 -inc PVC underground pipe would direct to the proposed underground 45-inch chambers. The storm drain system in the landscape areas around the building would

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 76 also direct runoff to the chambers. Additionally, the concrete brow ditch on top of the proposed retaining wall would capture the runoff produced on the slopes and be directed to the chambers.

The Hydromodification Management Plan ( HMP) and peak runoff discharge (Q peak) detention will take place by the proposed 45-inch chambers. The threshold for peak from is the 100-year storm. Then runoff would be directed to a proposed modular wetland for BMP treatment purposes and then directed to Twin Oaks Valley Creek and then to the culvert box. At the proposed driveway on E. Mission Road the project design incorporates a surface of permeable pavers as pollutant control and hydromodification BMP which allows percolation through void spaces into surface layers. a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? Less than Significant Impact The project site is located in the Carlsbad hydrologic unit (904) and Richland hydrologic subarea (904.52) of the Carlsbad watershed (904). Impaired water bodies in this watershed, as listed in the State Water Resources Control Board (SWRCB) 303(d) impaire d waters list, include San Marcos Creek (dichlorodiphenyldichloroethylene (DDE)), phosphorus, sediment toxicity, and selenium), Lake San Marcos (ammonia as nitrogen and nutrients), Batiquitos Lagoon (total coliform) and the Pacific Ocean (total coliform).

Construction of the project would involve ground -disturbing activities associated with grading and could result in sediment discharge to in stormwater runoff. Additionally, construction activities would involve the use of oil, lubricants and other chemical s that could be discharged from leaks or accidental spills.

These discharges would have the potential to impact water quality in receiving water bodies.

The applicant would be required to comply with the National Pollutant Discharge Elimination System (NPDES) permit. Regionally, this is achieved by preparing and implementing a Stormwater Quality Management Plan (SWQMP) based on the standards set forth in City of San Marcos BMP Design Manual (San Marcos 2025). The SWQMP would require implementation of water quality best management practices (BMPs) to ensure that water quality standards are met and that stormwater runoff from construction areas do not result in a degradation of water quality in receiving water bodies. The preliminary SWQMP prepared for this project indicates the project would meet the requirements of the BMP Design Manual. As such, impacts would be less than significant. b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? No Impact
Implementation of the project would not use any groundwater. Therefore, the project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. No impact is identified for this issue area.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off -site? Less than Significant Impact

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 77 Under existing conditions, runoff from the site discharges via overland flow to the adjacent Twin Oaks Valley Creek located west of the project site. In the develop ed condition, runoff from the project site is drained to one onsite underground detention facility. Peak flows are routed via the underground system and then conveyed to the adjacent Twin Oaks Valley Creek.

The project has been designed to generally match the existing drainage pattern of the site and would direct flows to the proposed underground detention facility. Implementation of the proposed project would increase impervious surfaces but would not substantially alter the existing drainage pattern of the site that would result in substantial erosion or s iltation on- or off-site. Twin Oaks Valley Creek is located along the western portion of the site; however, the project has been designed to avoid any development in that area and within associated riparian habitat areas.

The project would implement construction BMPs in compliance with the Construction General Permit.

These BMPs focus on areas such as good site management/housekeeping, non-stormwater management, erosion control, sediment control, run-on and run-off control, inspection/ maintenance/repair, rain event action plan, and monitoring/reporting requirements. Implementation of stated BMPs would further reduce the potential for erosion and siltation to enter project area waterways. Impacts would be less than significant.
d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Less than Significant Impact While implementation of the project would increase impervious surfaces, it would not alter the course of a stream or river. The project has been designed to be elevated above the 100-year storm event base flow elevation and outside of a regulatory floodway. Also, the use of a private storm drain system and underground infiltration facility would meet required hydromodification and detention requirements.

The proposed underground infiltration facility would be designed with an infiltration storage volume (a function of the surface ponding volume) equal to the full design capture volume and would be able to meet drawdown time limitations. The underground infiltration facility consists of an open bottom chamber system and would also assist in hydromodification flow control. The new development would alter existing drainage characteristics and patterns so that runoff in the post -developed condition does not exceed that of the pre-developed condition for flows durations. Therefore, the project would not alter existing drainage patterns of the site area in a manner that would result in a substantial increase to the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Impacts would be less than significant.
e) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would exceed the capacity of existing or planned st ormwater drainage systems or provide substantial additional sources of polluted runoff? Less than Significant Impact While implementation of the project would increase impervious surfaces, it would not alter the course of a stream or river. Twin Oaks Valley Creek is located along the western portion of the site; however, the project has been designed to avoid any development in that area and within associated riparian habitat areas. The project proposes a comprehensive stormwater management plan that includes stormwater

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 78 improvements within the project boundary. This includes the use of a private underground infiltration basin for treatment and hydromodification detention purposes. Construction of these features is proposed within the development footprint for the project; an expansion of existing facilities would not be required to serve the project. Therefore, the project would not create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. Impacts would be less than significant. f) In flood hazards, tsunami or seiche zones, risk release of pollutants due to project inundation? No Impact.

The proposed project site is not located within a tsunami evacuation area; therefore, damage due to tsunamis would not occur. Seiches are periodic oscillations in large bodies of water such as lakes, harbors, bays, or reservoirs. The proposed project is also not located immediately adjacent to any lakes or confined bodies of water; therefore, the potential for a seiche to affect the property is considered low.

The project site is relatively flat with elevations of approximately 571 to 611 feet amsl. Per FEMA, portions of the project site are located within Zone X and Zone AE and a regulatory floodway. Proposed grading activities include the import of up to 23,254 cy of materials to raise building pad elevations above the flood zone. The project is not cons tructing any structures within the floodway. The project has been designed to be elevated above the 100-year storm event base flow elevation. The project applicant would be required to process a full CLOMR/LOMR application through FEMA. In addition, the project proposes a comprehensive stormwater management plan that includes an underground infiltration basin within the project boundary. This facility was designed to accommodate 100-year 6-hour storm flows and to meet hydromodification requirements and peak flow attenuation. No impact is identified for this issue area. g) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Less than Significant Impact The project would not use any groundwater or affect direct infiltration and saturation. Therefore, implementation of the proposed project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. As such, the potential impacts would be less than significant.
h) Result in significant alteration of receiving water quality during or following construction? Less than Significant Impact
The applicant would be required to comply with the NPDES permit. Regionally, this is achieved by preparing and implementing a SWQMP based on the standards set forth in the City of San Marcos BMP Design Manual (San Marcos 2025). The SWQMP would require implementation of water quality BMPs to ensure that water quality standards are met and that stormwater runoff from construction areas do not result in a degradation of water quality in receiving water bodies. The preliminary SWQMP prepared for this project indicates the project would meet the requirements of the BMP Design Manual. Further the project is being designed to comply with the current HMP Requirements which includes addressing both flow-control and critical coarse sediment. Therefore, the project would not result in significant alteration of receiving water quality during or following construction. Impacts would be less than significant. i) Result in an increase in pollutant discharges to receiving waters ? Consider water quality parameters such as temperature, dissolved oxygen, turbidity, and other typical storm water

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 79 pollutants (e.g., heavy metals, pathogens, petroleum derivatives, synthetic organics, sediment, nutrients, oxygen-demanding substances, and trash). Less than Significant Impact Potential construction-related impacts associated with receiving water quality would include siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site. To minimize these potential sources of pollution, the project would incorporate construction-related water quality BMPs. Such measures could include, but are not limited to:
• Use of sediment trapping devices to control sediment runoff; • Proper containment and disposal of trash/debris;
• Use of erosion control devices to minimize runoff during rain events; and • Additional measures identified in the SWPPP that would be implemented prior to the commencement of on-site work.

These measures are designed to minimize the generation of pollutants, inducing sediment and trash/debris. Preparation and implementation of a SWPPP and construction -related water quality BMPs would ensure that there are no significant alterations to receiv ing water quality during project construction. During project operation, the project includes a comprehensive water quality management approach including implementing a variety of site design, source control, and treatment control BMPs to treat anticipated pollutants of concern and minimize the potential for pollutants prior to reaching the storm drain and off -site waterways. Therefore, the project would not result in significant alteration of receiving water quality during or following construction. Impacts would be less than significant. j) Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pollutant for which the water body is already impaired? Less than Significant Impact
The project site is located in the Carlsbad hydrologic unit (904) and San Marcos hydrologic subarea (904.52) of the Carlsbad watershed (904). Impaired water bodies in this watershed, as listed in the SWRCB 303(d) impaired waters list, include San Marcos Creek ( dichlorodiphenyldichloroethylene (DDE)), phosphorus, sediment toxicity, and selenium), Lake San Marcos (ammonia as nitrogen and nutrients), Batiquitos Lagoon (total coliform) and the Pacific Ocean (total coliform).

According to the preliminary SWQMP prepared for the project, anticipated pollutants to be generated by the project include sediment, nutrients, heavy metals, trash/debris, oxygen demanding substances, oil/grease, bacteria/ viruses, and pesticides. As identified above, the project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. The project proposes a comprehensive water quality approach including an underground infiltration basin. Pollutant control is provided via infiltration, sorption, sedimentation, and biodegradation processes.

The proposed BMPs would be subject to regular inspection and maintenance. The property owner would be required, pursuant to the City’s Municipal Code Section 4.14 and City of San Marcos BMP Design Manual to enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to the issuance of permits. Since the project includes a comprehensive approach to the handling and treatment of on -site stormwater runoff and

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 80 would achieve a medium or high efficiency for removal of anticipated pollutants, the project would not result in an increase in pollutant discharges to receiving waters. Impacts would be less than significant.

Since the project includes a comprehensive approach to the handling and treatment of on-site stormwater runoff and would achieve a medium or high efficiency for removal of anticipated pollutants, the project would not result in an increase in any pollutant for which area impaired water bodies are already impaired.

Impacts would be less than significant.
k) Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.) ? If so, can it exacerbate already existing sensitive conditions ? Less than Significant Impact
As identified above, impaired water bodies in the Carlsbad watershed include San Marcos Creek and Lake San Marcos. The project proposes a comprehensive water quality approach including a storm drain system and underground infiltration basin. Pollutant control is provided via infiltration, sorption, sedimentation, and biodegradation processes. The City’s BMP Design Manual requires that the pollutants of concern for each impaired water body in each watershed be treated by engineered treatment controls to a medium pollutant removal efficiency or better prior to leaving each development site, thus reducing pollutant levels. The proposed BMPs would be subject to regular inspection and maintenance. The property owner would be required, pursuant to the City’s Municipal Code Section 4.14 and BMP Design Manual to enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to the issuance of permits. Therefore, the project would not exacerbate already sensitive conditions within environmentally sensitive areas. Impacts would be less than significant.
l) Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters? Less than Significant Impact
The project site is located within an FPA of the MHCP. The project site is located in a developed portion of the city and adjacent to Twin Oaks Valley Creek . The project design avoids any direct impact to wetlands. To minimize impacts to these sensitive areas, the project includes a comprehensive water quality management approach to ensure there would not be an increase in pollutant discharge to receiving waters. Impacts would be less than significant.

4.11 Land Use and Planning
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Physically divide an established community? X
b) Cause a significant environmental impact due to
a conflict with any land use plan, policy, or
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 81 Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
regulation adopted for the purpose of avoiding
or mitigating and environmental effect?
The project applicant is requesting approval of a General Plan Amendment (GPA17 -0003), Specific Plan Amendment (SP17-0004) and a Multi-Family Site Development Plan (MFSDP19-0001) to construct a four- story 115-unit senior residential development. The General Plan Amendment would be for a graphical change to modify graphics in the General Plan Land Use Element including Figure 2-3 – Specific Plan Areas and Figure 2-5 – Land Use Plan. The Specific Plan Amendment would amend the Heart of the City Specific Plan to allow for a Senior Residential use. The Site Development Plan would be required to construct 115 senior residential units and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.

This section analyzes the potential for the proposed project to have impacts related to land use and planning. Although not required under CEQA, a Local Transportation Analysis (LTA) was prepared for the project to analyze automobile delay/Level of Service (LOS) . The LOS analysis was conducted to identify roadway deficiencies in the project study area and to recommend project improvements to address such deficiencies, if identified. The LTA is included as Appendix J.1 . The LTA is incorporated and addressed in this section as it relates to consistency with the City’s Mobility Element policies in the General Plan. a) Physically divide an established community? No Impact The project site is currently vacant in a developed portion of the city. The project would not divide an established community. The existing sidewalks along the project frontage would be retained to allow for pedestrian connectivity in the project vicinity. No impact would occur. b) Cause a significant environmental impact due to a conflict with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating and environmental effect? Less than Significant Impact
Mobility Element Level of Service Analysis
A Traffic Impact Study was prepared for the project in accordance with the SANTEC/ITE Guidelines for Traffic Impact Studies in the San Diego Region (March 2000) by Urban Systems Associates, Inc (September 2019). This section discusses the LOS analysis for the project and addresses the project’s consistency with the City’s Mobility Element policies in the General Plan.

Study Area
The study area consists of the following study roadway segments:
• Twin Oaks Valley Road, from Borden Road to Richmar Avenue • Twin Oaks Valley Road, from Richmar Avenue to San Marcos Boulevard

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 82 • San Marcos Boulevard, from Twin Oaks Valley Road to E. Mission Road • Woodward Street, from E. Mission Road to Vineyard Road • Woodward Street, from Vineyard Road to Borden Road
• Borden Road, from Twin Oaks Valley Road to Woodward Street The study area consists of the following study intersections:
• Twin Oaks Valley Road at Borden Road
• Woodward Street at Borden Road
• Twin Oaks Valley Road at Richmar Avenue
• Woodward Street at E. Mission Road
• Twin Oaks Valley Road at San Marcos Boulevard
The traffic study analyzed the following scenarios during typical weekday AM and PM peak hour conditions:
• Existing Conditions
• Existing Plus Project
• Near Term Without Project
• Near Term Plus Project
• Horizon Year 2035 Without Project
• Horizon Year 2035 Plus Project
Project Trip Generation
As shown in Table 14, the project would generate 460 total ADT, including 23 trips in the AM Peak hour and 32 trips in the PM peak hour. Trip generation rates were based on the SANDAG (Not So) Brief Guide to Vehicular Traffic Generation Rates (SANDAG 2002).

Table 14. Project Trip Generation

TRIP GENERATION RATES
Use Rate

AM PEAK HOUR PM PEAK HOUR
% of
ADT In: Out Ratio % of
ADT In: Out Ratio
Retirement
Community 4/unit 5% 0.40 : 0.60 7% 0.60 : 0.40

TRIP GENERATION CALCULATIONS
Land Use Amount ADT

AM PEAK HOUR PM PEAK HOUR
Total In Out Total In Out

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 83 TRIP GENERATION RATES
Retirement
Community 115 units 460 23 9 14 32 19 13
Source: SANDAG 2002.

Note: ADT=Average Daily Trips
Thresholds of Significance
Based on the performance standards established by the City of San Marcos, the project would result in an inconsistency with the Mobility Element of the General Plan if:
• The addition of project generated trips is forecast to cause the performance of a study intersection to deteriorate from acceptable Level of Service (D or better) to unacceptable Level of Service (E or F); or,
• The addition of project generated trips is forecast to worsen the performance of a study intersection operating at unacceptable Level of Service (E or F) in the baseline condition. A project related increase of 0.02 in volume to capacity ratios in Roadway Segments or an increase of 2 seconds delay for intersections would be considered a cumulatively significant impact.

Existing Conditions – Roadway Segments
Table 15 shows the study roadway segment LOS for existing conditions. As shown in Table 15, all roadway segments currently operate at acceptable LOS in the existing condition scenario.

Table 15. Existing Roadway Segment LOS
Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Twin Oaks
Valley Road
Borden
Road Richmar Avenue 4 40,000 28,115 0.70 C Acceptable
Twin Oaks
Valley Road
Richmar
Avenue
San Marcos
Boulevard 4 40,000 27,109 0.68 C Acceptable
San Marcos
Boulevard
Twin Oaks
Valley Road
East Mission
Road 4 40,000 16,882 0.42 B Acceptable
Woodward
Street
East Mission
Road
Vineyard
Road 4 30,000 7,816 0.26 A Acceptable
Woodward
Street Vineyard Road Borden
Road 2 15,000 3,781 0.25 A Acceptable
Borden Road Twin Oaks
Valley Road
Woodward
Street 4 30,000 10,325 0.34 B Acceptable
Source: Urban Systems Associates 2019.

Notes: ADT = Average Daily Traffic Volume
V/C = Volume to Capacity Ratio.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 84 Existing Conditions - Intersections
Error! Reference source not found.6 shows the intersection LOS for Existing conditions. As shown in Table 16, the study intersections currently operate within acceptable LOS D or better during the peak hours for Existing conditions with the exception of Twin Oaks Valley Road at San Marcos Boulevard, which operates at LOS E during both AM and PM Peak hours.

Table 16. Existing Intersection LOS
Study Intersection Traffic Control
AM Peak Hour PM Peak Hour
Delay LOS Delay LOS
Twin Oaks Valley Road at
Borden Road Signalized 43.1 D 37.7 D
Woodward Street at
Borden Road Signalized 29.2 C 40.4 D
Woodward Street at
Vineyard Road Signalized 16.1 B 9.2 A
Twin Oaks Valley Road at
Richmar Avenue Signalized 20.0 B 30.1 C
Woodward Street at
East Mission Road Signalized 46.1 D 50.1 D
Twin Oaks Valley Road at
San Marcos Boulevard Signalized 55.5 E 66.6 E
Source: Urban Systems Associates 2019.

Notes: Delay= seconds per vehicle
Existing Plus Project Analysis – Roadway Segments
The study roadway segment LOS for the Existing Plus Project conditions are shown in Table 17. As shown in Table 17, all of the study roadway segments are forecast to continue operating at acceptable LOS for the Existing Plus Project condition and the project does not result in an unacceptable reduction in capacity.

Table 17. Existing + Project Roadway Segments LOS
Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Twin Oaks
Valley Road Borden Road Richmar Avenue 4 40,000 28,221 0.71 C Acceptable Twin Oaks
Valley Road
Richmar
Avenue
San Marcos
Boulevard 4 40,000 27,224 0.68 C Acceptable
San Marcos
Boulevard
Twin Oaks
Valley Road
East Mission
Road 4 40,000 17,006 0.43 B Acceptable

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 85 Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Woodward
Street
East Mission
Road Vineyard Road 4 30,000 8,046 0.27 A Acceptable
Woodward
Street Vineyard Road Borden Road 2 15,000 3,790 0.25 A Acceptable Borden Road Twin Oaks
Valley Road
Woodward
Street 4 30,000 10,367 0.35 B Acceptable
Source: Urban Systems Associates 2019.

Notes: ADT = Average Daily Traffic Volume
V/C = Volume to Capacity Ratio.

Existing Plus Project Analysis – Intersections
The intersection LOS for Existing Plus Project conditions are shown in Table 18. As shown in Table 18, the study intersections are forecast to operate within acceptable LOS D or better during the peak hours for Existing Plus Project conditions with the exception of Twin Oaks Valley Road at San Marcos Boulevard.

Table 18. Existing + Project Intersections LOS
Study Intersection Traffic Control
AM Peak Hour PM Peak Hour
Delay LOS Delay LOS
Twin Oaks Valley Road at
Borden Road Signalized 43.3 D 38.0 D
Woodward Street at
Borden Road Signalized 29.3 C 40.5 D
Woodward Street at
Vineyard Road Signalized 16.2 B 9.3 A
Twin Oaks Valley Road at
Richmar Avenue Signalized 20.0 B 30.1 C
Woodward Street at
East Mission Road Signalized 46.1 D 51.7 D
Twin Oaks Valley Road at
San Marcos Boulevard Signalized 55.6 E 66.7 E
Source: Urban Systems Associates 2019.

Notes: Delay= seconds per vehicle
Although there would continue to be an unacceptable LOS E for the intersection of Twin Oaks Valley Road at San Marcos Boulevard, as shown in Table 19, the addition of project traffic would result in an increase of 0.1 seconds in the AM and PM Peak hours. This is below the City threshold of an increase in delay of two seconds for intersections operating at LOS E or F. Therefore, the project will not create any unacceptable intersection delays in the Existing Plus Project scenario.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 86 Near Term Analysis
Near term volumes were calculated by applying an ambient growth factor of a 1% percent increase per year and added to the existing volumes for both street segment ADT and AM/PM peak hour intersection turning movement counts.

Near Term Without Project – Roadway Segments
The study roadway segment LOS for Near Term Without Project conditions are shown in Table 20. As shown in Table 20, the study roadway segments are forecast to continue operating at acceptable LOS for Near Term Without Project conditions.

Table 20. Near Term Without Project Roadway Segments LOS Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Twin Oaks
Valley Road Borden Road Richmar Avenue 4 40,000 29,521 0.74 C Acceptable Twin Oaks
Valley Road
Richmar
Avenue
San Marcos
Boulevard 4 40,000 28,464 0.71 C Acceptable
San Marcos
Boulevard
Twin Oaks
Valley Road
East Mission
Road 4 40,000 17,726 0.44 B Acceptable
Woodward
Street
East Mission
Road Vineyard Road 4 30,000 8,207 0.27 A Acceptable
Woodward
Street Vineyard Road Borden Road 2 15,000 3,970 0.26 A Acceptable Borden Road Twin Oaks
Valley Road
Woodward
Street 4 30,000 10,841 0.36 B Acceptable
Source: Urban Systems Associates 2019.

Notes: ADT = Average Daily Traffic Volume
V/C = Volume to Capacity Ratio.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 87 Table 19. Existing and Existing Plus Project Intersection Comparison Intersection
Existing Existing + Project
AM Peak Hour PM Peak Hour AM Peak Hour
Change Acceptable?
PM Peak Hour
Change Acceptable?
Delay LOS Delay LOS Delay LOS Delay LOS
Twin Oaks Valley Road
at Borden Road 43.1 D 37.7 D 43.3 D 0.2 Yes 38.0 D 0.3 Yes Woodward Street at
Borden Road 29.2 C 40.4 D 29.3 C 0.1 Yes 40.5 D 0.1 Yes Woodward Street at
Vineyard Road 16.1 B 9.2 A 16.2 B 0.1 Yes 9.3 A 0.1 Yes Twin Oaks Valley Road
at Richmar Avenue 20.0 B 30.1 C 20.0 B 0.0 Yes 30.1 C 0.0 Yes Woodward Street at
East Mission Road 46.1 D 50.1 D 46.1 D 0.0 Yes 51.7 D 0.6 Yes Twin Oaks Valley Road
at San Marcos
Boulevard

55.5 E 66.6 E 55.6 E 0.1 Yes 66.7 E 0.1 Yes

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 88 Near Term Without Project – Intersections
The study intersections LOS for Near Term Without Project conditions are shown in Table 21. As shown in Table 2 1, the study intersections are forecast to continue operating at acceptable LOS for Near Term Without Project conditions with the exception of Twin Oaks Valley Road at San Marcos Boulevard which would continue to operate at LOS E.

Table 21. Near Term Without Project Intersections LOS
Study Intersection Traffic Control
AM Peak Hour PM Peak Hour
Delay LOS Delay LOS
Twin Oaks Valley Road at
Borden Road Signalized 47.9 D 41 D
Woodward Street at
Borden Road Signalized 29.5 C 43.2 D
Woodward Street at
Vineyard Road Signalized 16.5 B 9.4 A
Twin Oaks Valley Road at
Richmar Avenue Signalized 21.1 C 32.4 C
Woodward Street at
East Mission Road Signalized 50.9 D 53.5 D
Twin Oaks Valley Road at
San Marcos Boulevard Signalized 61.5 E 72.6 E
Source: Urban Systems Associates 2019.

Notes: Delay= seconds per vehicle
Near Term With Project – Roadway Segments
The study roadway segment LOS for Near Term With Project conditions are shown in Table 22. As shown in Table 2 2 all of the study roadway segments are forecast to continue operating at acceptable LOS for Near Term Plus Project conditions.

Table 22. Near Term + Project Roadway Segments LOS
Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Twin Oaks
Valley Road Borden Road Richmar Avenue 4 40,000 29,627 0.74 C Acceptable Twin Oaks
Valley Road
Richmar
Avenue
San Marcos
Boulevard 4 40,000 28,579 0.71 C Acceptable
San Marcos
Boulevard
Twin Oaks
Valley Road
East Mission
Road 4 40,000 17,910 0.45 B Acceptable

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 89 Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Woodward
Street
East Mission
Road Vineyard Road 4 30,000 8,437 0.28 A Acceptable
Woodward
Street Vineyard Road Borden Road 2 15,000 3,979 0.27 A Acceptable Borden Road Twin Oaks
Valley Road
Woodward
Street 4 30,000 10,892 0.36 B Acceptable
Source: Urban Systems Associates 2019.

Notes: ADT = Average Daily Traffic Volume
V/C = Volume to Capacity Ratio.

Near Term With Project – Intersections
The study intersections LOS for Near Term Plus Project conditions are shown in Table 2 3. As shown in Table 23, the study intersections are forecast to continue operating at acceptable LOS for Near Term With Project conditions with the exception of Twin Oaks Valley Road at San Marcos Boulevard which would continue to operate at unacceptable LOS E. The project would increase the delay at the intersection by

0.1 seconds in the AM peak hour and 0.2 seconds in the PM peak hour. This is below the threshold of a two second increase in delay. Therefore, no direct impact would occur in the Near -Term Plus Project condition.

Table 23. Near Term + Project Intersections LOS
Study Intersection Traffic Control
AM Peak Hour PM Peak Hour
Delay LOS Delay LOS
Twin Oaks Valley Road at
Borden Road Signalized 48.2 D 42.1 D
Woodward Street at
Borden Road Signalized 29.5 C 43.3 D
Woodward Street at
Vineyard Road Signalized 16.5 B 9.4 A
Twin Oaks Valley Road at
Richmar Avenue Signalized 21.1 C 32.4 C
Woodward Street at
East Mission Road Signalized 50.9 D 53.6 D
Twin Oaks Valley Road at
San Marcos Boulevard Signalized 61.6 E 72.8 E
Source: Urban Systems Associates, 2019.

Notes: Delay= seconds per vehicle
Although there would continue to be an unacceptable LOS E for the intersection of Twin Oaks Valley Road at San Marcos Boulevard, as shown in Table 24, the addition of project traffic would result in an increase

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 90 of 0.1 seconds in the AM Peak Hour and 0.2 seconds in the PM Peak hour. This is below the City threshold of an increase in delay of two seconds for intersections operating at LOS E or F. Therefore, the project will not create any unacceptable intersection delays in the Near Term scenario.

Horizon Year 2035 Analysis
To determine the Horizon Year 2035 base volumes the SANDAG Transportation Forecast Information Center (TFIC) Series 13, Year 2035 was referred to initially. However , due to the TFIC containing volumes that are lower than the Existing volumes obtained on the same street segments, the TFIC was not used to determine the Horizon Year 2035 base volumes. Instead, the base volumes were determined by applying a 1 percent ambient growth factor per year from 2018 (counts obtained) to 2035. The growth factor was applied to street segment volumes and AM/PM peak hour turning movement count volumes.

Horizon Year 2035 Without Project Levels of Service – Roadway Segments The study roadway segment LOS for General Plan Buildout Without Project are shown in Table 25 As shown in Table 25, all of the study roadway segments are forecast to operate within acceptable LOS D or better for Horizon Year 2035 Without Project conditions.

Horizon Year 2035 Without Project Levels of Service – Intersections The intersection LOS for Horizon Year 2035 Without Project conditions are shown in Table 26. As shown in Table 2 6, the following study intersections are forecast to operate at unacceptable LOS (E or worse) during the peak hours for Horizon Year 2035 Without Project conditions:
• Twin Oaks Valley Road at Borden Road – LOS E, AM Peak • Woodward Street at East Mission Road – LOS E, AM and PM peak • Twin Oaks Valley Road at San Marcos Boulevard – LOS F, AM and PM peak Horizon Year 2035 Plus Project Levels of Service – Roadway Segments The study roadway segment LOS for Horizon Year 2035 Plus Project are shown in Table 2 7. As shown in Error! Reference source not found.27, all of the study roadway segments are forecast to operate within acceptable LOS D or better for Horizon Year 2035 Plus Project conditions.

Horizon Year 2035 Plus Project Levels of Service – Intersections The intersection Levels of Service for Horizon Year 2035 Plus Project conditions are shown in Table 28. As shown in Table 2 8 the following study intersections are forecast to operate at unacceptable Levels of Service E or worse during the peak hours for Horizon Year 2035 Plus Project conditions:
• Twin Oaks Valley Road at Borden Road – LOS E, AM Peak • Woodward Street at East Mission Road – LOS E, AM and PM peak Twin Oaks Valley Road at San Marcos Boulevard – LOS F, AM and PM peak

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 91 Table 24. Near Term and Near Term Plus Project Intersection Comparison Intersection
Near Term Near Term + Project
AM Peak Hour PM Peak Hour AM Peak Hour Change Acceptable? PM Peak Hour Change Acceptable? Delay LOS Delay LOS Delay LOS Delay LOS
Twin Oaks Valley Road
at Borden Road 47.9 D 41.0 D 48.2 D 0.3 Yes 42.1 D 1.1 Yes Woodward Street at
Borden Road 29.5 C 43.2 D 29.5 C 0.0 Yes 43.3 D 0.1 Yes Woodward Street at
Vineyard Road 16.5 B 9.4 A 16.5 B 0.0 Yes 9.4 A 0.0 Yes Twin Oaks Valley Road
at Richmar Avenue 21.1 C 32.4 C 21.1 C 0.0 Yes 32.4 C 0.0 Yes Woodward Street at
East Mission Road 50.9 D 53.5 D 50.9 D 0.0 Yes 53.6 D 0.3 Yes Twin Oaks Valley Road
at San Marcos
Boulevard

61.5 E 72.6 E 61.6 E 0.1 Yes 72.8 E 0.2 Yes

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 92 Table 25. Horizon Year 2035 Without Project Roadway Segments Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Twin Oaks
Valley Road Borden Road Richmar
Avenue 4 40,000 32,895 0.82 D Acceptable
Twin Oaks
Valley Road
Richmar
Avenue
San Marcos
Boulevard 4 40,000 31,718 0.79 D Acceptable
San Marcos
Boulevard
Twin Oaks
Valley Road
East Mission
Road 4 40,000 19,752 0.49 B Acceptable
Woodward
Street
East Mission
Road Vineyard Road 4 30,000 9,145 0.30 A Acceptable
Woodward
Street Vineyard Road Borden Road 2 15,000 4,424 0.29 A Acceptable Borden Road Twin Oaks
Valley Road
Woodward
Street 4 30,000 12,080 0.40 B Acceptable
Source: Urban Systems Associates, 2019.

Notes: ADT = Average Daily Traffic Volume
V/C = Volume to Capacity Ratio.
1% growth factor per year applied to existing volumes
Table 26. Horizon Year 2035 Without Project Intersections Study Intersection Traffic Control
AM Peak Hour PM Peak Hour
Delay LOS Delay LOS
Twin Oaks Valley Road at Borden Road Signalized 66.6 E 51.2 D Woodward Street at Borden Road Signalized 30.2 C 49.6 D Woodward Street at Vineyard Road Signalized 17.6 B 9.8 A Twin Oaks Valley Road at Richmar
Avenue Signalized 25.2 C 38.5 D
Woodward Street at East Mission Road Signalized 66.3 E 65.7 E Twin Oaks Valley Road at San Marcos
Boulevard Signalized 81.9 F 88.4 F
Source: Urban Systems Associates, 2019.

Delay= seconds per vehicle

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 93 Table 27. Horizon Year 2035 + Project Roadway Segments Roadway
Segment Analysis Capacity
Description
From To Lanes Capacity ADT V/C LOS
Twin Oaks
Valley Road Borden Road Richmar
Avenue 4 40,000 33,001 0.83 D Acceptable
Twin Oaks
Valley Road
Richmar
Avenue
San Marcos
Boulevard 4 40,000 31,833 0.80 D Acceptable
San Marcos
Boulevard
Twin Oaks
Valley Road
East Mission
Road 4 40,000 19,936 0.50 B Acceptable
Woodward
Street
East Mission
Road
Vineyard
Road 4 30,000 9,375 0.31 A Acceptable
Woodward
Street
Vineyard
Road Borden Road 2 15,000 4,433 0.30 A Acceptable
Borden Road Twin Oaks
Valley Road
Woodward
Street 4 30,000 12,131 0.40 B Acceptable
Source: Urban Systems Associates, 2019.

Notes: ADT = Average Daily Traffic Volume
V/C = Volume to Capacity Ratio.
1% growth factor per year applied to existing volumes
Table 28. Horizon Year 2035 + Project Intersections
Study Intersection Traffic
Control
AM Peak Hour PM Peak Hour
Delay LOS Delay LOS
Twin Oaks Valley Road at
Borden Road Signalized 66.6 E 51.3 D
Woodward Street at
Borden Road Signalized 30.4 C 49.7 D
Woodward Street at
Vineyard Road Signalized 17.7 B 9.9 A
Twin Oaks Valley Road at
Richmar Avenue Signalized 25.3 C 39.5 D
Woodward Street at
East Mission Road Signalized 67.2 E 65.7 E
Twin Oaks Valley Road at
San Marcos Boulevard Signalized 82.0 F 88.4 F
Source: Urban Systems Associates, 2019.

Notes: Delay= seconds per vehicle
Table 2 9 presents a comparison of the intersection performance for the Horizon Year 2035 and the Horizon Year 2035 Plus Project. As shown in Table 29, the increase in delay ranges from 0.0 seconds to 1.0

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 94 seconds. The increase in delay is less than 2 seconds for intersections operating at LOS E and F. Therefore, the project would not contribute to an unacceptable increase in delay in the Year 2035 scenario.

Contribution to City-wide Traffic
Although implementation of the proposed project would not result in significant impacts to LOS under existing, near-term and horizon year conditions, the project will contribute to City-wide traffic. As detailed in Table 1, Project Design Features, 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). Participation in CFD 2011-01 will assist in City-wide efforts to reduce traffic congestion and impacts to SR-78 and would offsite the project’s contribution to area roadways.

Other Plans and Policies
With impleme ntation of the Specific Plan Amendment to allow Senior Residential as a use within the HOCSP, the proposed use would be consistent. The project has been designed to meet the design requirements of the HOCSP.

The biological resources analysis included an analysis of the project’s consistency with the MHCP and the Draft San Marcos Subarea Plan. The project site is located within a FPA and the project has been designed to meet the design criteria and mitigation measures identified in the Draft San Marcos Subarea Plan.

Impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration May 2024 95 Table 29. Horizon Year 2035 and Horizon Year 2035 Plus Project Intersection Comparison Intersection
Year 2035 Year 2035 + Project
AM Peak Hour PM Peak Hour AM Peak Hour Change Acceptable? PM Peak Hour Change Acceptable? Delay LOS Delay LOS Delay LOS Delay LOS
Twin Oaks Valley Road
at Borden Road

66.6 E 51.2 D 66.6 E 0.0 Yes 51.3 D 0.1 Yes
Woodward Street at
Borden Road

30.2 C 49.6 D 30.4 C 0.2 Yes 49.7 D 0.1 Yes
Woodward Street at
Vineyard Road

17.6 B 9.8 A 17.7 B 0.1 Yes 9.9 A 0.1 Yes
Twin Oaks Valley Road
at Richmar Avenue

25.2 C 38.5 D 25.3 C 0.1 Yes 39.5 D 1.0 Yes
Woodward Street at
East Mission Road

66.3 E 65.7 E 67.2 E 0.9 Yes 65.7 E 0.0 Yes
Twin Oaks Valley Road
at San Marcos
Boulevard

81.9 F 88.4 F 82.0 F 0.1 Yes 88.4 F 0.0 Yes

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 96 4.12 Mineral Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in the loss of availability of a known
mineral resource that would be a value to the
region and the residents of the state?
X
b) Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific plan,
or other land use plan?
X
a) Result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the state? No Impact
There are no known mineral resources on the project site of value to the region or to residents of the state. The project site is currently vacant and located in a developed part of the City. Therefore, the project would not result in the loss of availability of a known mineral resource. No impact would occur. b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact There are no known locally important mineral resources identified on the project site . The project site is currently vacant and located in a developed part of the City . The project would not result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. No impact would occur.

4.13 Noise
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in
the vicinity of the project in excess of standards
established in the local genera plan or noise
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 97 Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
ordinance, or applicable standards of other
agencies?
b) Generation of excessive groundborne vibration
or groundborne noise levels?
X
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or,
where such a plan has not been adopted, within
two miles of a public airport or public use
airport, would the project expose people
residing or working in the project area to
excessive noise levels?
X

A noise assessment was prepared for the project by Ldn Consulting (LDN) (LDN 2024c) and is included as Appendix I of this document.
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies ? Less Than Significant Impact with Mitigation Incorporated
Construction-Related Noise Analysis
Construction noise represents a short -term impact on the ambient noise levels. Noise generated by construction equipment can reach relatively high levels. Grading activities typically represent one of the highest potential sources for noise impacts. No blasting or grading is proposed as part of the project. The most effective method of controlling construction noise is through local control of construction hours and by limiting the hours of construction to normal weekday working hours.

Grading and earthwork activity would be required to prepare the site for development. Based upon the proposed grading concept, the project requires 1,725 cy of cut and 24,979 cy of fill, for a net import of 23,254 cy. Soils import is expected to take approximately 55 days. Assuming a 20- cy hauling truck, this results in approximately 21 truck trips per day for soils import. No demolition or rock crushing is proposed.

The project would be required to comply with Chapter 10.24 of the San Marcos Municipal Code, which prohibits loud, annoying, or unnecessary noises. Section 10.24.020 provides definitions for and examples of prohibited noise sources. Included in the list of prohibited noise sources are building construction activities that occur Monday through Friday before 7:00 AM and after 6:00 PM or on Saturdays before 8:00 AM or after 5:00 PM. The project would also be required to comply with the grading operation restrictions listed in Section 17.32.180 of the San Marcos Municipal Code. This section of the code addresses the time limits that apply to grading, extraction, and blasting b etween 7:00 AM and 4:30 PM

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 98 Monday through Friday. Grading, extraction, or related earth moving is not allowed in the City on the weekends or holidays. The Municipal Code does not set noise limits on construction activities. Commonly, the City has utilized the County of San Diego’s N oise Ordinance noise limit of 75 dBA for construction activities. These limits to construction hours are included as project design features listed in Table 1.

The U.S. Environmental Protection Agency (U.S. EPA) has compiled data regarding the noise generating characteristics of specific types of construction equipment. Noise levels generated by heavy construction equipment can range from 60 dBA to in excess of 1 00 dBA when measured at 50 feet. However, these noise levels diminish rapidly with distance from the construction site at a rate of approximately 6 dBA per doubling of distance. For example, a noise level of 75 dBA measured at 50 feet from the noise source to the receptor would be reduced to 69 dBA at 100 feet from the source to the receptor and reduced to 63 dBA at 200 feet from the source. Additionally, sound levels are logarithmic not linear, so adding two sources of 68 dBA plus 68 dBA is equal to 71 dBA, not 136 dBA.

Using a point-source noise prediction model, calculations of the expected construction noise impacts were completed. The essential model input data for these performance equations include the source levels of each type of equipment, relative source to rece iver horizontal and vertical separations, the amount of time the equipment is operating in a given day, also referred to as the duty -cycle and any transmission loss from topography or barriers.

The equipment needed for the development would consist of up to two large bulldozers, a medium bulldozer, three medium sized scrapers, a medium sized front loader, a medium sized crawler type excavator, a medium sized compactor, two small to medium sized road graders, a medium sized rubber tire backhoe and a water truck. Based on the EPA noise emissions, empirical data and the amount of equipment needed, worst case noise levels from the construction equipment for site preparation would occur during the grading operations.

The grading activities would consist of the preparation of internal roadways, parking, and the finished pad. The grading equipment would be spread out over the project site from distances near the occupied property lines to distances of 400 feet or more away. Based upon the site plan the majority of the grading operations, on average, would occur more than 300 feet from the property lines. This means that most of the time the average distance from all the equipment to the nearest property line is 300 feet. As can be seen in Table 30 at an average distance of 300 feet from the construction activities to the nearest property line would result in a noise attenuation of -15.6 dBA without shielding. Additionally, the amount of time equipment is operating during a normal work day, referred to as duty-cycle, is utilized in this analysis.

Given this, the noise levels would comply with the 75 dBA Leq standard average over 8 hours at the property lines. Therefore, no impacts are anticipated and no mitigation is required during construction of the proposed project. Additionally, as noted in Table 1, Project Design Features, all equipment shall be properly fitted with mufflers and all staging and maintenance sh all be conducted as far away from the existing residence as possible.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 99 Table 30. Construction Noise Levels
Construction Equipment Quantity
Source Level @
50-Feet
(dBA Leq)
Duty Cycle
(Hours/Day)
Cumulative Noise Level
@ 50-Feet
(dBA Leq-8)
Dozer – D8 1 74 8 74.0
Dozer – D6 1 74 6 75.8
Scraper 3 75 8 79.8
Wheel Loader 1 73 8 73.0
Excavator 1 72 8 72.0
Compactor 1 74 6 72.8
Grader 1 73 4 70.0
Backhoe 1 72 4 69.0
Water Truck 1 70 8 70.0
Cumulative Levels @ 50 Feet 84.2
Average Distance to Property Line (Feet) 300
Noise Reduction Due to Distance -15.6
Nearest Property Line Noise Level 68.6
Source: LDN 2024c.

Operational-Related Noise Analysis
This section analyzes the potential for the project to increase ambient noise levels in the project vicinity above existing levels. It considers project-generated vehicular noise as well as stationary noise.

Transportation Noise Analysis
Existing Noise Environment Onsite
To determine the existing noise environment and to assess potential noise impacts, a 1 -hour measurement was taken at the project having a relatively flat terrain and no obstruction from trees or rock outcroppings. This was done to determine the worst-case conditions at the nearest proposed noise sensitive land use. The noise measurements were recorded by LDN on September 20, 2019 between 12:00 PM and 1:00 PM.

Noise measurements were taken using a Larson-Davis Model LxT Type 1 precision sound level meter, programmed, in "slow" mode, to record noise levels in "A" weighted form. The sound level meter and microphone were mounted on a tripod, five feet above the ground and equipped with a windscreen during all measurements. The sound level meter was calibrated before and after the monitoring using a Larson-Davis calibrator, Model CAL 200. The noise measurement location was determined based on-site access and noise impact potential to the proposed sensitive uses. Monitoring location 1 (M1) was located near the southern end of the project site adjacent to E. Mission Road. The noise monitoring location is provided graphically in Figure 8.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 100
Figure 8. Ambient Monitoring Location

Source: LDN 2024c.

The result of the noise level measurement is presented in Table 31. The ambient 24-hour CNEL noise levels measured in the area of the project was found to be roughly 58 dBA CNEL. The existing noise levels in the project area consisted primarily of traffic along E. Mission Road.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 101
Table 31. Measured Ambient Noise Levels
Measurement
Identification Description Time
Noise Levels (dBA)
CNEL Lmax Lmin L10 L50 L90
M1 Along E.

Mission Road
September 20, 2019
12:00 p.m. to 1:00 p.m. 57.8 69.8 49.0 61.3 55.7 51.4
Source: LDN 2024c.

Future Onsite Noise Prediction
To determine the future noise environment and impact potentials the Sound32 model was utilized. The critical model input parameters, which determine the projected vehicular traffic noise levels, include vehicle travel speeds, the percentages of automobiles, medium trucks and heavy trucks in the roadway volume, the site conditions, and the peak hour traffic volume. The peak hour traffic volumes range between 6-12% of the ADT and 10% is generally acceptable for noise modeling.

Table 32 presents the roadway parameters used in the analysis including the peak traffic volumes, vehicle speeds and the hourly traffic flow distribution (vehicle mix). The vehicle mix provides the hourly distribution percentages of automobile, medium trucks and heavy trucks for input into the Sound32 Model. The Buildout conditions include the future year 2035 traffic volume forecasts provided by the project’s traffic study (Urban Systems 2019).

Table 32. Future Traffic Parameters
Roadway Average Daily
Traffic (ADT)1
Peak Hour
Volumes(1)
Modeled
Speeds (MPH)
Vehicle Mix %(3)
Auto Medium
Trucks
Heavy
Trucks
E. Mission Road 14,100(1) 1,410 45 96 2 2
Woodward Street 9,145(2) 915 35 96 2 2
Source: LDN 2024c.

Notes: SANDAG Series 13 Traffic Prediction Model, Forecast Year 2035 Urban Systems 2018.

Typical vehicle mix
The required coordinate information necessary for the Sound32 model input was taken from the conceptual site plans. The conceptual plans were used to identify the pad elevations, roadway elevations, and the relationship between the noise source(s) and the outdoor receptor areas. To evaluate the potential noise impacts on the proposed development, outdoor observers were located in the common patio areas located on the north and east side of the building and placed five feet above the finished pad elevation. The modeled observer locations for the potential outdoor use areas are presented in Figure 9.

Private outdoor use areas would be provided by ground floor patios and second floor balconies which were modeled to determine if shielding/mitigation is required to reduce the noise levels below the City’s 65 dBA CNEL threshold.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 102
Figure 9. Modeled Receptor Locations

Source: LDN 2024c.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 103
Onsite Rail Line Noise
The proposed project is located a minimum of 160 feet from the San Diego Northern Railroad (SDNR) consisting of SPRINTER service operated by NCTD. According to the City of San Marcos General Plan Noise Element, the 65 dBA CNEL noise contour from the rail activity, with no shielding, is located 130 feet from the centerline of the railroad. No reduction factor was taken for the building facades.

Cumulative Onsite Noise Levels and Findings
Ground floor patios and upper floor balconies were modeled to determine if shielding/mitigation is required to reduce the noise levels below the City’s 65 dBA CNEL threshold. The noise levels determined for the roadway and train activities were combined to determine the overall cumulative noise levels at the proposed patios. The resultant cumulative noise levels from the traffic and train activities are provided below in Table 33 for the ground floor patios and Table 34 for the upper floor balconies.

Table 33. Combined Future Exterior Noise Levels (Ground Floor) Receptor Number
Unmitigated Noise
Levels from all
Sources
(dBA CNEL)
Proposed
Mitigation
Barrier Height
(Feet)
Outdoor Ground
Floor Noise Levels
with Mitigation
(dBA CNEL)1
Unshielded
Building Façade
Noise Levels
(dBA CNEL)1
1 69 4 65 69
2 69 4 65 69
3 68 4 65 69
4 68 4 65 69
5 64 4 64 66
6 64 4 64 65
7 62 4 62 63
8 62 4 62 --
Source: LDN 2024c.

Note: (1) Interior Noise Study required per City Guidelines if building façade is above 60 dBA CNEL.

Table 34. Combined Future Exterior Noise Levels (Upper Floors) Receptor Number
Unmitigated Noise
Levels from all
Sources
(dBA CNEL)
Proposed
Mitigation
Barrier Height
(Feet)
Balcony Noise
Levels with
Mitigation
(dBA CNEL)1
Unshielded
Building Façade
Noise Levels
(dBA CNEL)1
1 69 4 64 69
2 69 4 64 69
3 68 4 64 70
4 68 4 65 69
5 67 4 64 68

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 104
Receptor Number
Unmitigated Noise
Levels from all
Sources
(dBA CNEL)
Proposed
Mitigation
Barrier Height
(Feet)
Balcony Noise
Levels with
Mitigation
(dBA CNEL)1
Unshielded
Building Façade
Noise Levels
(dBA CNEL)1
6 66 4 63 67
7 65 4 62 66
Source: LDN 2024c.

Note: (1) Interior Noise Study required per City Guidelines if building façade is above 60 dBA CNEL.

As shown in these tables, unmitigated noise levels would exceed the City’s noise standard of 65 dBA CNEL at the outdoor usable areas (ground-floor patios and upper floor balconies) that front E. Mission Road and Woodward Street. This represents a significant impact ( Impact N-1) and mitigation is required to reduce impacts to below a level of significance. Implementation of mitigation measure MM-N-1, which would be required as a condition of project approval, would reduce this impact to below a level of significance.

MM-N-1 Patios and balconies in units that front E. Mission Road and Woodward Street, as detailed in Figure 10, shall require 4-foot barriers to reduce sound levels. The barriers must be constructed of non-gapping materials (i.e., masonry, stucco, ¼ inch thick glass or Plexiglas).

As shown in Tables 33 and 34, noise levels at the building facades are forecasted to be above 60 dBA CNEL.

As shown in Table 1, to ensure compliance with CCR Title 24, a final noise assessment is required prior to the issuance of the first building permit to identify the interior noise requirements based upon architectural and building plans. Interior noise levels of 45 dBA CNEL can be obtained with conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air conditioning) and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces).

Project Related Offsite Transportation Noise
To determine if cumulative off -site noise level increases associated with the development of the project and other planned or permitted projects in the vicinity would create noise impacts. The noise levels for the near-term project buildout and other planned and permitted projects were compared with the existing conditions. Utilizing the project’s traffic assessment (Urban Systems 2019) noise contours were developed for the following traffic scenarios:
• Existing: Current day noise conditions without construction of the project. • Existing Plus Project: Current day noise conditions plus the completion of the project. • Existing vs. Existing Plus Project: Comparison of the direct project related noise level increases in the vicinity of the project site.

The existing noise levels and reference distances to the 60 dBA CNEL contours for the roadways in the vicinity of the project site are given in Table 35 for the Existing Scenario and the Existing plus Project contours are provided in Table 36. No noise barriers or topography that may affect noise levels were incorporated in the calculations.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 105
Figure 10. Patio and Balcony Mitigation Locations

Source: LDN 2024c.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 106
Table 35. Existing Noise Levels
Roadway Roadway Segment ADT1
Vehicle
Speeds
(MPH)1
Noise Level
@ 50-Feet
(dBA CNEL)
60 dBA CNEL
Contour
Distance (Feet)
Twin Oaks
Valley Road
Borden Road to Richmar Avenue 28,115 45 73.7 1,179
Richmar Avenue to
San Marcos Boulevard 27,109 45 73.6 1,137
San Marcos
Boulevard
Twin Oaks Valley Road to
E. Mission Road 16,882 35 69.2 412
Woodward
Street
E. Mission Rd to Vineyard Road 7,816 40 67.0 253
Vineyard Rd to Borden Road 3,781 40 63.9 122
Borden Road Twin Oaks Valley Road to
Woodward Street 10,325 35 67.0 252
Source: LDN 2024c.

Notes: (1) ADT and MPH from project traffic study (Urban Systems 2019).

Table 36. Existing + Project Noise Levels
Roadway Roadway Segment ADT1
Vehicle
Speeds
(MPH)1
Noise Level
@ 50-Feet
(dBA CNEL)
60 dBA CNEL
Contour
Distance (Feet)
Twin Oaks
Valley Road
Borden Road to Richmar Avenue 28,221 45 73.7 1,184
Richmar Avenue to
San Marcos Boulevard 27,224 45 73.6 1,142
San Marcos
Boulevard
Twin Oaks Valley Road to
E. Mission Road 17,066 35 69.2 417
Woodward
Street
E. Mission Rd to Vineyard Road 8,046 40 67.2 260
Vineyard Rd to Borden Road 3,790 40 63.9 123
Borden Road Twin Oaks Valley Road to
Woodward Street 10,376 35 67.0 253
Source: LDN 2024c.

Notes: (1) ADT and MPH from project traffic study (Urban Systems 2019).

Table 37 presents the comparison of the Existing Year and the Existing Year plus project noise levels. The overall roadway segment noise levels would increase 0.2 dBA CNEL on one segment with development of the project. The other segments did not identify any noise increase. Impacts would be less than significant since the increase is less than 3 dBA CNEL on any roadway segment.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 107
Table 37. Existing vs. Existing + Project Noise Levels
Roadway Roadway Segment
Existing Noise
Level @ 50-Feet
(dBA CNEL)
Existing Plus
Project Noise
Level @ 50-Feet
(dBA CNEL)
Project Related
Noise Level
Increase
(dBA CNEL)
Twin Oaks
Valley Road
Borden Road to Richmar
Avenue 73.7 73.7 0.0
Richmar Avenue to
San Marcos Boulevard 73.6 73.6 0.0
San Marcos
Boulevard
Twin Oaks Valley Road to
E. Mission Road 69.2 69.2 0.0
Woodward
Street
E. Mission Rd to Vineyard
Road 67.0 67.2 0.2
Vineyard Rd to Borden Road 63.9 63.9 0.0
Borden Road Twin Oaks Valley Road to
Woodward Street 67.0 67.0 0.0
Source: LDN 2024c.

Cumulative Noise Impacts
To determine if cumulative off -site noise level increases associated with the development of the project and other planned or permitted projects in the vicinity would create noise impacts. The noise levels for the near-term Project Buildout and other planned and permitted projects were compared with the existing conditions. Utilizing the project’s traffic assessment (Urban Systems Associates, Inc., 2019) noise contours were developed for the following traffic scenarios:
• Existing: Current day noise conditions without construction of the project. • Existing Plus Cumulative Projects Plus Project: Current day noise conditions plus the completion of the project and the completion of other permitted, planned projects or approved ambient growth factors.
• Existing vs. Existing Plus Cumulative Plus Project: Comparison of the existing noise levels and the related noise level increases from the combination of the project and all other planned or permitted projects in the vicinity of the site.

The existing noise levels and reference distances to the 60 dBA CNEL contours for the roadways in the vicinity of the project site are given in Table 35 above for the Existing Scenario. The near-term cumulative noise conditions are provided in Table 38. No noise barriers or topography that may affect noise levels were incorporated in the calculations.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 108
Table 38. Existing + Project + Cumulative Noise Levels
Roadway Roadway Segment ADT1
Vehicle
Speeds
(MPH)(1)
Noise Level
@ 50-Feet
(dBA CNEL)
60 dBA CNEL
Contour
Distance (Feet)
Twin Oaks
Valley Road
Borden Road to Richmar Avenue 29,535 45 70.2 524
Richmar Avenue to
San Marcos Boulevard 28,487 45 67.6 287
San Marcos
Boulevard
Twin Oaks Valley Road to
E. Mission Road 17,818 35 64.9 154
Woodward
Street
E. Mission Rd to Vineyard Road 8,437 40 67.9 309
Vineyard Rd to Borden Road 4,016 40 67.7 297
Borden Road Twin Oaks Valley Road to
Woodward Street 10,878 35 64.0 126
Source: LDN Consulting 2024c.

Notes: (1) ADT and MPH from project traffic study (Urban Systems 2019).

Table 39 presents the comparison of the Existing Year and the Near -Term Cumulative noise levels. The overall roadway segment noise levels would increase 0.2 to 1.3 dBA CNEL with the development of the project and proposed cumulative projects. Since the cumulative noise increase is less than 3 dBA CNEL on any roadway segment, impacts would be less than significant.

Table 39. Existing vs. Existing + Project + Cumulative Noise Levels Roadway Roadway Segment
Existing Noise
Level @ 50-Feet
(dBA CNEL)
Existing Plus
Project Noise
Level @ 50-Feet
(dBA CNEL)
Project Related
Noise Level
Increase
(dBA CNEL)
Twin Oaks
Valley Road
Borden Road to Richmar
Avenue 73.7 74.0 1.3
Richmar Avenue to
San Marcos Boulevard 73.6 73.8 0.2
San Marcos
Boulevard
Twin Oaks Valley Road to
E. Mission Road 69.2 69.4 0.2
Woodward
Street
E. Mission Rd to Vineyard
Road 67.0 67.4 0.4
Vineyard Rd to Borden Road 63.9 64.1 0.2
Borden Road Twin Oaks Valley Road to
Woodward Street 67.0 67.3 0.3
Source: LDN 2024c.

In summary, with implementation of mitigation measures, as detailed in MM-N-1, all noise impacts would be reduced to below a level of significance.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 109
b) Generation of excessive groundborne vibration or groundborne noise levels ? Less Than Significant Impact
Construction Vibration Analysis
Table 40 lists the average vibration levels that would be experienced at the nearest vibration sensitive land uses to the east from temporary construction activities. The FTA has determined vibration levels that would cause annoyance to a substantial number of people and potential damage to building structures.

The FTA criterion for vibration induced structural damage is 0.20 in/sec for the peak particle velocity (PPV).

Project construction activities would result in PPV levels below the FTA’s criteria for vibration induced structural damage. Therefore, project construction activities would not result in vibration induced structural damage to residential buildings near the construction areas. The FTA criterion for infrequent vibration induced annoyance is 80 Vibration Velocity (VdB) for residential uses. Construction activities would generate levels of vibration that would not exceed the FTA criteria for nuisance for nearby residential uses. Therefore, vibration impacts would be less than significant.

Table 40. Vibration Levels from Construction Activities (Nearest Receptors) Equipment Approximate
Velocity Level at 25
Feet
(VdB)
Approximate
RMS Velocity
at 25 Feet
(in/sec)
Approximate
Velocity Level at
100 Feet
(VdB)(1)
Approximate
RMS Velocity at
100 Feet
(in/sec)(2)
Small Bulldozer 58 0.003 39.9 0.0004
Jackhammer 79 0.035 60.9 0.0044
Loaded trucks 86 0.076 67.9 0.0095
Large Bulldozer 87 0.089 68.9 0.0111
FTA Criteria 80 0.2
Significant Impact? No No
Source: LDN 2024c.

Notes: (1) VdB = VdB(25 feet) – 30log(d/25) provided by the FTA (2) PPV at Distance D = PPVref x (25/D)1.5 provided by the FTA c) For a project located within an airport land use plan within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? Less than Significant Impact As identified above, the nearest airport is the McClellan-Palomar Airport in Carlsbad, which is located approximately seven miles west of the project area. According to the Airport Land Use Compatibility Plan (ALUCP) for the McClellan-Palomar Airport, the proposed project site is located outside of the existing and future 60 dB CNEL noise contours of the airport (SDCRAA 2010).

According to the ALUCP, the project site is located within Review Area 2 of the airport influence area. This influence area is regulated by the Airport Land Use Commission, which regulates land uses in the area to be compatible with airport-related noise, safety, airspace protection, and overflight factors. Review Area 2 limits the heights of structures in areas of high terrain and requires the recordation of overflight

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 110
notification documents, which informs prospective buyers of property near an airport that the property may be subject to noise, vibration, overflights, or odors associated with airport operations. In summary, because the project site is located outside of the existing and future 60 dB CNEL noise contours of the airport, the project would not expose people residing or working in the project area to excessive noise levels. Impacts would be less than significant.

4.14 Population and Housing
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Induce substantial unplanned population growth
in an area, either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?
X
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
X

a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? No Impact
The project proposes to construct a 115-unit senior residential project. Typically, a rate of 3.1 persons per dwelling unit is assumed for population growth determination. However, given the age-restricted nature of the proposed project, up to 2 persons per unit are assumed. Therefore, the project could potentially add an estimated 230 people to the area. The Housing Element of the General Plan notes the need for additional housing for seniors (over 65 years of age). The senior population in San Marcos has been increasing. In 2010, there were 8,527 senior persons in San Marcos. Between 2000 and 2010, the senior population in San Marcos grew by approxi mately 31 percent (from 6,525 seniors). Twenty percent of households have elderly heads of household. As reflected in Table 8 -8 of the Housing Element, senior residents had the highest incidence of disability (43 percent). The Housing Element notes that most of the affordable senior apartments located in San Marcos have long waiting lists. The proposed project would help the City meet its goal of providing more senior housing and the potential population growth would be consistent with planned City growth.

The project would not result in the construction of new offsite infrastructure. The project would be served by existing water, sewer and storm drain infrastructure offsite and would make infrastructure improvements on site to serve the future development. Therefore, the project would not induce substantial unplanned population growth in an area, either directly or indirectly. No impact is identified.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 111
b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? No Impact.

The project site is undeveloped and does not contain any existing residential units . The project would construct a 115-unit senior residential complex which would add to the City’s housing stock. No impacts would occur.

4.15 Public Services
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection? X
b) Police protection? X
c) Schools? X
d) Parks? X
e) Other public facilities? X

a) Fire protection? Less than Significant Impact
Fire protection services in the City are provided by the SMFD. SMFD is a full-service department responsive to the City and the San Marcos Fire Protection District, which covers an area of 33 square miles and a population of approximately 95,000 residents. SMFD provides the following services within its service area: fire suppression, rescue, emergency medical service, fire prevention services, vegetation management, public education, emergency preparedness and trauma support (City of San Marcos 2020).

The project would be served by Fire Station 1, located at 180 W. Mission Road. The station has one engine, one truck, a brush engine, ambulance as associated staff, including a battalion chief.

Development of the project would contribute to the incremental increase in demand for fire protection services City-wide. As a condition of project approval, and as detailed in Table 1, Project Design Features, 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). Participation in the CFD would offset the cost of increases in necessary services resulting from implementation of the proposed project and impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 112
b) Police protection? Less than Significant Impact
The San Diego County Sheriff’s Department provide law enforcement services to the City . The closest station is the San Marcos Station located nearby at 182 Santar Place , located approximately one mile southeast of the project site. Development of the project would contribute to the incremental increase in demand for police protection services City -wide. As a condition of project approval, and as detailed in Table 1, Project Design Features, 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, Improvement Area No. 1 (Police) . Participation in the CFD would offset the cost of increases in necessary services resulting from implementation of the proposed project and impacts would be less than significant. c) Schools? No Impact
The project site is located within the service boundary of the San Marcos Unified School District (SMUSD).

As a 115-unit multi-family development that is age restricted for 55 and up, the proposed project would not generate any students and no impact is identified. Since the project is an age-restricted senior residential project, pursuant to Section 65995.1 of the California Government Code, the project applicant is not required to pay school fees. No impact is identified for this area. d) Parks? Less than Significant Impact
The City has 44 parks, seven facilities and two aquatic complexes (San Marcos 2026). The closest parks to the project site are Richmar Park and Hollandia Park. Richmar Park is located 0.25 miles west of the project site at 110 Richmar Avenue. Richmar Park is developed with adapted play equipment, a performance plaza, permanent restrooms, a picnic shelter, 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. There is also a tot lot at the southeast corner of N. Twin Oaks Valley Road and Richmar Avenue associated with the San Marcos Senior Activity Center.

The project proposes a 115-unit senior living development. The project design includes private patio or balcony spaces for each unit . There are also interior community spaces in the project design including a library/TV room, fitness room, great room with kitchen and storage. Exterior community spaces include a patio area with lap pool, jacuzzi, and barbeque.

Residents are anticipated to recreate on-site and would not be expected to increase demand on existing neighborhood parks. The project applicant would still be required to pay the City’s Public Facilities Fee (PFF), a portion of which is designated for parks. The PFF money would go towards the acquisition and development of local and community park facilities throughout the Ci ty. As noted in Table 1, Project Design Features, payment of the PFF would be required prior to issuance of a building permit. Because the project is not anticipated to increase demand on existing parks and through the contribution of funds for the acquisition and development of local and community park facilities throughout the City, impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 113
e) Other public facilities? Less than Significant Impact The analysis within Sections 4.15(a) through 4.15(d) concluded that the project would have a less than significant impact or reduces impacts to below a level of significance for police protection, fire protection, schools, and parks. The project would not result in an impact to any other public facilities. Impacts would be less than significant.

4.16 Recreation
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities, such that substantial
physical deterioration of the facility would occur
or be accelerated?
X
b) Does the project include recreational facilities or
require the construction or expansion of
recreational facilities, which might have an
adverse physical effect on the environment?
X

a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration of the facility would occur or be accelerated? Less than Significant Impact
The City has 44 parks, seven facilities and two aquatic complexes (San Marcos 2026). The closest parks to the project site are Richmar Park and Hollandia Park. Richmar Park is located 0.25 miles west of the project site at 110 Richmar Avenue. Richmar Park is developed with adapted play equipment, a performance plaza, permanent restrooms, a picnic shelter, 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. There is also a tot lot at the southeast corner of N. Twin Oaks Valley Road and Richmar Avenue associated with the San Marcos Senior Activity Center.

The project proposes a 115-unit senior living development. The project design includes private patio or balcony spaces for each unit . There are also interior community spaces in the project design including a library/TV room, fitness room, great room with kitchen and storage. Exterior community spaces include a patio area with lap pool, jacuzzi, and barbeque.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 114
Residents are anticipated to recreate on-site and would not be expected to increase demand on existing neighborhood parks. The project applicant would still be required to pay the City’s PFF, a portion of which is designated for parks. The PFF money would go towards the acquisition and development of local and community park facilities throughout the City. Payment of the PFF would be required prior to issuance of a building permit. Because the project is not anticipated to increase demand on existing parks and through the contribution of funds for the acquisition and development of local and community park facilities throughout the City, impacts would be less than significant. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment ? No Impact
As identified above, the project includes communal spaces recreational areas including a library/TV room, fitness room, great room with kitchen and storage. Exterior community spaces include a patio area with lap pool, jacuzzi, and barbeque. The recreational amenities are included as part of the project description and within the footprint of the project that is analyzed in this document. Any impacts associated with the construction of these amenities are analyzed within this environmental document. No impacts would occur.

4.17 Transportation
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with a program, plan, ordinance, or
policy addressing the circulation system,
including transit, roadway, bicycle, and
pedestrian facilities?
X
b) Would the project conflict or be inconsistent
with CEQA Guidelines section 15064.3
subdivision (b)?
X
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses
(e.g., farm equipment)?
X
d) Result in inadequate emergency access? X

The project would generate increased traffic through the development of 115 senior living units . The following traffic studies were prepared for the project by Urban Systems Associates and are included as Appendices J.1 through J.5 of this document.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 115
• San Marcos Senior Apartment Project – Traffic Impact Study, prepared by Urban Systems Associates, September 17, 2019 (Appendix J.1)
• San Marcos Senior Residential – VMT Analysis, prepared by Urban Systems Associates, April 13, 2023 (Appendix J.2)
• San Marcos Senior Residential – Vehicle Miles Traveled Analysis – Supplemental, prepared by CR Associates, November 24, 2025. (Appendix J.3)
• San Marcos Senior Residential – Sight Study for Left Turn Pocket (In) and Project Driveway, prepared by Urban Systems Associates, March 8, 2023 (Appendix J.4) • San Marcos Senior Residential – Driveway Queue Analysis Memo. prepared by Urban Systems Associates, August 21, 2025 (Appendix J.5)
The project would generate 460 total ADT, including 23 trips in the AM Peak hour and 32 trips in the PM peak hour. Trip generation rates were based on the SANDAG ( Not So) Brief Guide to Vehicular Traffic Generation Rates (SANDAG 2002).

The proposed project includes two access points. One driveway would be located on E. Mission Road with right in/right out access only due to an existing raised median being present on E. Mission Road. The second driveway would be located onto Woodward Street and would provide full access. a) Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Less than Significant Impact Transit Facilities
Transit services in San Marcos are provide by NCTD and include the Breeze Bus and the SPRINTER light rail. NCTD Breeze Route 305 runs between the Vista Transit Center and the City of Escondido and travels along E. Mission Road south of the project site. The closest bus stops are on E. Mission Road in front of the project site, one for westbound service and one for eastbound service. The closest light rail stop is the SPRINTER station at the San Marcos Civic Center which is located across the street from the project site.

Due to the proximity of the project site to the light rail station, the project is located in a Transit Priority Area (TPA) as defined by Public Resources Code, Section 21099: “Transit priority area means an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations”. A “Major Transit Stop” is defined in Public Resources Code, Section 21064.3 as: “Major transit stop means a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods”. Therefore, the project area qualifies as a Transit Priority Area. The project would not result in any impact to or change in transit facilities. No impact is identified.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 116
Bicycle and Pedestrian Facilities
The project site is located adjacent to E. Mission Road which is classified as an Arterial with enhanced bicycle pedestrian facilities and has an existing Class II bicycle path, according to the Mobility Element in the City of San Marcos General Plan. There is a sidewalk along the project frontage with E. Mission Road.

The project site is also adjacent to Woodward Street which has an existing sidewalk and bicycle lane.

These sidewalks would be retained as part of the project. The intersection of Mission Road and Woodward Street has crosswalks on the north, west, and southern legs of the intersection. Sidewalk facilities also exist along both sides of San Marcos Blvd., Twin Oaks Valley Road, and only on the southern portion of Borden Road. The portion of N. Twin Oaks Valley Road between E. Mission Road and Borden Road is identified as a Four Lane Arterial with Class II or III bicycle facilities and a sidewalk. A bicycle lane and sidewalk are located on N. Twin Oaks Valley Road.

The project would expand the E. Mission Road right-of-way by approximately four feet along the project frontage, remove an acceleration lane and add a painted buffered bicycle lane. The project would not result in any impact to or other changes to the bicycle and pedestrian infrastructure adjacent to the project site on E. Mission Road. No impact is identified.

Parking
The project design includes 135 parking spaces. According to the HOCSP, parking for Senior Residential calls for one parking space per unit for projects located within a half-mile of a major transit stop, including visitor spaces). Since the project is wit hin a half -mile of a major transit stop (San Marcos Civic Center SPRINTER station), the project would be required to provide 115 spaces. As currently designed, the project is providing 20 additional parking spaces beyond the minimum per the HOCSP. b) Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b) ? Less than Significant Impact
Section 15064.3(b) of the CEQA Guidelines provide criteria for analyzing transportation impacts for land use projects and transportation projects. The City’s Transportation Impact Analysis Guidelines (TIA Guidelines) (2020) provides guidance to City staff, applicants, and consultants on the requirements to evaluate transportation impacts for projects in the City. The TIA Guidelines implement the requirements of SB743 with respect to the City of San Marcos.

A vehicle miles traveled (VMT) analysis is not required where a project’s LOS traffic study was undertaken before the effective date (July 1, 2020) of CEQA Guidelines section 15064.3. The project’s traffic impact analysis, which included the LOS analysis, was originally submitted to the City on October 25, 2018 .

Therefore, a VMT analysis is not required for the project for CEQA compliance. Although not required, a VMT analysis was prepared by Urban Systems Associates (USA) in 2025, which initially concluded that the project’s transportation impacts under current conditions would be less than significant. USA’s VMT analysis is included as Appendix J.2. Upon review of this analysis, a discrepancy was identified in the model year used in the VMT calculations. A supplemental VMT analysis was therefore conducted by CR Associates (CRA 2025), which demonstrates that, with implementation of a dedicated shuttle service, the project would reduce VMT to below 85 percent of the regional VMT mean. CRA’s analysis is included as Appendix J.3. Therefore, the project’s transportation impacts would be less than significant.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 117
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) ? Less than Significant Impact
The project proposes access via two driveways, one on E. Mission Road and one on Woodward Street. The E. Mission Road driveway would be right -in/right-out only. The second driveway would be located on Woodward Street and would have limited access, right -in/right-out/left-in only . USA prepared a site distance memorandum for the project (USA 2023) and a driveway queue analysis memorandum (USA 2025). The analyses are included as Appendix J.4 and J.5 of this report and summarized below.

Sight Distance
A sight distance analysis was performed by USA (2023) to determine whether there would be adequate stopping sight distance for a left turn pocket into the project driveway along Woodward Street.

The existing condition of Woodward Street between Mission Road and Vineyard Road is that of a 4-lane street with a posted speed limit of 40 miles per hour. Additionally, the aforementioned segment has the geometric characteristics of a crest vertical curve with a noticeable change in grade that crests just north of the driveway along Woodward Street. Given the existing conditions on the Woodward Street and the proposed project access along Woodward Street, field observations including a radar speed survey and sight distance evaluation at the proposed left turn pocket was conducted.

A radar speed survey was conducted to analyze the speeds of vehicles traveling along Woodward Street in the southbound and northbound directions to determine the 85 th percentile speed of typical free flow
speed along the road. A total of 100 vehicle speeds were recorded along the street segment with 50 in the southbound direction and 50 in the northbound direction. It was determined based on the data that the 85th percentile of travel speed was 45 miles per hour (mph).

To determine the required stopping sight distance, the American Association of State Highway Transportation Officials (AASHTO) A Policy on Geometric Design of Highways and Streets was referenced, in particular the stopping sight distance on grades (Table 3 -2 of the AASHTO document) was referenced due to the existing conditions of Woodward Street having a vertical curve and a 3 percent upgrade. Based on the AASHTO table, the required stopping sight distance for a design speed of 45 mph and a 3 percent upgrade is 344 feet.

The City’s criteria for Sight Distance Minimum were not utilized as the City ’s criteria is only applied to access onto City streets. The scenario analyzed by USA was for the northbound left -turn into the project driveway on Woodward from the proposed conversion of the painted median to a two-way left-turn lane, so the conflicts involve two main street traveling vehicles. Therefore, the AASHTO criteria for stopping sight distance were used.

AASHTO requires that a driver at a 3.5 -foot eye level can see a 4.25 -foot object. Based on the analysis , from the driver in the left turn pocket ’s point of view, the 4.25 -foot object can be seen with no obstructions (see pictures in Appendix J. 4), For th e southbound oncoming vehicle approach, the 4.25 object can also be seen with no obstructions. Therefore, the existing stopping sight distance conditions for the left-turn movements into the project driveway appear adequate based on the observed conditions in the field.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 118
Driveway Queue Analysis
The project proposes two access driveways, one on E. Mission Road and one on Woodward Street. A two- way left turn lane is proposed to be striped near the driveway to allow northbound Woodward Street drivers to turn left into the project driveway. Another residential project , the Woodward 46 project, is proposed to be located on the opposite side of Woodward Street (northeast of the Woodward St reet/E.

Mission Road intersection) and would also include a driveway on Woodward Street just south of the proposed project’s driveway. A driveway queue analysis was performed by USA (2020) to determine whether any driveway queuing onto Woodward due to both projects’ driveways would cause a problem for drivers attempting to make a left turn onto the proposed project site.

To provide a more conservative analysis for potential queuing at the project driveway, the long term (year 2035) condition peak hour volumes were obtained from the San Marcos Senior Apartment Project Traffic Impact Study , dated September 17, 2019. The proposed project was assumed to be built out for the analysis with the inclusion of all project volumes entering and exiting the driveway along Woodward Street for the critical PM peak hour. Peak hour turning movement counts were determined based on the trip generation by the proposed project and from balancing the volumes for the intersections of Woodward Street / E. Mission Road and Woodward Street / Vineyard Road.

The queuing analysis was conducted on Synchro 10. A 95th percentile queue based on vehicles can be obtained from Synchro. To determine the distance between the driveways, an exhibit was prepared with both projects superimposed and scaled accordingly. There would be approximately 133 feet between the driveways.

The 95th percentile queue for the northbound left turn lane is expected to be a queue of only 0.1 vehicles.

With the average length of a vehicle being 16 feet, and 0.1 vehicles being the 95th percentile queue, it is far below the 133 feet distance from the San Marcos Senior Apartments driveway to the south. The proposed project generates 32 PM peak hour trips with 19 entering and 13 exiting during that peak hour.

Therefore, the proposed project would have only 19 vehicles arriving throughout the entire hour and any potential queues would be minimal.

In conclusion, no queuing issue is expected to occur due to the length of the distance between driveways being long enough to handle any potential queues and from the proposed project having a very minimal queue length. Therefore, less than significant impacts would occur. d) Result in inadequate emergency access? No Impact
Access to the project site would be via two driveways, one on E. Mission Road and one on Woodward Street. The E. Mission Road driveway would be right -in/right-out only. The Woodward Street driveway would allow full access. The Fire Marshal reviewed the project and did not identify any emergency access or circulation issues on the project site. A sight distance and driveway queue analyses were performed as detailed above. No impacts related to the project driveways were ident ified. No impact is identified for this issue area.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 119

4.18 Tribal Cultural Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code section 5020.1(k)?
X
b) A resource determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code section 5024.1. In applying the criteria set
forth in subdivision (c) of Public Resources Code
section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe.

X

AB 52 Coordination
Assembly Bill (AB) 52 requires consultation with California Native American Tribes and consideration of tribal cultural resources, requiring consultation prior to the release of an environmental document if requested by a California Native American Tribe. Outreach to local tribes by the City, consistent with AB 52, was initiated as part of the preparation of this environmental document Two tribes have responded and requested consultation , the San Luis Rey Band and the Rincon Band of Luiseño Indians (Rincon Band). The Rincon Band and the City conducted a walk of the project site and the Rincon Band followed up with a letter on December 19, 2024. The letter requested specific design features and mitigation measures be incorporated into the project, which are further detailed in the analysis section below. The San Luis Rey Band respon ded on February 20, 2025 and indicated they reviewed the proposed cultural resources mitigation measures (MM-CR-1 through MM-CR-4). The response also noted that City has addressed the San Luis Rey Band’s concerns. a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: Listed or

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 120
eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? Less than Significant with Mitigation Incorporated
The San Luis Rey Band responded on February 20, 2025 and indicated they reviewed the proposed cultural resources mitigation measures (MM -CR-1 through MM -CR-4). The response also noted that City has addressed the San Luis Rey Band’s concerns.

Based upon consultation with the Rincon Band, the project site is within a Traditional Cultural Landscape (TCL), which as previously identified in consultation with the City. Although a formal assessment of the TCL is outstanding, the Rincon Band requested that, for the proposed project, the TCL be determined eligible for listing and that implementation of the proposed project be determined to have a significant tribal cultural resources impact ( Impact TCR-1). Implementation of the following mitigation measures, which were developed and requested by the Rincon Band would reduce the impact to below a level of significance. These mitigation measures will be made a condition of project approval.

MM-TRC-1 The project applicant shall incorporate interpretive signage near a seating area on the project site to acknowledge the Luiseño people’s history and culture. The content of the interpretive panel shall be consulted with and approved by the Rincon Band. The location for the signage shall be shown on the project plans.

MM-TCR-2 An archaeological and Tribal monitor shall be present for all ground disturbing activities associated with the project.

MM-TCR-3 Prior to the issuance of the grading permit, the developer/applicant shall provide evidence to the Planning Director that an Environmental Constraints Sheet has been included in the grading plans. This sheet shall indicate an area that will be protected and not disturbed in the future. This area will be used for reburial of any artifacts that will be impacted and/or discovered during grading. This is confidential and the exact nature of this area will not be called out on the grading plans.

To further ensure Native American archaeological resources are protected, implementation of MM-TRC-1 through MM-TCR-3 as well as MM -CR-1 through MM-CR-4 provides additional protections for significant resources and describes the process for proper treatment and handling to ensure impacts would be minimized. Implementation of these mitigation measures would reduce potential project-level impacts to tribal cultural resources to below a level of significance. b) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code section

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 121
5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. Less than Significant with Mitigation Incorporated As discussed in 4.18(a), based upon consultation with the Rincon Band, the project site is within a TCL, which as previously identified in consultation with the City and implementation of the proposed project has the potential impact the TCL (Impact TCR-1) . Implementation of the mitigation measures MM -TCR-1 through MM-TCR-3, as detailed above, would reduce the impact to below a level of significance. The San Luis Rey Band responded on February 20, 2025 and indicated they reviewed the proposed cultural resources mitigation measures (MM -CR-1 through MM -CR-4). The response also noted that City has addressed the San Luis Rey Band’s concerns. These mitigation measures will be made a condition of project approval.

4.19 Utilities and Services Systems
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Require or result in relocation or the
construction of new or expanded water,
wastewater treatment facilities, or stormwater
drainage, electric power, natural gas, or
telecommunications facilities, the construction
or relocation of which could cause significant
environmental effects?
X
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry, and multiple
dry years?
X
c) Result in a determination by the wastewater
treatment provider, which serves or may serve
the project, that it has adequate capacity to
serve the project’s projected demand in addition
to the provider’s existing commitments?
X
d) Generate solid waste in excess of State or local
standards or in excess of the capacity of local
infrastructure, or otherwise impair the
attainment of solid waste reduction goals?
X
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 122
VWD was contacted during the preparation of this document for input on the water and wastewater analysis. A Water and Sewer Study was prepared for the project by VWD (2020). The complete report is included as Appendix K of this document.

The project site is within the VWD water and sewer service boundaries and VWD has indicated they can serve the project. The domestic water and fire water connections would be to the existing VWD water main in E. Mission Road. Sewer connection would be to the existing sewer line that also runs within E.

Mission Road. No upsizing of offsite water or sewer lines or facilities would be needed to serve the project.

The project would pay Water Capital Facility Fees and Waste Water Capital Facility Fees consistent with VWD Ordinance No. 175 and NO. 176.
a) Require or result in the construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction of which could cause significant environmental effects? Less Than Significant Impact Water Facilities Analysis
Water Distribution Infrastructure Analysis – The project is located within VWD boundaries for water service and is completely within the 920 pressure zone. Water modeling prepared by VWD concluded that the project would not create any new distribution system deficiencies under average day demand, maximum day demand, or peak hour demand.

Water Storage Analysis – The City’s approved land use designation on the site is Commercial. VWD’s 2018 Master Plan based its ultimate water demand planning on this approved land use. The VWD 2018 Master Plan assumed water demand on the project site would be 5,940 gallons per day (gpd). Under the proposed development, the project would have a water demand of 23,760 gpd. This represents an increase of approximately 17,820 gpd (Table 41).

Table 41. Estimated Water Demand
Land Use Type Area (acres) Duty Factor
(gpd/acre)
Water Demand
(gpd)
2018 Master Plan Land Use Demand
Commercial 3.96 1,500 5,940
Total 3.96 - 5,940
Proposed Project Demand
Residential (20-30 du/ac) 3.96 6,000 23,760
Total 3.96 23,760
Increase in Water Demand 17,820
Source: VWD 2020.

Notes: GPD (gallons per day)
Potable water storage within VWD is sized for operational, emergency, and fire flow storage. The project site is entirely within VWD’s 920 pressure zone. Water storage for this zone is located within the 920 Richland and the 1028 Twin Oaks pressure zone. Table 42 shows the required storage in these zones for the existing and ultimate build-out conditions relative to the existing storage provided within each zone.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 123
Table 42. Existing Reservoir Storage Capacity and Requirements Pressure Zone
Existing
Average Day
Demand
(MGD)
Existing
Storage
Requirements
(MG)
Ultimate
Average Day
Demand
(MGD)
Ultimate
Storage
Requirements
(MG)
Existing
Storage
Available (MG)
855 3.74

50.05 6.79
101.25
0 920 Richland 5.61 10.40 18
1028 Twin Oaks 0.66 3.06 73
Totals 10.01 50.05 20.25 101.25 91
Source: VWD 2020.

The project would increase the projected average day demand (ADD) by approximately 17,820 gallons per day. The reservoir storage requirement is 500 percent of the development’s average day demand, which would be 89,100 gallons for the proposed project. VWD concluded that water storage capacity is currently available to serve the project’s increased storage requirements. Master Plan projects identified in the 2018 VWD Water P lan address and accommodate the ultimate build-out storage deficiencies and the Water Capital Facility Fees per VWD Ordinance No. 175 paid by the project applicant would be used for the increase in storage necessitated by the project’s increase in demand. The payment of these fees are identified in Table 1, Project Design Features. VWD considers payment of the Water Capital Facility Fees as mitigation for the increase in water storage demand.

Water Pump Station Analysis – Since the project is located in a pressure zone that is not served by pumping, there are no impacts to existing or proposed pump stations by the project.

Wastewater Facilities Analysis
The project site is located completely within VWD sewer shed 24C. VWD’s 2018 Master Plan assumed a wastewater generation of 4,752 gpd for the project site. Under the proposed project, the wastewater generation is anticipated to be 17,820 gpd. This represents an increase of approximately 13,068 gpd (Table 43).

Table 43. Estimated Wastewater Flows
Land Use Type Area (acres) Duty Factor
(gpd/acre)
Wastewater
Generation (gpd)
2018 Master Plan Land Use Flows
Commercial 3.96 1,200 4,752
Total 3.96 - 4,752
Proposed Project Demand
Residential (20-30 du/ac) 3.96 4,500 17,820
Total 3.96 - 17.820
Increase in Sewer Generation 13,068
Source: VWD 2020.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 124
Wastewater Collection System Analysis – The VWD Sewer Study (2020) included modeling that considered the sewer collection infrastructure in the direct vicinity of the project as well as all downstream infrastructure from the proposed project to Lift Station No. 1 on San Marcos Boulevard. The mod eling results show that there are no system deficiencies under peak wet weather flows in the ultimate build- out condition.

Wastewater Lift Station Analysis – Lift stations are sized for peak wet weather flow. Since the project site is not located in a sewer shed that is served by a lift station, there are no lift station upgrade requirements for the project.

Parallel Land Outfall Analysis – VWD’s existing outfall is approximately eight miles in length and consists of four gravity pipeline sections and three siphon sections varying from 20 to 54 inches in diameter. VWD maintains the entire pipeline from Lift Station No. 1 to the Encina Water Pollution Control Facility (EWPCF).

From Lift Station No. 1 to El Camino Real, VWD is the sole user of this pipeline. From El Camino Real to the EWPCF, the ownership capacity is split between the City of Carlsbad (5 million gallons per day (MGD)), the City of Vista (3.75 MGD), and VWD (12.10 MGD), for a total capacity of 20.85 MGD.

The Meadowlark Reclamation Facility (MRF) has a capacity of 5 MGD with a peak wet weather capacity of 8 MGD. Combined with the capacity at EWPCF, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD at these two facilities. VWD’s 2014 average daily wastewater flow was

7.5 MGD, which corresponds to a peak wet weather flow of 17.5 MGD. This falls within VWD’s combined peak wet weather collection capacity.

The 2018 Master Plan estimated that, under approved land uses, VWD has an ultimate built-out average daily flow of 14.4 MGD, which corresponds to a peak wet weather flow of 31.7 MGD. This exceeds VWD’s peak wet weather collection capacity. To accommodate additional wastewater flows from planned development, including the proposed project, the 2018 Master Plan recommended conveyance of peak flows to the EWPCF via a parallel land outfall.

The project proposes to generate additional average wastewater flows of 13,068 gpd of additional average wastewater flow that was not accounted for in the Land Outfall’s capacity studies in the 2018 Master Plan. With the outfall, there is available capacity to serve the project’s proposed wastewater generation. The project would pay Wastew ater Capital Facility Fees per VWD Ordinance No. 176. These fees would be used by VWD to help fund the parallel land outfall design and construction. VWD considers payment of the fees as mitigation for the increase in the need for land outfall capacity.

Wastewater Treatment Facility Analysis – VWD uses two wastewater treatment facilities to treat wastewater that is collected within its sewer service area: the MRF and EWPCF. MRF has a liquids treatment capacity of up to 5 MGD with a peak wet weather capacity of 8 MGD. MRF does not have solids treatment capacity; all solids are treated at EWPCF.

EWPCF is a regional facility and has a treatment capacity of up to 40.51 MGD. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, there is adequate solids treatment capacity at this time to serve the project. VWD currently owns 10.47 MGD of solids treatment capacity at the EWPCF.

The ultimate average wastewater flow identified in the VWD 2018 Master Plan is 14.4 MGD, resulting in a projected solids treatment capacity deficiency of 3.93 MGD.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 125
VWD currently owns 7.67 MGD of liquids treatment capacity at EWPCF, in addition to the liquids treatment capacity of 5 MGD at MRF, totaling 12.67 MGD of liquids treatment capacity. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, there is a dequate liquid treatment capacity at this time to serve the project.

The ultimate average wastewater flow identified in the 2018 Master Plan of 14.4 MGD would result in a projected liquids treatment capacity deficiency of 1.73 MGD.

VWD also currently owns 10.47 MGD of ocean disposal capacity at EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, there is adequate ocean disposal capacity at this time to serve the project.

The ultimate average wastewater flow identified in the 2018 Master Plan of 14.4 MGD would result in an ocean disposal deficiency of 3.93 MGD. In summary, VWD would experience ultimate solids handling, liquids handling, and ocean disposal capacity deficiencies.

The project would increase the wastewater flows from the project site by approximately 13,068 gpd; however, this increase was not identified as a significant impact in the VWD water and sewer study. Page 19 of the VWD sewer study specifically states that, considering VWD’s 2014 average daily wastewater flow of 7.5 MGD, adequate wastewater treatment and disposal capacity currently exists for the project.

As noted in Table 1, Project Design Features, t he project would pay Wastewater Capital Facility Fees per VWD Ordinance No. 176. These fees would be used by VWD to help fund the expansion and/or construction of wastewater treatment facilities to handle increased wastewater quantities. VWD considers payment of the fees as mitigation for the increase in treatment need.

In summary, the project would not require or result in the construction of new wastewater treatment facilities or expansion of existing facilities. Impacts would be less than significant.

Storm Water Drainage
The project site does not currently have an underground storm drain system. Under current conditions, the site surface drains from the east to west towards the existing culvert box that drains to San Marcos Creek. Under the proposed conditions, the site su rface would drain from east to west towards a 48-inch X 48-inch inlet that would capture the runoff. The runoff would go through an underground PVC pipe that would direct the flow to an underground chamber and to San Marcos Creek. Additionally, the storm drain system in the landscaped areas around the building would direct runoff to the chamber. The project owner would be responsible for the maintenance of the underground detention and infiltration facility.

Impacts to the City’s storm drains would be less than significant.

Electric Power, Natural Gas and Telecommunications
Electricity service and natural gas services would be provided by SDG&E. The project would connect to existing infrastructure in the project vicinity for electric power, natural gas, and telecommunications. The project would meet all requirements from SDG&E for service. No impact is identified for this issue area.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 126
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? Less Than Significant Impact The VWD 2018 Master Plan assumed water demand on the project site would be 5,940 gpd. Under the proposed development, the project would have a water demand of 23,760 gpd. This represents an increase of approximately 17,820 gpd; however, this increase was not identified as a significant impact in the VWD water and sewer study (VWD 2020). Page 20 of the VWD study specifically states that VWD currently has water capacity to serve the project. Therefore, sufficient water supplies would be available to serve the project from existing entitlements and resources. Impacts would be less than significant. c) Result in a determination by the wastewater treatment provider, which serves or may serve the project, that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less Than Significant Impact Due to the proposed development of 115 residential units on the project site, the project would increase the demand for wastewater treatment as well as land outfall capacity. The project would pay Wastewater Capital Facility Fees per VWD Ordinance No. 176. These fees would be used by VWD to help fund the expansion and/or construction of wastewater treatment facilities to handle increased wastewater quantities and also the expansion of land outfall facilities. VWD considers payment of these fees as mitigation for the increase in treatment need. Therefore, the project would not result in a determination by the wastewater treatment provider which serves the project that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. Impacts would be less than significant.
d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals ? Less than Significant Impact
The project would generate solid waste from the construction and operation of an assisted living facility.

Solid waste service in the City is provided by a private franchise hauler, EDCO Waste and Recycling (EDCO), which handles all residential, commercial, and industrial collections within the City. Waste collected by EDCO is hauled to the Escondido Resources Recovery Transfer Station where it is then transported to the Sycamore Sanitary Landfill in Santee. According to CalRecycle, the facility currently has a daily permitted capacity of 5,000 tons per day for solid waste but is projected to increase to 7,000 tons per day in 2025 and 9,000 tons per day in 2027. Sycamore landfill’s e stimated closure date is listed as 2042 though the permit is anticipated to be revised and extended to 2054 (County of San Diego 2022).

CalRecycle provides solid waste generation rates for various types of land uses. Construction debris would be generated by the project. Construction debris recycling is available through EDCO. Negligible solid waste generation is anticipated during project construction. The anticipated solid waste generation from the proposed project was estimated using CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019). It is estimated that the residential uses (115 units) would generate approximately 1,407 pounds of solid waste per day (12.23 pounds per household). This does not consider any waste diversion through recycling. According to CalRecycle, the City has a disposal rate target of 8.9 pounds per person per day. If the City meets this target, the Cit y is considered in compliance with the 50% diversion requirement of AB 939. The most recent data (2022 ) from CalRecycle identifies the annual per capita disposal rate as 5.3 pounds per person per day (CalRecycle 2022). Thus, the City is exceeding their target for diversion. With consideration of the diversion rate, the proposed project’s solid waste generation

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 127
during operation can be accommodated at the landfill based upon the available daily permitted capacity.

Impacts would be less than significant.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste? Less than Significant Impact
The proposed project would comply with all federal, state, and local statues and regulations regarding solid waste. More specifically, the proposed project would comply with AB 341, which requires a 75 percent diversion rate by 2020. All solid waste facilities, including landfills, require solid waste facility permits to operate. In San Diego Coun ty, Public Resources Code (Sections 44001 - 44018) and California Code of Regulations Title 27, Division 2, Subdivision 1, Chapter 4 (Section 21440 et seq.) authorizes the County Department of Environmental Health, Local Enforcement Agency to issue solid wa ste facility permits. Sycamore Sanitary Landfill is a permitted facility and EDCO is a licensed hauler. As such, the project would comply with existing regulations related to solid waste disposal and would not violate federal, state, or local management and reduction statutes and regulations related to solid waste. Impacts would be less than significant.

4.20 Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zone, would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
X
b) Due to slope, prevailing wind, and other factors,
exacerbate wildlife risk, and thereby expose
project occupants to, pollutant concentrations
from a wildlife or the uncontrolled spread of
wildlife?
X
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or
that may result in the temporary or ongoing
impacts to the environment?
X
d) Expose people or structures to significant risk,
including downslope or downstream flooding or
landslide, as a result of runoff, post-fire slope
instability, or drainage changes?
X

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 128
The four wildfire thresholds relate specifically to projects located in or near state responsibility areas or lands classified as very high fire severity zones . The project site is located in an urbanized portion of the City. The project site is not located in or near a State Responsibility Area nor is it classified as being located in a very high fire severity zone (CalFire 2009). Further, per Figure 6 -4 (SMFD Community Hazard Zones) of the Safety Element of the City’s General Plan, the project site is not identified as being within a community hazard zone. No wildfire impact is identified for the project.

4.21 Mandatory Findings of Significance
Does the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have the potential to substantially degrade the
quality of the environment, substantially reduce
the habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a plant or
animal community, substantially reduce the
number, or restrict the range of a rare or
endangered plant or animal, or eliminate
important examples of the major periods of
California history or prehistory?
X
b) Have impacts that are individually limited, but
cumulatively considerable? ("Cumulatively
considerable" means that the incremental
effects of a project are considerable when
viewed in connection with the effects of past
projects, the effects of other current projects,
and the effects of probable future projects.)
X
c) Have environmental effects, which will cause
substantial adverse effects on human beings,
either directly or indirectly?
X

The following are Mandatory Findings of Significance in accordance with Section 15065 of the CEQA Guidelines.
a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number, or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Less Than Significant Impact with Mitigation Incorporated

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 129
Based upon the biological resources analysis for the project, the project has the potential to impact sensitive species and sensitive habitat. Implementation of mitigation measures MM -BIO-1 and MM-BIO- 2 will reduce potential impacts to coastal California g natcatcher, Cooper’s hawk, and other avian species protected under the MBTA to a level below significance. The project will be required to mitigate for impacts to sensitive vegetation including Diegan coastal sage scrub, b accharis scrub and non -native grasslands (MM -BIO-3). Construction monitoring will also be required to avoid inadvertent impacts to sensitive habitat and periodic inspection by a biologist and other measures will be required (MM -BIO-4 and MM -BIO-5). With implementation of these mitigation measures, the project will not degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, thre aten to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal.

A cultural resources study was prepared for the project and did not identify any resources on the site. The City also conducted outreach to tribes consistent with the requirements of AB 52 and a summary of that consultation is discussed in the cultural resources and tribal cultural resources sections of this document.

Mitigation measures MM-CR-1 through MM-CR-4 and MM-TCR-1 through MM-TCR-3 would be applicable to the project during project grading to reduce any potential impact to previously unidentified cultural resources. The project would not eliminate important examples of the major periods of California history or prehistory.
b) Does the project have impacts that are individually limited, but cumulatively considerable ? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) Less Than Significant Impact Cumulative impacts related to traffic, air quality, greenhouse gas , and noise were analyzed in this CEQA document. Based upon the analysis, the project will not have any cumulative impact related to air quality or noise. The project will contribute to City -wide traffic congestions and will participate in CFD 2011 -01 (Congestion Management) will assist with the reduction of traffic congestion in the City and to SR-78. The project will also add to the increase in demand for police and fire services. the project participate in CFDs for police, fire and traffic congestion would reduce the project’s contribution towards the increase in demand for public services.
c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? Less Than Significant Impact with Mitigation Incorporated
In the evaluation of environmental impacts in this Initial Study, the potential for adverse direct or indirect impacts to human beings were considered in the response to certain questions in Sections 4.1 (Aesthetics), 4.3 (Air Quality), 4.7 (Geology and Soils), 4.9 (Hazards and Hazardous Materials), 4.10 (Hydrology and Water Quality), 4.13 (Noise), 4.14 (Population and Housing). 4.15 (Public Services), and

4.17 (Transportation). As a result of this evaluation, there is no substantial evidence that there are adverse effects on human beings associated with t his project. All impacts in these environmental issue areas are less than significant or mitigated to below a level of significance through implementation of mitigation measures that will be required as a condition of project approval (MM -GEO-1 and MM -N-1) Therefore, this project has been determined not to meet this Mandatory Finding of Significance and impacts are less than significant with the incorporation of mitigation.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 130

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 131

5.0 Preparers
This section identifies those persons who prepared or contributed to preparation of this document . This section is prepared in accordance with Section 15129 of the CEQA Guidelines.

CITY OF SAN MARCOS
Chris Garcia, Senior Planner
Bradley Holder, Associate Civil Engineer
Edd Alberto, City Traffic Engineer

CONSULTANTS
CEQA Documentation
Sophia Mitchell & Associates, LLC
Sophia Habl Mitchell, LEED AP, Project Manager
Melyssa Sheeran, Senior Environmental Consultant
Air Quality, Greenhouse Gas and Noise Reports
Ldn Consulting, Inc.

Jeremy Louden, Principal
Biological Resources
Helix Environmental
Jason Kurnow, Senior Biology Project Manager
Thomas S. Liddicoat, Senior Biology Project Manager
Angelica Grunloh, Biologist IV
Alexander Walsk, Biologist
Cultural Resources
ASM Affiliates, Inc.

Shelby Castells, M.A., R.P.A, Director/Principal Investigator Geotechnical Engineering Investigation
NorCal Engineering
Keith D. Tucker, R.G.E, Project Engineer
Scott D. Spensiero, Project Manager
Hydrology
REC Consultants
Luis A. Parra-Rosales, PhD, CPSWQ, ToR, D.WRE, RCE
Kamal S. Sweis, PE
Stormwater Management
K&S Engineering, Inc.

Kamal S. Sweis, PE

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 132
Phase 1 Environmental Site Assessment
Marc Boogay Consulting Engineer
Marc Boogay, Principal
Transportation (LTA and TDM Reports)
Urban Systems Associates
Justin P. Schlaefli, PE TE PTOE

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 133

6.0 References
ASM Affiliates, Inc. (ASM). 2023. Archaeological Survey Report for the Adult Living Community Project at Mission Road and Woodward Street, San Marcos, Diego County, California. July, 2023.

California Department of Conservation. 2019. Alquist-Priolo Earthquake Fault Zones. https://www.conservation.ca.gov/cgs/geohazards/eq-zapp Viewed March 31, 2026.

CalFire. 2024. Fire Hazards Severity Zones Mapping Tool. https://osfm.fire.ca.gov/what-we-do/ community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones Viewed April 24, 2024.

California Department of Fish and Wildlife (CDFW). 2023. Survey Considerations for California Endangered Species Candidate Bumble Bee Species. June 6, 2023.

California Department of Resources Recycling and Recovery (CalRecycle). 2022. Jurisdiction Diversion/ Disposal Rate Summary. https://www2.calrecycle.ca.gov/LGCentral/DiversionProgram/ JurisdictionDiversionPost2006 Viewed April 24, 2024.

California Department of Resources Recycling and Recovery (CalRecycle). 2019. Estimated Solid Waste Generation Rates. https://www2.calrecycle.ca.gov/wastecharacterization/general/rates Viewed April 14, 2024.

California Department of Transportation (Caltrans). 2020. Officially Designated State Scenic Highways. https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i- scenic-highways Viewed April 24, 2024.

California Air Pollution Control Officers Association (CAPCOA). 2021. CalEEMod Version 202.40 Calculation Details (Appendix A). http://www.aqmd.gov/
docs/default-source/caleemod/user-guide-2021/appendix-a2020-4-0.pdf?sfvrsn=6 City of San Marcos. 2026. San Marcos Park & Recreation Webpage. https://www.sanmarcosca.gov/Parks-Recreation Viewed March 28, 2026.

City of San Marcos. 2025. City of San Marcos BMP Design Manual. February. https://www.sanmarcosca.gov/files/assets/city/v/1/development-svs/engineering/storm-water-quality- management/bmp-design-manual-chapter.pdf Viewed March 28, 2026.

C
City of San Marcos. 2020. Final Climate Action Plan. December. https://www.sanmarcosca.gov/files/assets/city/v/1/development-svs/climate-action-plan/2020- climate-action-plan.pdf
City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November 16. https://www.sanmarcosca.gov/files/assets/city/v/1/development-svs/planning/ceqa- resources/transportation-impact-analysis-tia-guidelines.pdf City of San Marcos. 2012a. General Plan. https://www.sanmarcosca.gov/Business- Services/Development/Planning/General-Plan

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 134
City of San Marcos. 2001. Natural Community Conservation Plan for the City of San Marcos. San Marcos Subarea Plan Public Review Draft.

County of San Diego. 2022. Five-Year Review Report of the Countywide Integrated Waste Management Plan. https://www.sandiegocounty.gov/content/dam/sdc/dpw/SOLID_WASTE_PLANNING_and_RE CYCLING/Files/2022%20Five-Year%20Review.pdf Viewed April 24, 2024.

CR Associates (CRA). 2025. Vehicle Miles Traveled (VMT) Analysis – Supplemental. November 24, 2025.

FEMA. 2020. Federal Insurance Rate Map Panel 06073C0793G (Effective 5/16/2012). https://msc.fema.gov/portal/search?AddressQuery=woodward%20street%2C%20san%20marcos Viewed April 24, 2024.

Helix Environmental Planning. 2026 Lanikai Residential Development Project Biological Technical Report.

January.

K&S Engineering, Inc. 2025. Priority Development Project Storm Water Quality Management Plan for San Marcos Lanikai. August 19, 2025.

LDN Consulting, Inc. (LDN). 2024a. Lanikai Senior Residential Apartments – City of San Marcos – Air Quality Report. May 6, 2024.

LDN Consulting, Inc. (LDN). 2024b. Lanikai Senior Residential Apartments – City of San Marcos – Greenhouse Gas Analysis. May 6, 2024.

LDN Consulting, Inc. (LDN). 2024c. Lanikai Senior Residential Apartments – City of San Marcos – Noise Assessment. May 6, 2024.

Mark Boogay Consulting Engineers (MBCE). 2017. Phase 1 Environmental Subject Site Assessment for 4- acre lot in Northwest Corner of East Mission Road & Woodward Street (APN 220-063-0400) in San Marcos.

NorCal Engineering. 2018. Updated Geotechnical Engineering Investigation – Proposed Retail Development Located at Northwest Corner of Woodward Street and Mission Road. January 8.

OEHHA. (2014). Air Toxicology and Epidemiology. Retrieved 2014, from All OEHHA Acute, 8-hour and Chronic Reference Exposure Levels (chRELs) as of June 2014: http://www.oehha.ca.gov/air/allrels.html REC Consultants. 2018a. Technical Memorandum SWMM Modeling for Hydromodification Compliance of San Marcos Lanikai. June 1, 2018.

REC Consultants. 2018b. 100-Year Routing Analysis for San Marcos Lanikai.

San Diego Air Pollution Control District (SDAPCD). 2020. Attainment Status. http://www.sdapcd.org/ content/sdc/apcd/en/air-quality-planning/attainment-status.html Viewed May 18, 2020.

San Diego Association of Governments (SANDAG). 2003. Final MHCP Plan. March. https://www.sandag.org/-/media/SANDAG/Documents/PDF/projects-and- programs/environment/regional-habitat-conservation/final-multiple-habitat-conservation-program- executive-summary-2003-03-01.pdf

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 135
SANDAG. 2002. (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region.

April. https://www.sandag.org/uploads/publicationid/publicationid_1140_5044.pdf San Diego County Regional Airport Authority (SDCRAA) Airport Land Use Commission. 2010. McClellan- Palomar Airport Land Use Compatibility Plan. January 25. Amended March 4, 2010 and December 1, 2011. http://www.san.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command =Core_Download&EntryId=2991&language=en-US&PortalId=0&TabId=225 Viewed May 30, 2020.

South Coast Air Quality Management District (SCAQMD). 1993. CEQA Air Quality Handbook. http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/ceqa-air-quality- handbook-(1993)
United States Environmental Protection Agenncy (USEPA). 1992. Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised. US EPA. Retrieved from http://www.epa.gov/ scram001/guidance/guide/EPA-454R-92-019_OCR.pdf
United States Fish and Wildlife Service (USFWS). 2001. Least Bell’s Vireo Survey Guidelines. https://www.fws.gov/sites/default/files/documents/survey-protocol-for-least-bells-vireo.pdf United States Fish and Wildlife Service (USFWS). 1997. Coastal California Gnatcatcher Presence/Absence Survey Protocol. https://www.fws.gov/sites/default/files/documents/survey-protocol-for-coastal- california-gnatcatcher.pdf
United States Census Bureau (USCB). 2023. Quick Facts Escondido City, San Marcos City, California, United States. https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia, sanmarcos%20citycalifornia,US/PST045219 Viewed November 21, 2023.

Urban Systems Associates, Inc. (USA). 2025b. San Marcos Senior Residential – VMT Analysis. January 9, 2025.

Urban Systems Associates, Inc. (USA). 2025b. San Marcos Senior Residential – Driveway Queue Analysis Memo. August 21, 2025.

Urban Systems Associate, Inc. (USA). 2023. San Marcos Senior Residential Sight Study for Left Turn Pocket (In). March 8, 2023.

Urban Systems Associates, Inc. (USA). 2019. San Marcos Senior Apartment Project Traffic Impact Study.

September 17, 2019.

Vallecitos Water District. (VWD). 2020. Lanikai Senior Residential Water and Sewer Study Work Order #234074 Final Technical Memorandum. October 29, 2020.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 136

7.0 Mitigation Monitoring and Reporting Program
Impact Mitigation Measure Action Timing Responsibility

BIOLOGICAL RESOURCES
BIO-1a, BIO-1b and BIO-
1c: The project has the
potential to impact
coastal California
gnatcatcher through
habitat loss, potential
impact to nests and
through construction-
generated noise.

MM-BIO-1a Coastal California Gnatcatcher Mitigation
Prior to land disturbance, clearing, grubbing, and/or the issuance of a grading permit for the project site, the project proponent shall demonstrate to the City that off-site mitigation has been provided for project impacts to 2.1 acres of Diegan coastal sage scrub habitat occupied by coastal California gnatcatcher. Mitigation shall occur at no less than a 1:1 ratio through the purchase of no less than 2.1 acres of coastal sage scrub Mitigation Bank credits, occupied by coastal California gnatcatcher at the Red Mountain Conservation Bank or another CDFW approved mitigation bank with available credits, unless otherwise required by the City or Wildlife Agencies.

Proof of purchase of
credits from a
mitigation bank
submitted to
Planning Director.

Prior to land
disturbance,
clearing,
grubbing, and/or
the issuance of a
grading permit
for the project
site

Applicant/
Landowner .

Prior to the issuance of a grading permit, the project proponent shall demonstrate to the City that consultation with the United States Fish and Wildlife Service for an evaluation of proposed project impacts to Coastal California gnatcatcher in accordance with the Federal Endangered Species Act has been completed (e.g., Section 10 consultation) or is not required.

Proof of consultation
with USFWS
regarding impacts to
coastal California
gnatcatcher
submitted to the
Planning Director.

Prior to issuance
of a grading
permit.

Applicant/
Landowner.

BIO-2a and BIO-2b: The
project has the potential
for direct and indirect
impacts to Cooper’s
Hawk, yellow-breasted
MM-BIO-2 Nesting Bird and Raptor Avoidance
If initial grading and vegetation removal activities (i.e., earthwork, clearing, and grubbing) must occur during the nesting season for coastal California gnatcatcher (February 15 through August 30), the project applicant shall retain a qualified biologist to conduct If site clearing
activities occur
during breeding
season, conduct a
pre-construction
For construction
activities
proposed for the
period of
January 15
Applicant/
Landowner, Project
Biologist.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 137
Impact Mitigation Measure Action Timing Responsibility
chat, yellow warbler and
other nesting birds and
raptors.
pre-construction surveys to determine the presence or absence of this species. Additionally, a pre-construction survey for migratory birds and raptors during the general bird breeding season (January 15 through September 15) shall also be
conducted if applicable. The survey shall consist of searching for nesting birds within the proposed work area and surrounding 300 feet, where feasible, and the final survey shall not be completed more than three days prior to the beginning of impacts. If the surveys conclude no active nesting, the work shall resume as planned without further requirements. If the results of the survey identify nesting birds (including raptors), no-work species-dependent disturbance buffers shall be implemented as follows: 100 feet around non-listed active passerine (perching birds and songbirds) nests, 300 feet around listed passerine nests (e.g., coastal California gnatcatcher), and 300 feet around active raptor nests (e.g., Cooper’s hawk). The buffers may be reduced, if appropriate, and as directed by a qualified biologist.

The reduction in no-work buffers shall be approved by the City prior to implementation. The qualified biologist will regularly monitor active nest during work hours to monitor chick
development and parent stress to mitigate indirect effects to nesting birds (i.e., noise, dust, human presence, etc.) and accurately determine when the juveniles have fledged. The buffers shall be respected and maintained until the qualified biologist has determined that all juveniles have fledged.

If coastal California gnatcatcher is determined to be nesting on the project site or within the 300-foot survey buffer, no construction activities that would result in noise levels exceeding 60 A-weighted decibel (dBA) hourly Energy Equivalent Noise Level (Leq
) at the nest site shall be allowed. Ambient background noise shall be excluded from the 60 dBA calculation. Noise barriers or other noise attenuation measures shall be
implemented to reduce noise impacts to occupied coastal California gnatcatcher habitat to below 60 dBA hourly Leq and/or the activities shall be suspended. Noise monitoring shall be conducted weekly, to confirm noise levels remain at or below 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
through
September 15,
conduct survey
within three days
prior to the start
of construction
activities.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 138
Impact Mitigation Measure Action Timing Responsibility
60 dBA hourly Leq. The results of weekly noise monitoring will be submitted to the City.

BIO-2c: The project has
the potential to impact
Coronado skink and
Blainville’s horned lizard.

Implementation of mitigation measures MM-BIO-1, MM-BIO-3 and MM-BIO-4 would reduce potential impacts to below a level of significance.

BIO-3: Permanent impact
to 2.1 acres of Diegan
coastal sage scrub, 0.7
acre of Baccharis scrub
and 0.03 are of non-
native grassland.

MM-BIO-3 Sensitive Vegetation Mitigation
Prior to land disturbance, clearing, grubbing, and/or the issuance of a grading permit for the project site, impacts to 2.1 acres of Diegan coastal sage scrub and 0.7 acre of baccharis scrub shall be mitigated at a 2:1 ratio, for a total of 5.6 acres of coastal sage scrub. Impacts to 0.3 acre of non-native grassland shall be mitigated at a 0.5:1 mitigation ratio.

Of the 5.6 acres of coastal sage scrub mitigation required, a minimum of 2.1 acres shall be occupied by coastal California gnatcatcher (see MM-BIO-1). The remaining 3.5 acres of coastal sage scrub mitigation, as well as the 0.15 acre of non-native grassland mitigation, shall be provided through the total purchase of 3.65 acres of coastal sage scrub at the Red Mountain Conservation Bank or another California Department of Fish and Wildlife approved mitigation bank, unless otherwise required by the City or Wildlife Agencies.

Proof of purchase of
credits from a
mitigation bank
submitted to
Planning Director.

Prior to land
disturbance,
clearing,
grubbing, and/or
the issuance of a
grading permit
for the project
site

Applicant/
Landowner.

BIO-4: Project
construction would occur
immediately adjacent to
sensitive southern
cottonwood-willow
riparian forest habitat.

Inadvertent intrusion into
this adjacent sensitive
habitat by construction
vehicles, equipment, and
personnel could result in
additional impacts

MM-BIO-4 Best Management Practices
The project applicant shall ensure the construction contractor implements Best Management Practices (BMPs) including but not limited to: flagging/fencing the limits of construction adjacent to sensitive habitats; maintaining the project area free of trash and debris which will not only keep the habitat clean but reduce the potential of attracting predator/scavenger species; locating staging and refueling areas at least 50 feet from jurisdictional waters; employing appropriate standard spill prevention practices and clean-up materials; installing and maintaining sediment and erosion control measures in
accordance with an approved Storm Water Pollution Prevention Plan (SWPPP); maintaining effective control of fugitive dust; Implementation of
BMPs during
construction.

Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 139
Impact Mitigation Measure Action Timing Responsibility
properly storing, handling, and disposing of all toxins and pollutants, including waste materials; and shielding and directing lighting (if work to be conducted at night) away from habitats along the Twin Oaks Valley Creek, and the native habitats (coastal sage scrub) in the vicinity.

MM-BIO-5 Biological Construction Monitoring
A qualified biologist shall be retained to oversee initial clearing/grubbing efforts as well as site grading and other construction activities that have the potential to impact native vegetation communities and other sensitive biological resources which occur outside of the development footprint. Monitoring frequency will be determined by the qualified biologist and shall be based on the type of activity and proximity to sensitive biological resources. Other responsibilities shall include verification of boundary fencing/staking prior to the start of construction, site inspections to confirm the project boundary remains clearly defined, and attending a pre-construction meeting. At the pre-construction meeting, the qualified biologist shall discuss the project’s biological mitigation measures and familiarize construction personnel with the surrounding sensitive biological resources.

Biological monitoring
during construction.

Prior to and
during
construction.

Applicant/
Landowner, Project
Biologist,
Contractor.

CULTURAL RESOURCES
CR-1: Due to grading and
ground disturbing
activities, the proposed
project has the potential
to impact unidentified
archaeological resources
on the project site.

MM-CR-1a Pre-Excavation Agreement
Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall enter into a Tribal Cultural Resources Treatment and Repatriation Agreement (Pre-
Excavation Agreement) with a Traditionally and Culturally Affiliated Native American Tribe (TCA Tribe), identified in consultation with the City. The purpose of the Pre-Excavation Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the TCA Tribe for the
protection, treatment, and repatriation of 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 Enter into a pre-
excavation
agreement with TCA
Tribe.

Prior to issuance
of a grading
permit

Applicant/
Landowner,
Archaeologist, TCA
Tribe
representative.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 140
Impact Mitigation Measure Action Timing Responsibility
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 Pre-Excavation 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 Pre-Excavation Agreement. If the TCA Tribe does not accept the return of the cultural resources, then the cultural resources will be subject to curation.

MM-CR-1b 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 a Qualified Archaeologist and Traditionally and Culturally Affiliated Native American monitor (TCA Native American monitor) have been retained at the Applicant/Owner or Grading Contractor’s expense to implement the construction monitoring program, as described in the Pre-Excavation Agreement
.

The Qualified Archaeologist and 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 Qualified Archaeologist and TCA Native American monitor shall be present onsite during grubbing, grading, trenching, Provide
documentation to
the City’s Planning
Division that a
qualified
archaeologist and
TCA Native American
monitor have been
retained.

Conduct construction
monitoring and at its
conclusion submit
archaeological
monitoring report
documenting
findings to the City.

Prior to the
issuance of a
grading permit.

Applicant/
Landowner,
Archaeologist,
Tribal Monitor,
Contractor.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 141
Impact Mitigation Measure Action Timing Responsibility
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 pavi ng,
the Qualified Archaeologist and 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 more than six inches below the original pre-project ground surface to identify any evidence of potential
archaeological or 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 Qualified Archaeologist and TCA Native American monitor.

The Qualified Archaeologist 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 Tribe, preferably through e-mail, of the start and end of all ground disturbing activities.

Prior to the release of any grading bonds, or prior to the issuance of any project Certificate of Occupancy, an archaeological monitoring report, which describes the results, analysis, and conclusions of the construction monitoring shall be submitted by the Qualified Archaeologist, along with any TCA Native American monitor’s notes and comments received by the Qualified
Archaeologist, to the Planning Division Manager for approval.

Once approved, a final copy of the archaeological monitoring report shall be retained in a confidential City project file and may

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 142
Impact Mitigation Measure Action Timing Responsibility
be released, as a formal condition of Assembly Bill (AB) 52 consultation, to San Luis Rey Band of Mission Indians, Rincon Band of Luiseño Indians, or any parties involved in the project specific monitoring or consultation process. A final copy of the report, with all confidential site records and appendices, will also be submitted to the South Coastal Information Center after approval by the City.

MM-CR-1c Unanticipated Discovery Procedures
Both the Qualified Archaeologist and the TCA Native American monitor may temporarily halt or divert ground disturbing activities if potential archaeological resources or 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. Isolates and clearly non-significant archaeological resources (as determined by the Qualified Archaeologist, in consultation with the TCA Native American monitor) will be minimally documented in the field. All unearthed archaeological resources or tribal cultural resources will be collected, temporarily stored in a secure location (or as otherwise agreed upon by the Qualified Archaeologist and the TCA Tribe), and repatriated according to the terms of the Pre-Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent
jurisdiction.

If a determination is made that the archaeological resources or tribal cultural resources are considered potentially significant by the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor, then the City and the TCA Tribe shall determine, in consultation with the Applicant/Owner and the Qualified Archaeologist, the culturally appropriate treatment of those resources.

If the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor cannot agree on the significance or mitigation for such resources, these issues will be presented to the If potential cultural
resources are found,
halt ground
disturbance and
follow procedures
listed for discovery.

During all earth
moving and
ground
disturbing
activity.

Applicant/
Landowner,
Archaeologist,
Tribal Monitor,
Contractor.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 143
Impact Mitigation Measure Action Timing Responsibility
Planning Division Manager for decision. The Planning Division Manager shall make a determination based upon the provisions of CEQA and California Public Resources Code Section
21083.2(b) with respect to archaeological resources and California Public Resources Section 21704 and 21084.3 with respect to tribal cultural resources, and shall take into account the religious beliefs, cultural beliefs, customs, and practices of the TCA Tribe.

All sacred sites, significant tribal cultural resources, and/or unique archaeological 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 t he
City as the Lead Agency, then the City shall require additional culturally appropriate mitigation to address the negative impact to the resource, such as, but not limited to, the funding of an ethnographic study and/or a data recovery plan, as determined by the City in consultation with the Qualified Archaeologist and the TCA Tribe. The TCA Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation and the drafting and finalization of any ethnographic study and/or data recovery plan, and/or other culturally appropriate mitigation. Any archaeological isolates or other cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site (or as otherwise agreed upon by the Qualified Archaeologist and TCA Tribe), and repatriated according to the terms of the Pre-Excavation Agreement, unless ordered to do otherwise by 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.

If a data recovery plan is authorized as indicated above and the TCA Tribe does not object, then an adequate artifact sample to address research avenues previously identified for sites in the area will be collected using professional archaeological collection methods. If the Qualified Archaeologist collects such

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 144
Impact Mitigation Measure Action Timing Responsibility
resources, the TCA Native American monitor must be present during any testing or cataloging of those resources. Moreover, if the Qualified Archaeologist does not collect the cultural resources that are unearthed during the ground disturbing activities, the TCA Native American monitor may, at their discretion, collect said resources for later reburial or storage at a local curation facility, as described in the Pre-Excavation Agreement.

In the event that curation of archaeological resources or tribal cultural 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 TCA Tribe or the curation facility, whichever is most applicable, that the repatriation and/or curation have been completed.

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

MM-CR-1d 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 human remains
are found, halt
ground disturbance
and follow
procedures listed for
discovery.

During all earth
moving and
ground
disturbing
activity.

Archaeologist,
Tribal Monitor.

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 145
Impact Mitigation Measure Action Timing Responsibility
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.

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)).

GEOLOGY AND SOILS

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 146
Impact Mitigation Measure Action Timing Responsibility
GEO-1: The project site
contains expansive soils.

MM-GEO-1 Expansive Soils
The project applicant shall implement the geotechnical
recommendations identified beginning on pages 7 – 17 of the Geotechnical Investigation Report and follow the Expansive Soil Guidelines provided on pages 18-21 prepared by Norcal
Engineering for the project site.

Implement the
geotechnical
recommendations
During project
construction.

Applicant/
Landowner,
Contractor.

GEO-2: Project grading
may result in disturbance
of previously unknown
paleontological
resources.

MM-GEO-2 Paleontological Resources:

Prior to project grading the project applicant shall retain a qualified paleontologist to review the proposed project area to determine the potential for paleontological resources to be encountered. If there is a potential for paleontological resources to occur, the paleontologist shall identify the area(s) where these resources are expected to be present, and a qualified
paleontological monitor shall be retained to monitor the initial cut in any areas that have the potential to contain
paleontological resources.

Site review and if
potential for
paleontological
resources is
identified, monitoring
of initial cut in any
areas that have the
potential for
resources.

If potential
paleontological
resources are found,
follow procedures
listed for discovery.

Prior to grading
and if applicable
during initial cut.

Applicant/
Landowner,
Paleontologist.

NOISE
N-1: Elevated noise levels
at outdoor usable areas
(ground-floor patios and
upper floor balconies
that front E. Mission
Road and Woodward
Street.

MM-N-1
Patios and balconies in units that front E. Mission Road and Woodward Street, as detailed in Figure 10 of the IS/MND, shall require 4-foot barriers to reduce sound levels. The barriers must be constructed of non-gapping materials (i.e., masonry, stucco, ¼ inch thick glass or Plexiglas).

Show 4-foot barriers
on patios and
balconies fronting E.

Mission Road and
Woodward Street.

During final
architectural
plan review.

Applicant/
Landowner, City
(Planning Director
).

TRIBAL CULTURAL RESOURCES
TR-1: The project site is
within a tribal cultural
landscape and has the
potential to impact a
tribal cultural resource.

MM-TCR-1
The project applicant shall incorporate interpretive signage near a seating area on the project site to acknowledge the Luiseño people’s history and culture. The content of the interpretive panel shall be consulted with and approved by the Rincon Band.

The location for the signage shall be shown on the project plans.

Present location of
interpretive signage
on the project plans.

The interpretive
signage shall be
During plan
review and
during project
construction.

Applicant/
Landowner, City
(Planning Director)

Lanikai Senior Residential Apartments City of San Marcos Initial Study/Mitigated Negative Declaration April 2026 147
Impact Mitigation Measure Action Timing Responsibility
placed during project
construction.

MM-TCR-2
An archaeological and Tribal monitor shall be present for all ground disturbing activities associated with the project.

Provide
documentation to
the City’s Planning
Division that a
qualified
archaeologist and
TCA Native American
monitor have been
retained.

Conduct construction
monitoring and at its
conclusion submit
archaeological
monitoring report
documenting
findings to the City.

Prior to the
issuance of a
grading permit.

Applicant/
Landowner,
Archaeologist,
Tribal Monitor,
Contractor.

MM-TCR-3
Prior to the issuance of the grading permit, the
developer/applicant shall provide evidence to the Planning Director that an Environmental Constraints Sheet has been included in the grading plans. This sheet shall indicate an area that will be protected and not disturbed in the future. This area will be used for reburial of any artifacts that will be impacted and/or discovered during grading. This is confidential and the exact nature of this area will not be called out on the grading plans.

Inclusion of an
Environmental
Constraints sheet in
the grading plan set.

Prior to the
issuance of a
grading permit.

Applicant/
Landowner, City
(Planning Director).

EXHIBIT 11
Page | 0

Project Number: 001718
Date: September 17, 2019

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Table of Contents
Section Page

1.0 INTRODUCTION 8

2.0 METHODOLOGY 12

3.0 EXISTING CONDITIONS 16

4.0 PROPOSED PROJECT 21

5.0 EXISTING PLUS PROJECT 26

6.0 NEAR TERM 31

7.0 NEAR TERM PLUS PROJECT 36

8.0 HORIZON YEAR 2035 41

9.0 HORIZON YEAR 2035 PLUS PROJECT 47

10.0 ONSITE CIRCULATION AND PARKING ANALYSIS 53

11.0 ANALYSIS OF OTHER MODES OF TRANSPORTATION 56

12.0 CONCLUSIONS, RECOMMENDATIONS, AND MITIGATIONS 57

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Figures
Section Page
FIGURE 1-1: PROJECT SITE PLAN 9
FIGURE 1-1: STUDY AREA MAP 11
FIGURE 3-1: EXISTING ADT VOLUMES 19
FIGURE 3-2: EXISTING PEAK HOUR TRAFFIC VOLUMES 20
FIGURE 4-1: PROJECT TRIP DISTRIBUTION 23
FIGURE 4-2: PROJECT ONLY PEAK HOUR VOLUMES 24
FIGURE 4-3: PROJECT ONLY ADT VOLUMES 25
FIGURE 5-1: EXISTING PLUS PROJECT 27
FIGURE 5-2: EXISTING PLUS PROJECT PEAK HOUR VOLUMES 29
FIGURE 6-1: NEAR TERM ADT 32
FIGURE 6-2: NEAR TERM PEAK HOUR VOLUMES 34
FIGURE 7-1: NEAR TERM PLUS PROJECT ADT VOLUMES 37
FIGURE 7-2: NEAR TERM PLUS PROJECT PEAK HOUR VOLUMES 39 San Marcos Senior Apartment Project September 17, 2019 Page | 3

FIGURE 8-1: SANDAG TFIC SERIES 13, YEAR 2035 42
FIGURE 8-2: HORIZON YEAR 2035 ADT VOLUMES 43
FIGURE 8-3: HORIZON YEAR 2035 PEAK HOUR VOLUMES 45
FIGURE 9-1: HORIZON YEAR PLUS PROJECT ADT VOLUMES 48
FIGURE 9-2: HORIZON YEAR 2035 PLUS PROJECT PEAK HOUR VOLUMES 50 FIGURE 10-1: SAN MARCOS ZONING ORDINANCE FOR OFF-STREET PARKING 54

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Tables
Section Page
TABLE 1-1: STUDY AREA STREET SEGMENTS AND INTERSECTIONS 10 TABLE 3-1: EXISTING STREET SEGMENT LOS ANALYSIS 17
TABLE 3-2: EXISTING INTERSECTION LOS ANALYSIS 18
TABLE 4-1: TRIP GENERATION: 21
TABLE 5-1: EXISTING PLUS PROJECT STREET SEGMENT ANALYSIS 26 TABLE 5-2: EXISTING & EXISTING PLUS PROJECT STREET SEGMENT ANALYSIS 28 TABLE 5-3: EXISTING PLUS PROJECT INTERSECTION LOS ANALYSIS 30 TABLE 5-4: EXISTING & EXISTING PLUS PROJECT INTERSECTION COMPARISONS 30 TABLE 6-1: NEAR TERM STREET SEGMENT ANALYSIS 33
TABLE 6-2 NEAR TERM INTERSECTION LOS ANALYSIS 35
TABLE 7-1: NEAR PLUS PROJECT STREET SEGMENT ANALYSIS 36 TABLE 7-2: NEAR TERM & NEAR TERM PLUS PROJECT STREET SEGMENT COMPARISONS 38
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TABLE 7-3: NEAR TERM PLUS PROJECT INTERSECTION LOS ANALYSIS 40 TABLE 7-4: NEAR TERM & NEAR TERM PLUS PROJECT INTERSECTION LOS COMPARISONS 40
TABLE 8-1: HORIZON YEAR 2035 STREET SEGMENT ANALYSIS 44 TABLE 8-2: HORIZON YEAR 2035 INTERSECTION LOS ANALYSIS 46 TABLE 9-1: HORIZON YEAR 2035 PLUS PROJECT STREET SEGMENT 47 TABLE 9-2: HORIZON YEAR 2035 & HORIZON YEAR 2035 PLUS PROJECT STREET SEGMENT COMPARISONS 49
TABLE 9-3: HORIZON YEAR PLUS PROJECT INTERSECTION LOS ANALYSIS 51 TABLE 9-4: HORIZON YEAR 2035 & HORIZON YEAR 2035 PLUS PROJECT INTERSECTION COMPARISONS 51

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Appendices
Section Page
APPENDIX A: TRAFFIC COUNTS 59
APPENDIX B: EXISTING SCENARIO SYNCHRO WORKSHEETS 60
APPENDIX C: EXISTING +PROJECT SCENARIO SYNCHRO WORKSHEETS 61 APPENDIX D: NEAR TERM SCENARIO SYNCHRO WORKSHEETS 62
APPENDIX E: NEAR TERM + PROJECT SCENARIO SYNCHRO WORKSHEETS 63 APPENDIX F: HORIZON YEAR 2035 SCENARIO SYNCHRO WORKSHEETS 64 APPENDIX G: HORIZON YEAR 2035 + PROJECT SCENARIO SYNCHRO WORKSHEETS 65 APPENDIX H: QUEUING SYNCHRO SHEETS 66

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Executive Summary
Urban Systems Associates, Inc. was retained to evaluate possible traffic impacts with the construction of the proposed project located at Woodward St. and Mission Rd. in San Marcos California. The proposed project is a 11 5-unit age -restricted senior housing on the site. The proposed project falls within the jurisdiction of the City of San Marcos and the Traffic Impact Analysis will adhere to the SANTEC/ITE Guidelines for Traffic Impact Studies in the San Diego Region (dated March 2, 2000).

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1.0 INTRODUCTION
Urban Systems Associates, Inc has prepared a Traffic Impact Analysis for the proposed development of 115 units of senior housing located at the Woodward St. and Mission Rd. site.

To evaluate possible project impacts, the scenarios of Existing, Existing Plus Project, Near Term (2023), Near Term Plus Project (2023), Buildout Year 2035, and Buildout Year 2035 Plus Project were evaluated.

2.0 Project Description
The proposed project will be located at the northwest corner of undeveloped land at the intersection of Woodward Street and Mission Road in San Marcos California. The project includes 115 units of age restricted senior living home on roughly 3.9 acres of land. The project is expected to generate 460 average daily trips (ADT) with 23 (9 in / 14 out) AM peak hour trips and 32 (19 in / 13 out) PM peak hour trips.

A site plan of the project is provided in Figure 1-1.

Table 1-1 displays the study area street se gments and intersections and Figure 1-2 displays the study area map.

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Figure 1-1: Project Site Plan

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Segment
Borden Road to Richmar Avenue
Richmar Avenue to San Marcos Boulevard
Twin Oaks Valley Road to East Mission Road
East Mission Road to Vineyard Road
Vineyard Road to Borden Road
Twin Oaks Valley Road to Woodward Street
Number
1 2
3 4
5 6
Twin Oaks Valley Road
Street Segments
Road
Twin Oaks Valley Road
Woodward Street
Borden Road
Intersections
Woodward Street
San Marcos Boulevard
Woodward Street at Borden Road
Twin Oaks Valley Road at San Marcos Boulevard
Intersection
Twin Oaks Valley Road at Richmar Avenue
Woodward Street at East Mission Road
Twin Oaks Valley Road at Borden Road
Woodward Street at Vineyard Road
Table 1-1: Study Area Street Segments and Intersections

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Figure 1-1: Study Area Map

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2.0 Methodology
The Traffic Impact Study was prepared with accordance to the SANTEC/ITE Guidelines for Traffic Impact Studies in the San Diego Region (dated March 2, 2000).

According to the flow chart shown on the previous page, a TIS is probably not required due to the proposed project only producing 460 ADT. However “for health and safety reasons, and/or local and residential street issues, an abbreviated or focused TIS may still be requested by a local agency.

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Street segments within the study area were analyzed using SANTEC/ITE roadway classifications provided below.

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Studied intersections were analyzed using the software program Synchro 10. Highway Capaci ty Manual Methodologies are applied within Synchro 10 and are used to calculate for intersections delays to measure intersection level of service. The table below is the criteria for intersection level of service.

The studied street segments and intersections were analyzed for significant project impacts based on the “Measure of Significant Project Traffic Impacts” table provided in the SANTEC/ITE guidelines, the table can be seen on the next page.

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3.0 Existing Conditions
To analyze Existing condition traffic scenarios, traffic volumes were obtained on January 25, 2018.

These volumes were evaluated to determine current operating conditions. The traffic volumes for the Existing Conditions are provided in Appendix A.

3.1 Existing Transportation Conditions
The following street segments were analyzed in the Existing scenario:
• Twin Oaks Valley Road – between Borden Road and Richmar Avenue • Twin Oaks Valley Road – between Richmar Avenue to San Marcos Boulevard • San Marcos Boulevard – between Twin Oaks Valley Road to East Mission Road • Woodward Street – between East Mission Road to Vineyard Road • Woodward Street – between Vineyard Road to Borden Road • Borden Road – between Twin Oaks Valley Road to Woodward Street Figure 3-1 displays the Existing ADT volumes for the studied street segments.

Based on the roadway classifications table provided in the SANTEC/ITE Traffic Impact Study Guidelines, all street segments are operating at an acceptable level of Service (LOS) of D or better.

The following intersections were analyzed in the Existing scenario:
• Twin Oaks Valley Road at Borden Road
• Woodward Street at Borden Road
• Woodward Street at Vineyard Road
• Twin Oaks Valley Road at Richmar Avenue
• Woodward Street at East Mission Road
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Road Segment Standard # of Ln. Class. Cap. Volume V/C LOS Borden Road to Richmar Avenue SANTEC/ITE 4 4-M 40,000 28,115 0.70 C Richmar Avenue to San Marcos Boulevard SANTEC/ITE 4 4-M 40,000 27,109 0.68 C San Marcos Boulevard Twin Oaks Valley Road East Mission Road SANTEC/ITE 4 4-M 40,000 16,882 0.42 B East Mission Road to Vineyard Road SANTEC/ITE 4 4-C 30,000 7,816 0.26 A Vineyard Road to Borden Road SANTEC/ITE 2 2-Ca 15,000 3,781 0.25 A Borden Road Twin Oaks Valley Road to Woodward Street SANTEC/ITE 4 4-C 30,000 10,325 0.34 B Legend:

Class. = Functional Class
Cap. = Capacity
LOS = Level of Service
4-C = 4 Lane Secondary Arterial, LOS "E" Capacity 30,000 4-M = 4 Lane Major Arterial, LOS "E" Capacity 40,000
Woodward Street
Twin Oaks Valley Road
• Twin Oaks Valley Road at San Marcos Boulevard
The Existing peak hour traffic volumes at the studied intersections are displayed in Figure 3-2.

The average delay and level of service at the studied intersections in the AM and PM peak hours were analyzed using Synchro 10. Due to unavailable signal timing sheets for the studied intersections, phasing and signal timing were determined based on engineering judgement and geometric measurements via google earth to determine a conservative value for timing.

Table 3-1 displays the Existing street segment LOS analysis.

Table 3-2 displays the Existing intersection LOS analysis.

Table 3-1: Existing Street Segment LOS Analysis

All street segments are operating at an acceptable level of service in the Existing conditions.

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Delay LOS Delay LOS
1 Twin Oaks Valley Road at Borden Road Signalized 43.1 D 37.7 D 2 Woodward Street at Borden Road Signalized 29.2 C 40.4 D 3 Woodward Street at Vineyard Road Signalized 16.1 B 9.2 A 4 Twin Oaks Valley Road at Richmar Avenue Signalized 20.0 B 30.1 C 5 Woodward Street at East Mission Road Signalized 46.1 D 50.1 D 6 Twin Oaks Valley Road at San Marcos Boulevard Signalized 55.5 E 66.6 E Notes: