Santee City Council
September 14, 2022

STAFF REPORT

PUBLIC HEARING FOR THE DEVELOPMENT OF FANITA RANCH, FINAL REVISED ENVIRONMENTAL IMPACT REPORT (AEIS2017-11), GENERAL PLAN AMENDMENT (GPA2017-2), AN ORDINANCE ESTABLISHING THE “SPECIFIC PLAN” ZONE DISTRICT, APPROVING A ZONE DISTRICT AMENDMENT (R2017-1) TO AMEND THE BASE ZONE DISTRICT FROM “PD - PLANNED DEVELOPMENT” TO “SP - SPECIFIC PLAN,” AND ADOPTING THE FANITA RANCH SPECIFIC PLAN (SP2017-1), VESTING TENTATIVE MAP (TM2017-3), DEVELOPMENT REVIEW PERMIT (DR2017-4) CONDITIONAL USE PERMITS FOR PUBLIC PARKS (P2017-5, P2020-2), AND AN ORDINANCE APPROVING

AND AUTHORIZING THE CITY MANAGER TO EXECUTE A DEVELOPMENT

AGREEMENT BETWEEN THE CITY OF SANTEE AND HOMEFED FANITA RANCHO LLC APPLICANT: HOMEFED FANITA RANCHO LLC
CITY COUNCIL MEETING SEPTEMBER 23, 2020
In compliance with the California Environmental Quality Act (CEQA), a Draft Revised Environmental Impact Report (EIR) was prepared by the City for the proposed Fanita Ranch Project. A Notice of Availability of the Draft Revised EIR was published in the East County Californian on May 29, 2020. A total of 255 copies of the Notice of Availability were mailed and 74 copies of the Notice of Availability were emailed to agencies, tribes, organizations and individuals who had requested notice or otherwise indicated an interest in the project. An electronic version of the Notice of Availability as well as the Draft Revised EIR, technical appendices and a link to the administrative record prepared under Public Resources Code Section 21167.6.2 were also posted on the City of Santee’s website on May 29, 2020 and filed and posted with the San Diego County Clerk. A Notice of Completion and the Draft Revised EIR were submitted to the California Office of Planning and Research. Three sets of the Draft Revised EIR and the technical appendices were made available at the City of Santee in the Development Services Department, City Clerk’s office and City Manager’s office.

The Draft Revised EIR was circulated for public review from May 29, 2020 through 5:00 p.m. (close of business) on July 13, 2020 (SCH No. 2005061118). During that time, the document was reviewed by various federal, state and local agencies, as well as by interested tribes, organizations, and individuals. A total of 216 timely comment letters/emails were received by the City. Written comments received by the City have been fully addressed in written responses.

The City has prepared a Final Revised EIR, consisting of the written comments received during the review and comment period on the EIR; written responses to those comments as well as thematic responses; a First Errata (Volume III) showing revisions to the Draft Revised EIR (Volume I) and technical appendices (Volume II) in response to comments; and a Second Errata (Volume IV) showing revisions to the Final Revised EIR and technical appendices to reflect the removal of the Magnolia Avenue extension from the project in response to a request made by the applicant on August 20, 2020. The Final Revised EIR may be found on the City’s website at https://www.cityofsanteeca.gov, along with the Draft Revised EIR and Exhibit A to the Staff Report
corresponding technical appendices. The Final Revised EIR is also available in the administrative record for the project posted on SharePoint for the Fanita Ranch Project accessible at:
https://www.cityofsanteeca.gov or
http://sntbberry.cityofsanteeca.gov/sites/FanitaRanch/Public/default.aspx For purposes of this Staff Report, “Revised EIR” refers to the Final Revised EIR.

A Notice of Public Hearing for September 23, 2020 was published in the East County Californian on September 11, 2020, and mailed by U.S. Postal Service or e-mailed to interested parties and agencies on September 10 and 11, 2020, respectively. An electronic version of the Public Hearing Notice was also posted on the City’s website at http://www.cityofsanteeca.gov on September 10, 2020. As explained further below (see Section F, Removal of Magnolia Extension as Project Design Feature), a public hearing was initially noticed for August 26, 2020 but was canceled due to the request received by the applicant on August 20 to remove the extension of Magnolia Avenue from the project.

Staff Report, September 23, 2020
Fanita Ranch

A. SITUATION AND FACTS

1. Requested by ................................. HomeFed Fanita Rancho LLC

2. Land Owner(s)................................. HomeFed Fanita Rancho LLC (see Ownership Disclosure for others, Attachment 1)

3. Type and Purpose of Request Revised Environmental Impact Report; General Plan Amendment; Vesting Tentative Map; Development
Review Permit for development regulations; Specific
Plan for allowable uses and development standards;
Conditional Use Permits for 2 public parks;
Development Agreement to provide public benefit.

4. Location........................................... North of Carlton Hills Blvd and Fanita Parkway

5. Site Area ......................................... 2,368 acres

6. Number of lots................................. 1,467 (proposed)

7. Number of units 2,949 with school; 3,008 without school

8. Density ............................................ Various (4-50 dwelling units per acre)

9. Hillside Overlay ............................... No

10. Existing Zoning................................ PD-Planned Development; Proposed SP-Specific Plan

11. Surrounding Zoning......................... North: Unincorporated Lakeside Rural Residential South: R-2, R-1, R1A, HL
East: Unincorporated Lakeside Rural Residential
West: MCAS Miramar; East Elliot (San Diego)

12. General Plan Designation ............... Planned Development District

13. Existing Land Use............................ Undeveloped site

14. Surrounding Land Use .................... North: Open space South: Single-family residential
East: Undeveloped land; rural residential
West: Open space; PDMWD water treatment
facility

15. . Terrain…………………………………Hillside and valley terrain

16. Environmental Status ...................... Final Revised Environmental Impact Report (SCH# 2005061118)

17. Within Airport Influence Area (AIA)…Gillespie Field and MCAS AIA Staff Report, September 23, 2020
Fanita Ranch

B. LATE COMMENTS ON DRAFT REVISED EIR
After the close of the comment period for the Draft Revised EIR on July 13, 2020 at 5:00 p.m., the City continued to receive dozens of additional comments, which may be found in the administrative record posted on SharePoint for the Fanita Ranch Project accessible at:
https://www.cityofsanteeca.gov or
http://sntbberry.cityofsanteeca.gov/sites/FanitaRanch/Public/default.aspx Late comments may be found in Section (G), Remainder of the Record, Subsection (14)(C), Documents Received After Release of Draft EIR for Comment, Comments and Other Correspondence on Draft EIR.

CEQA does not require the lead agency to respond to late comments. The lead agency is also not required to delay the environmental review process to prepare responses to late comments. (Public Resources Code, § 21091(d)); CEQA Guidelines, § 15088(a); 15207.) Late comments, which were submitted in support and in opposition to the project, did not raise any new environmental issues that were not previously addressed in the EIR, responses to timely comments on the EIR, or elsewhere in the administrative record for the project. Late comment letters submitted to the City by the Southwest Regional Council of Carpenters (received on July 13, 2020 at 5:50 p.m.) and the Center for Biological Diversity, with comments from SWAPE (received on July 28, 2020) raised environmental concerns warranting further clarification. Those late comment letters and the City’s responses are located in Attachments 7 and 8, respectively, to this Staff Report.

C. BACKGROUND
In 2003, with the adoption of the City’s “General Plan 2020”, the previous “Specific Plan” land use designation for the Fanita Ranch site was changed to “Planned Development” and the 16 “Essential Elements” that guided development of the property were restated as the 16 “Guiding Principles”. These principles adhered to a longstanding vision of “move-up” housing with 40% of the lots ranging in size from 10,000 to 20,000 square feet. The Guiding Principles included development of a golf course with hotel/conference facility, a business park, and a recreational facility next to a man-made lake. The extensions of Fanita Parkway and Cuyamaca Street were expected, but the extension of Magnolia Avenue would be based on a proposed project’s impacts and/or necessity.

In 2007, the City certified an Environmental Impact Report (SCH# 200506118) and issued entitlements to Barratt American Inc., Fanita Partners LLC for 1,395 dwelling units, with 80% of these on lots ranging in size between 10,000 and 20,000 square feet, in accordance with the Guiding Principles. The development included a commercial center, recreational vehicle storage, parks, a community building, lake, trail network and a 1,412-acre habitat preserve.

Site design was in the form of four villages that extended from south to north, with road extensions designed for Fanita Parkway, Carlton Hills Boulevard and Cuyamaca Street to serve the development. From 2008 through 2012, the entitlements and EIR were subject to litigation and the project did not move forward. Refer to the Revised EIR (Section 2.2) for Staff Report, September 23, 2020
Fanita Ranch

additional discussion on the Project Background.

In August 2018, HomeFed and JWO Land LLC, as new owners of the project site, submitted a complete application to the City for 2,949 dwelling units, 80,000 square feet of commercial/civic uses, trails, parks, farmland, recreational vehicle storage and a 1,640-acre habitat preserve. Fanita Parkway, Cuyamaca Street and Magnolia Avenue would serve three villages, namely Fanita Commons, Orchard Village and Vineyard Village.

While the Barratt American project proposed a Development Plan and an Administrative Program for procedures, regulations and guidelines to implement the project, the current applicant has chosen to utilize a single Specific Plan for similar purposes. As such, the application includes a General Plan Amendment to restore the pre-2003 “SP – Specific Plan” land use designation and Base Zone District “SP” classification and to replace the 16 Guiding Principles with 13 Guiding Principles. Prior to formal project application submittal, in November 2015, the City Council received a staff presentation on the Fanita Ranch Guiding Principles and potential ways in which these could be changed to reflect a more compact and sustainable development.

California State law authorizes cities to prepare and adopt Specific Plans for the systematic implementation of the General Plan for all or part of the area covered by the General Plan (Government Code Section 65450). Specific Plans contain both planning policies and regulations and may combine zoning regulations, capital improvement programs, detailed development regulations, and other regulatory requirements into one document designed to meet the needs of a specific area. Specific Plans may be adopted by City Council Resolution or by Ordinance. Per the application, the subject Specific Plan would be adopted by Ordinance because of its regulatory nature, to include established land uses and development standards.

Staff has worked with the applicant for five years on this project, including preparation of the Revised EIR by the City’s consultant. During this time the City updated its Circulation Element (Mobility Element), updated its Five-Year Capital Improvement Program twice, and adopted a Climate Action Plan, known as the “Sustainable Santee Plan.” The project’s Resolutions and Ordinances recommended by staff for approval represent the work of many professionals in the fields of planning, engineering, traffic, fire and environmental sciences. City staff obtained third-party peer review for many of the technical reports in support of the analysis and conclusions in the Revised EIR, as well as many of the mitigation measures and conditions of approval to be imposed during construction and operation of the project.

Beginning in 2019, four public workshops were held to inform both the City Council and the public about the project:

May 8, 2019: Application and overview of the development proposal September 11, 2019: Transportation and circulation overview October 23, 2019: Parks, trails and open space overview February 12, 2020: Fire protection and public safety overview Staff Report, September 23, 2020
Fanita Ranch

The applicant has conducted substantial public outreach regarding the project over the past few years, reiterating its commitment that no certificates of occupancy would be issued for the project until certain SR-52 corridor improvements have been installed by Caltrans. That commitment is memorialized in the proposed Development Agreement (Section 4.5.2) between the City and the applicant and is also discussed in the Revised EIR (See Appendix N to the Draft Revised EIR, Traffic Impact Analysis, Section 21.4).

More specifically, the SR-52 improvements include:
• Converting the existing two-way bike path on the north side of the freeway to a 4.2-mile long westbound auxiliary/truck climbing lane from Mast Boulevard to Santo Road • Extending the westbound truck climbing lane from the off-ramp to Santo Road to the onramp from Santo Road (including a retaining wall under the Santo Road Overcrossing) • Relocating the existing 4.6-mile long two-way bike path on the north side of the freeway to the south side including one 10-foot wide light weight cantilevered separated bike path on two existing bridges;
• Adding an eastbound auxiliary lane from I-15 to Santo Road; • Restriping eastbound SR 52 from 2 lanes to 3 lanes from Mast Boulevard to east of the San Diego River Bridge, eliminating the lane drop at Mast Boulevard and maintaining three eastbound through lanes to SR 125; and
• Widening the westbound on-ramp from Mast Boulevard to SR 52 to a two-lane ramp.

These improvements are based on a Caltrans “Project Study Report SR-52–Project Development Support” (PSR-PDS) funded by the applicant and sponsored by the City in coordination with other local jurisdictions and regional transportation agencies. The improvements would be carried out by Caltrans to increase capacity and improve freeway operations along SR 52. An Environmental Impact Report and Environmental Impact Statement for the improvements are underway, with an estimated completion date in December 2020. Project plans, specifications and estimates would be completed by August 2021, and a one-year construction period is anticipated between April 2022 through April 2023. The applicant has committed up to $10M toward the design, environmental compliance and implementation of these improvements.

In addition, the Development Agreement (Section 4.5.1) commits the applicant to an additional $5M toward funding SR-52 improvements, or other transportation infrastructure of significant importance intended to ease traffic congestion as determined by City Council (Section 4.5.3). In 1992, the City of Santee agreed to participate in a regional conservation planning effort led by the City of San Diego. The City of San Diego prepared a Multiple Species Conservation Program (MSCP) for the preservation and management of roughly 900 square miles in the southwestern County of San Diego, and the MSCP Plan and EIR/Environmental Impact Statement were adopted in August 1998 (City of San Diego 1998).

The 1998 MSCP outlines a comprehensive regional habitat preserve system and establishes minimum conservation and management requirements for 84 species. The City’s draft Subarea Plan identifies 22 species that occur, or are likely to occur in Santee, and for which habitats would be preserved, expanded (created) or restored.

Staff Report, September 23, 2020
Fanita Ranch

The City’s General Plan includes Conservation Element Policy 7.4 which requires the completion of a MSCP Program Subarea Plan that conserves a minimum of 2,600 acres as permanent open space for preservation of habitats and species. The largest contributor of land to the intended preserve would be the owner of the Fanita Ranch property, in step with approved development.

Project development is concentrated to the northern half of the site so that landslide prone soils are avoided to the south, hillside views from existing neighborhoods are maintained, the highest concentration of habitat for protected California Coastal Gnatcatchers is preserved, and habitat linkages are designed to accommodate animal movement in all cardinal directions. Although the City of Santee’s draft Subarea Plan has not yet been completed, development entitlements affecting sensitive resources (habitats, flora and fauna) have included requirements for on- and/or off-site preservation of permanent and managed open space, consistent with the City’s draft Subarea Plan. Since 2007, 614 acres have been added to a managed preserve system in Santee. The City of Santee’s draft Subarea Plan is comprised of six subunits. Fanita Ranch is the largest subunit (refer to Attachment 2).

D. PROJECT DESCRIPTION
The proposed development includes a new community
consisting of approximately 2,949 housing units under a preferred land use plan with school, or 3,008 units under the land use plan without school, and up to 80,000 square feet of commercial uses, in addition to parks, open space, and agriculture uses. The project development would be
clustered into three villages to preserve natural open space areas, drainages, and key wildlife corridors.

The three villages would be named according to their
design theme: Fanita Commons, Vineyard Village, and
Orchard Village. The three villages would be situated
around a centralized farm that would provide food and
function as a focal point for the community. Each village would be defined by its location, physical characteristics, and mix of housing types and uses.

Architectural designs reflect various periods of development in California, to include the hacienda, the ranch, and contemporary/modern homes and commercial/farm buildings. This mix of architectural styles and building typologies are proposed to support the vision of a high quality, sustainable community and to promote visual interest and diversity. The Specific Plan lists a variety of styles: Americana, Arts & Crafts, Early Californian, Mediterranean, Modern and Contemporary. These are illustrated in Chapter 6 of the Specific Plan and are generally distinguished by roof form, exterior wall materials (stucco, plank siding, patterned masonry), window and door trim, porches, columns, and accent features such as corbels, brackets, brick, stone, and decorative metalwork.

Staff Report, September 23, 2020
Fanita Ranch

Fanita Commons would serve as the main village and include the primary Village Center, the Village Green, the Community Park, the preferred K–8 school site, and an Active Adult neighborhood. The Vineyard and Orchard Villages would include smaller, mixed-use Village Centers that would allow for neighborhood-serving uses, office space, and other community services and amenities, as well as medium-density residential and low-density residential neighborhoods. A variety of parks would be located within walking distance of all residences, and a comprehensive system of walking and biking trails would connect the residences to key destinations throughout the project site and to existing off-site trails in surrounding park and recreation areas.

A Special Use Area would be located in the southwestern corner of the project site. Uses in this area include a solar farm, recreational vehicle storage, above-ground agriculture, and a mini-park/trail staging area. The proposed land uses and maximum residential unit yield for the project are provided in the following Table:

Preferred Land Use Plan Project Component Summary
Land Use Designation
Acreage
(ac)1
Residential
Units2
Density
Range
(residential
unit/ac)
Commercial
Square Feet
Village Center3 (VC) 36.5 435 Up to 50 60,000
Medium Density Residential
(MDR)

67.0 866 8–25 —
Low Density Residential (LDR) 240.8 1,203 4–10 —
Active Adult Residential (AA) 31.0 445 5–25 —
School (S) Overlay6 15.0 — — —
Agriculture (A) Overlay7 38.2 — — 20,000
Community Park (CP) 31.2 — — —
Neighborhood Park (NP) 30.4 — — —
Mini-Park4 (MP) 16.4 — — —
Open Space (OS) 256.0 — — —
Special Use (SU) 31.9 — — —
Habitat Preserve (HP) 1,650.4 — — —
Roadways4 193.3 — — —
Total 2,638.1 2,9496 — 80,000
Staff Report, September 23, 2020
Fanita Ranch

Village Center (VC): In total, there would be three Village Centers in the project. The Village Center land use designation would apply to approximately 36.5 acres and would allow development of approximately 435 residential units. It would
accommodate a mix of residential, commercial
(retail, service, and office), civic, and recreational
uses in a walkable mixed-use configuration with a
maximum building height of 55 feet. When uses
are mixed, they may be combined horizontally (side
by side or adjacent to one another) or vertically
(residential, office above retail, or combination of
both). Residential densities would be allowed up to
50 residential units per acre. A minimum of 60
square feet of private open space per residential
unit would be provided.

The Fanita Commons Village Center would be the largest and would serve the entire project site.

A fire station and law enforcement satellite office would be located in the Fanita Commons Village.

The fire station would be equipped and staffed to provide service to both project residents and existing Santee neighborhoods.

Two smaller Village Centers would be located in Orchard Village and Vineyard Village, which would provide for similar mixed-use residential, retail, service, office, and/or recreational needs of those individual villages. Typical allowed non-residential uses include specialty food markets, restaurants/night clubs, and business services. The location of parking would consider proximity to the Village Centers and parks and seek to promote walkability or alternative modes by providing bicycle facilities and trails to offset single-occupancy vehicle use.

Medium Density Residential (MDR): The Medium
Density Residential land use designation would
apply to approximately 67 acres of the project site
and would allow development of approximately
866 residential units. It would establish areas for
residential uses in a variety of attached, detached,
and semi-detached building typologies at densities
ranging from 8 to 25 residential units per acre. The
Medium Density Residential land use designation
would occur in Orchard Village and Vineyard
Village near parks and the Village Centers to
promote walkability. Maximum building height in
the Medium Density Residential designation would
be 45 feet. Residences may be served by public or private streets along the front, private driveways at the rear, or motor courts. A minimum of 100 square feet of private open space per attached residential unit would be provided per attached unit, and a minimum of 50 square feet of common open space would be required per unit.

Staff Report, September 23, 2020
Fanita Ranch

Low Density Residential (LDR): The Low-Density Residential land use designation would apply to approximately 240.8 acres of the project site and would allow development of approximately 1,203 residential units. It would establish areas for low-density detached residential uses in a variety of lot sizes and configurations and with densities ranging from 4 to 10 residential units per acre.

The Low-Density Residential land use
designation would be located in Orchard
Village and Vineyard Village near parks
and trailheads to promote walkability
and wellness. Building types would
include single-family detached
residences, detached cluster
residences, and community buildings
with a maximum building height of 45
feet. A minimum of 350 square feet of
private open space would be provided
for each unit.

Active Adult (AA): The Active Adult land use designation would apply to approximately 31 acres within Fanita Commons and would allow development of approximately 445 residential units. It would establish areas for age-restricted residential uses in a variety of building types with densities ranging from 5 to 25 residential units per acre and a maximum building height of 55 feet. The Active Adult land use designation would occur in the northwestern portion of Fanita Commons, near the Village Center, Farm, and Community Park. Building types would include single-family detached residences, detached cluster residences, and attached/semi-detached residences with a maximum building height of 55 feet. A minimum of 60 square feet of private open space would be provided for each unit, and a minimum of 50 square feet of common open space would be required per unit.

School Overlay (S): The School Overlay land use designation would reserve a school site for a potential K–8th grade public school or other educational uses on approximately 15 acres in Fanita Commons. If acquired by the Santee School District, the site would accommodate up to 700 students. Other uses, such as private school, charter school, child care center, nature center, and cultural and farm education facilities, would be permitted if the Santee School District does not pursue the site for a public school.

The preferred land use plan with school analyzed in the Revised EIR includes the school site.

Because the City and applicant do not control whether the site would be acquired by the Santee School District for use as a school, the underlying land use for the School Overlay site is Medium Density Residential. If the school site is not acquired for a permitted educational use within two years of the filing of the Final Map for the phase in which the site is located, the underlying Medium Density Residential land use designation would be implemented, and the maximum total number of units permitted on the project site would be increased by 59 units to 3,008 units.

Staff Report, September 23, 2020
Fanita Ranch

Agriculture Overlay (A): The Agriculture Overlay land use designation would apply to approximately 38.2 acres of the project site and establish areas for a farm and other agricultural uses. The 27.3-acre farm in Fanita Commons would be the community focal point of the project. Continuous education and learning experiences linked to a working farm, its orchards and vineyards and “AgMeander” trail are proposed.

The working farm would also be open to the
public-at-large. In addition to vegetables and
community gardens, the farm would include
small-scale animal husbandry. Maximum
building height in the Agriculture Overlay would
be 35 feet. Farm equipment operations would
be limited to the hours of 7:00 a.m. to 7:00 p.m.
every day.

A community-supported agriculture program,
where the consumer receives produce on a
regular basis, would be offered. Food grown on the Farm would also be distributed to local schools, restaurants, and other institutional facilities, such as congregate care and assisted living facilities.

The Farm would allow for a range of community activities including farm-to-table events, community harvests, weddings, and other celebrations and festivals. Farm-based education would be provided as tours, volunteer opportunities, camps, and workshops related to gardening and farmer training, nutrition, cooking, herbal medicines, and home preservation of food.

Temporary special events in the Agriculture Overlay areas would be subject to the applicable criteria and conditions of the Santee Municipal Code, Section 13.06.070. Special and temporary event attendance would be limited to a maximum of 300 attendees. Keeping, raising, and boarding of large and small four-legged animals, as allowed under the Santee Municipal Code, would be permitted. The number of four-legged animals shall not exceed five animals per gross acre of the Agriculture Overlay areas. Keeping, raising and boarding of fowl such as chickens, roosters, ducks, geese and other similar fowl would also be permitted.

The underlying land use for the Agriculture Overlay planning area is Open Space. This would ensure that no residential or commercial units would be built in these areas. The underlying Open Space land use designation may be implemented in the Agriculture Overlay planning area if uses permitted within the Agriculture Overlay planning area become infeasible (e.g., the farm fails). Caretaker units (a maximum of six residential units) and commercial accessory uses are only permitted when the Agriculture Overlay is applied and would not be allowed when the Open Space land use is in effect.

Staff Report, September 23, 2020
Fanita Ranch

Parks (CP, NP, MP): The Park land use designation
would apply to approximately 78 acres of the site. An
approximately 31.2-acre Community Park (CP), 8
Neighborhood Parks (NP), and 31 Mini-Parks (MP)
would be distributed throughout the development to
provide active and passive recreational opportunities
and gathering spaces within walking distance of all
residences.

Permitted building types would be limited to
community buildings including swimming pools, sport
courts, and restrooms. The Community Park and one
Neighborhood Park located in Fanita Commons (NP-8) would be owned and maintained by the City of Santee, and the other parks would be owned and maintained by a Master Homeowner’s Association (HOA). Some of the Mini-Park designated areas would also provide trail access and serve as the key access points to the trail system. All parks contributing to the total parkland requirement would be publicly accessible and ensured by public use easements shown on the Final Map.

Open Space (OS): The Open Space land use designation would apply to approximately 256 acres of open space area outside of the Habitat Preserve. The Open Space designation would include brush management areas, also referred
to as Fuel Modification Zones (FMZs) at the
edge of development, slopes adjacent to
streets and within the villages, trailheads, water
quality basins, land for water tanks and pump
stations that would be dedicated to and
maintained by Padre Dam Municipal Water
District, and two riparian areas in Fanita
Commons. Two bridges over the riparian areas
are proposed. Open Space areas and bridges
would be owned, maintained and managed by
the HOA.

Special Use Area (SU): The Special Use land use designation would apply to an approximately 31.9-acre site located in the southwestern corner of the project site east of Fanita Parkway and west of an existing PDMWD Carlton Hills water reservoir. Permitted uses for the Special Use Area are limited to water quality basins, a road extension at the current terminus of Carlton Hills Boulevard, a solar farm, a recreational vehicle (RV) and boat storage facility, and a non-irrigated Mini-Park with trailhead. Due to underlying soil conditions, no mass grading or introduction of water would be allowed in the Special Use area.

Staff Report, September 23, 2020
Fanita Ranch

Habitat Preserve (HP): A Preserve Management Plan would apply to those open space areas outside the limits of development and would include approximately 1,650.4 acres representing about 63 percent of the total project site. It would include areas undisturbed from development and specific revegetated slopes at the edge of the planned development area. Revegetated slopes would consist of native plants that blend into the existing natural landscape in conformance with a habitat restoration plan. The intent of this land use is to designate areas that would ultimately be included in City’s MSCP Subarea Plan, fulfilling the City’s commitment to participate in the regional MSCP. The project applicant has prepared a Preserve Management Plan that directs and provides funding mechanisms for the long-term management and monitoring of the biological resources in the Habitat Preserve, with or without the approval of the City’s Subarea Plan by the Wildlife Agencies. The Habitat Preserve would be selectively accessible through a managed and maintained trails system. A conservation easement would be dedicated on the Final Map that reflects the Habitat Preserve area.

Roadways: The project would improve and construct new segments of two of the Santee General Plan Mobility Element streets: Fanita Parkway and Cuyamaca Street. Improvements would also occur at the terminus of Carlton Hills Boulevard and at existing dead-end streets that terminate at the project site boundary where drainage facilities, erosion control measures and sidewalks are deemed necessary to access the perimeter trail. Refer to Attachment 3 for more information on the design of the street network.

During new road construction, or when trenching occurs within existing roadways, there is an opportunity to install conduit (pipes through which fiber optic cable may later be pulled through). This approach reduces the cost associated with trenching and resurfacing roads at a later date. As part of the project (as conditioned) empty conduit will be included in projectrelated roadwork to accommodate future communication improvements between the new Fire Station and the two parks that will be owned by the City (Community Park CP#1 and Neighborhood Park #8). Additionally, all new traffic signals required for the project will be connected with a fiber optic interconnect system at the closest existing connection point to advance the deployment of adaptive “smart signals” along major arterials in the City.

It will be necessary to acquire land from property owners with properties located between the existing terminus of Cuyamaca Street and the project limits (approximately 30 parcels). The City has established procedures necessary to ensure due process and orderly acquisition of off-site public right of way and City easements from private developers. Legislative Policy Memorandum, LPM-91-1 has established these requirements and procedures.

Project Phasing: The conceptual phasing plan for the project indicates four phases. The public facilities would be provided commensurate with development and public services would be provided prior to the time of need. The conceptual phases for the project include the following:
• Phase 1: Fanita Commons and the easterly portion of Orchard Village, off-site and on-site improvements to Fanita Parkway and Cuyamaca Street, sewer infrastructure through the Staff Report, September 23, 2020
Fanita Ranch

Phase 2 area, and water infrastructure in the Special Use area. Residential units in this phase total 1,050.
• Phase 2: Westerly portion of Orchard Village and dead-end street improvements.

Residential units in this Phase total 573.
• Phase 3: Connections to and construction of the southerly half of Vineyard Village and water infrastructure through the Phase 4 area. Residential units in this Phase total 512. • Phase 4: Northerly half of Vineyard Village. Residential units in this Phase total 814.

These proposed phases are conceptual and non-sequential. Phases may occur simultaneously. Phases may overlap or vary depending on market conditions. Each phase is estimated to take approximately two to four years to complete. Construction is anticipated to begin in summer 2021 with a buildout over a 10- to 15-year period. The Special Use Area is not tied to the development phasing described previously and may be developed at any time during project buildout.

Upon buildout of the four phases of development, implementation of the land use plan with school would add approximately 7,974 residents and 450 employees and the land use plan without school would add approximately 8,145 residents and 200 employees.

E. GENERAL PLAN CONSISTENCY / ENVIRONMENTAL ANALYSIS
This section of the Staff Report summarizes the project’s consistency with the overarching intent of the General Plan to maximize the opportunity for a master-planned community on Fanita Ranch and the environmental analysis for the project in the Revised EIR. The project includes a variety of residential types, supporting commercial uses, parks, open space and “working farm” uses all clustered in three villages.

General Plan Conformance:

The 2020 Santee General Plan Land Use Element identifies Fanita Ranch as an Area for Special Study and includes Guiding Principles for the comprehensive development of Fanita Ranch. Since the General Plan’s adoption in 2003, the housing, office, and retail markets have evolved. The project is responsive to the ever-increasing demand for housing to meet population growth, while also preserving natural resources.

Unlike the predominant 1970 tract home subdivisions comprised of similar building forms and lot placement, the project includes a mix of residential neighborhoods within clustered villages. A variety of residential opportunities include live/work units, multiple-family, singlefamily, congregate care and age-restricted development. The clustered village design offers a unique opportunity to provide an interconnected recreation and open space network that includes active and passive parks, trails, bikeways, recreation facilities and an approximately 1,650-acre, managed, Habitat Preserve.

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The project results in a master-planned community that promotes and encourages conservation of resources; facilitates the creation of an attractive and harmonious community; attains a desirable mix of residential and recreational opportunities; and ensures the provision of adequate and essential public services and facilities. The project will provide needed housing and result in the City meeting its housing target for above-moderate income housing (Fifth Cycle Housing Element) as required by the State Department of Housing and Community Development.

The Resolution prepared for the General Plan Amendment to change the Fanita Ranch property from a “Planned Development District” designation to a “Specific Plan District” designation includes an Exhibit describing the project’s conformance with the Guiding Principles for Fanita Ranch.

An important requirement of the project is that it provide a high-end residential community with unique design characteristics and amenities. The following are key amenities of the project:

Housing: Provides a variety of housing types attractive to different households.

Open Space: Contributes 1,650 acres of biological habitat toward Santee’s open space preserve, representing the single largest dedication of open space in the City’s history.

Parks: Adds approximately 78 acres of parkland, of which 35 acres are comprised of two publicly-owned parks and 43 acres are comprised of private parks with full public access.

Community Center: Provides a 7,000-10,000 square foot public building within the Community Park.

Trails: Provides City residents with new public recreational opportunities, including use of a trail network (currently the site is privately owned and gated).

Farm: Includes a publicly accessible working farm.

Fire Station: Provides a 10,000 square-foot, turn-key fire station to provide service to both project residents and existing Santee neighborhoods. The project includes one Type I fire engine and one Type III wildland fire engine added to the City’s fire apparatus resources. It also includes full staffing, twenty-four hours a day, seven days a week, with three captains, three engineers and three firefighter/paramedics.

Fire Protection: Provides a state-of-the art Fire Protection Plan that incorporates the City’s fire code, amended to be more restrictive than the state code, and includes highly specialized brush management zones adjacent to structures and roadways.

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Fees: Contributes approximately $31 million in fees, including Regional Transportation Congestion Improvement Program (RTCIP) Mitigation fees pursuant to project conditions:

Traffic Impact Fee $ 9.6 million
Traffic Signal Fee $ 1.0 million
Public Facilities Fee $12.8 million
RTCIP Fee $ 7.6 million
Economic Benefit: A Fiscal Impact Analysis for the project has been completed by Development Planning & Financing Group, Inc. This analysis includes the projection of all ongoing revenues (property tax, sales tax, property tax in lieu, etc.) generated from the project and all ongoing costs (police and fire protection, street maintenance, park and landscape maintenance, etc.) incurred as a result of the project. The analysis determined that the project would generate an annual $1.4 million net positive revenue stream to the City upon build-out of the project.

Development Agreement:

A Development Agreement is proposed for City Council consideration and introduction for first reading (Ordinance). The key additional public benefits to be provided by the applicant in the Development Agreement include:

1. Design/construct two public parks and maintain such parks for two years at applicant’s expense.

2. Public access easements for neighborhood parks and trail network, maintained by the applicant/future HOA in perpetuity.

3. Advancement of funds for preparation and consideration of the MSCP Subarea Plan for adoption.

4. Open space dedication and habitat management in perpetuity by the applicant.

5. Funding in the amount of $2.6 million to the City for the construction of affordable housing.

6. Funding in the amount of $2.6 million to BE USED BY THE City to fund an off-site infrastructure improvement project identified in the Capital Improvement Program.

7. Maintenance of landscaped areas in medians, parkways and outer areas along Cuyamaca Street and Fanita Parkway by the applicant for five years following City acceptance of facilities.

8. Funding in the amount of $10 million toward SR 52 improvements.

9. Funding in the amount of $5 million for transportation infrastructure of significant importance intended to ease traffic congestion.

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Park Facilities:

Santee Municipal Code (SMC) Chapter 12.40, Park Lands Dedication establishes the provisions for dedication of land, payment of an in-lieu fee or a combination of both for the purpose of providing park and recreation facilities to serve future residents of a subdivision development. SMC Section 12.40.070 requires the amount of land to be dedicated based on the average occupancy rate per dwelling type and the ratio of dedication equivalent to 5 acres per 1,000 population, according to the following: single-family dwellings at 740.5 square feet per unit and multi-family dwellings at 675.2 square feet per unit. Based upon the proposed 1,203 single-family homes and 1,746 multi-family homes, 47.6 acres of developed parks and recreation facilities must be provided at Fanita Ranch to satisfy the parkland dedication requirement of 5 acres per 1,000 population pursuant to SMC Section 12.40.070.

Per the public park credit provisions set forth in SMC Section 12.40.110, developed park land dedicated to, and maintained by, the City of Santee would represent 100 percent park credit.

Developed parkland maintained by an HOA and trails will receive up to 50 percent credit per the private park credit provisions in SMC Section 12.40.100. Roughly 78 acres of public and private park lands for active and passive recreation, and 4.5 acres of trails, consisting of perimeter trails and the Stowe Trail connections, are planned within Fanita Ranch, for a total of 82.5 acres. Of the total 82.5 acres, 52.4 acres are eligible and available for park land dedication credit, which satisfies the SMC Chapter 12.40, Park Lands Dedication requirement.

Refer to Attachment 4 for location of parks within the project.

The park plan provides new recreational
opportunities to existing and future residents
with the development of a new Community Park
that will include two multi-purpose ballfields,
sport courts, restrooms, parking, tot lots, open
play areas, passive picnicking areas, and may
include an aquatic element, community
gathering plaza and dog park. In addition, a
7,000 to 10,000 square-foot community center
will provide multi-purpose, flexible spaces to
support recreation, learning, arts and crafts,
social and service functions. The project includes approximately 42.6 acres of Homeowner’s Association Neighborhood and Mini-Parks within the residential villages in addition to the City neighborhood and community park, all of which are within walking distance to future residents and accessible to the Santee public. The project, as proposed, provides adequate recreation amenities and eliminates the requirement for park-in-lieu fees.

Traffic/Circulation:

Given the scale of the project, development would occur over several years, with buildout occurring over a 10- to 15-year period. In order to provide for a worst-case analysis, impacts were measured assuming construction of the entire project at once. Potential project impacts were then tied to a unit occupancy number to identify the point in time in which Staff Report, September 23, 2020
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implementation of mitigation measures would be required. These are found in the Mitigation, Monitoring, and Reporting Program, attached to the Revised EIR. These mitigation measures include, but are not limited to, the following local road improvements. • Traffic signal installations at Ganley Road and Lake Canyon Road intersections with Fanita Parkway, each with southbound and northbound left turn protected phasing. • Traffic signal installations at Beck Drive, El Nopal, Woodglen Vista and Princess Joann intersections at Cuyamaca Street.
• Widening the intersection of Mast Boulevard and Cuyamaca Street with additional lane geometry (striping) to improve flow of through traffic and turning traffic. • Widening the intersection of Mast Boulevard and Fanita Parkway with additional lane geometry to improve flow of through traffic and turning traffic. • Installation of an Adaptive Traffic Signal Control system along Mission Gorge Road between Fanita Drive and Town Center Parkway. This is a traffic management strategy in which traffic signal timing changes, or adapts, based on actual traffic demand. • Widening the intersection at Mission Gorge Road and Cuyamaca Street to provide a dedicated northbound right turn lane to Mission Gorge Road from Cuyamaca Street. • A fair share contribution toward roadway striping improvements at the intersection of West Hills Parkway and Mission Gorge Road.
• Street widening, bike lanes, landscaping and median improvements along Fanita Parkway and Cuyamaca Street.

Attachment 3 also includes an aerial showing the location of circulation improvements by intersection and roadway segment.

State Route 52: The project is conditioned to preclude occupancy of the first equivalent dwelling unit until the SR 52 improvements described above are completed. As discussed in the Revised EIR, the applicant has commenced coordination with Caltrans for improvements to mitigate potential project impacts, executed agreements and committed funds for such purposes. For impacts to SR-52, the applicant has privately funded a Caltrans PSR-PDS for the evaluation of potential improvements to the SR-52 corridor by Caltrans intended to relieve congestion.

State Route 67: The Revised EIR includes a mitigation measure to install a traffic signal at the Riverford Road/ SR 67 Southbound Ramps intersection. Because this intersection is located within the County of San Diego’s and Caltrans’ jurisdictions, the City is without jurisdiction to ensure the construction of the recommended improvements. Nevertheless, City staff and the applicant have been actively coordinating with County staff regarding implementation of mitigation measures outside of Santee’s jurisdiction.

The project would generate new vehicular trips to the local and regional network. The trip generation rates used for the proposed land uses are based on corresponding land uses Staff Report, September 23, 2020
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listed in the (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002, by SANDAG. Additional rates were sourced to the “Institute of Transportation Engineers” (ITE) Trip Generation Manual where noted. Table 4.16-10 in the Revised EIR identifies the trip generation rates and calculations for the project land uses (refer to Attachment 5 for Table 4.16-10). Applying the rates listed in Table 4.16-10, the following gross trip generation amounts were calculated:
• The residential portion of the project is calculated to generate a gross total of 24,490 ADT with 1,914 trips (499 inbound/1,415 outbound) during the AM peak hour and 2,393 trips (1,663 inbound/730 outbound) during the PM peak hour.
• The non-residential development, including commercial, school, and parks, is calculated to generate a gross total of 6,723 ADT with 1,284 trips (689 inbound/595 outbound) during the AM peak hour and 563 trips (261/302 outbound) during the PM peak hour. • The entire project is calculated to generate a gross total of 31,213 ADT with 3,198 trips (1,188 inbound/2,010 outbound) during the AM peak hour and 2,956 trips (1,924 inbound/1,032 outbound) during the PM peak hour.

Two categories of trip reduction were applied:
• Pass-by trip reduction: these are trips that people take as part of a primary trip, such as a stop at the grocery store on the way home (2,500 trips); • Internal trip capture: these are trips that occur within the Fanita Ranch area, such as shopping at the local stores and traveling to the school in Fanita Ranch, thereby not adding new trips to the City’s roadway network. A deduction against a project’s primary trips may be taken to account for the share of such trips. The project ultimately applied an “internal capture” rate of 8.5 percent, calculated based on SANDAG’s mixed-use reduction rate of 8.5 percent.

Net external trips were determined by subtracting the pass-by and internal trips from the primary trips. As shown in Table 4.16-10, the project is estimated to generate a total of 26,272 net external daily trips with 2,472 trips in the AM peak hour (843 inbound and 1,629 outbound) and 2,509 trips in the PM peak hour (1,670 inbound and 839 outbound). The total external trip generation for the land use plan without school would increase from a total 26,272 ADT under the preferred land use plan with school to 26,445 ADT for a net difference in 173 ADT.

Construction traffic over the build-out period was also considered. Staging for all equipment and construction personnel would occur on the project site in designated areas. To minimize the impact of haul trucks on the off-site street network and to avoid the need to import or export dirt, grading for the project has been designed to balance cut and fill materials. Haul trucks used for site preparation and grading activities would operate on site only and not result in new trips to the City roadway network; therefore, they are not included in the trip generation calculations.

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There would be days when worker trips and vendor trips would access the site each day.

Based on the anticipated construction schedule, a maximum of 1,411 daily trips (1,099 daily worker trips, 312 daily vendor trips, 0 haul trips) is estimated to occur. The temporary increase in construction traffic would have the potential to result in a significant impact if not properly managed; implementation of Mitigation Measure TRA-1 would reduce temporary construction impacts to below a level of significance.

Starting July 1, 2020, automobile delay, described by Level of Service (LOS) or similar measure of traffic congestion, is no longer considered a metric of impact under CEQA. Under CEQA, vehicle miles traveled (VMT) is now the appropriate measure for transportation impacts. The VMT methodology assesses the amount and distance of automobile travel associated with a project, while the focus of LOS is on traffic flow/vehicle delay. Because the Draft Revised EIR was circulated for review before July 1, 2020, a VMT analysis was not required per CEQA. Nevertheless, the Traffic Impact Analysis (TIA) included a VMT analysis as part of the project review process.

The change to VMT does not preclude application of the City's General Plan to projects under authority outside of CEQA. Policy 2.1 of the City's Mobility Element of the General Plan still addresses targets for automobile LOS related to street segments and intersections throughout the City's circulation network while also maintaining or improving the effectiveness of the non‐ automotive components of the circulation system (i.e. pedestrians, bicyclists, and public transit). LOS analysis may result in local roadway improvements that widen roads, install traffic signals, and changes in road striping. As such, among the conditions of approval for Fanita Ranch are requirements for fair share contributions toward improvements at Mission Gorge Road at Cuyamaca Street and West Hills Parkway, improvements to the Ganley Road/Fanita Parkway intersection, and traffic signal installations along Fanita Parkway and Cuyamaca Street.

The City considers LOS D the minimum LOS. Therefore, the TIA considers LOS E or F conditions as unacceptable. Impacts are identified at locations where LOS E or F is calculated. The TIA identifies LOS E as a significant impact.

Table 4.16-4 of the Revised EIR indicates the LOS E capacity (the volume where the road degrades from LOS E to LOS F) consistent with City standards. An analysis of Fanita Parkway, Mast Boulevard, and Cuyamaca Street was conducted with the addition of the 26,272 project ADT, and with mitigation, it was determined that the roadways can accommodate those trips.

With respect to traffic signals and how they operate to improve LOS (flow), the Revised EIR Section 4.16 discusses the installation of Adaptive Traffic Signal Control, or “smart” signals, to handle additional traffic by communicating with each other and dynamically adjusting signal timings, memorizing traffic patterns, improving traffic flow, and reducing vehicle stops. This system is memorialized under Mitigation Measure TRA-16, which would require such a system on Mission Gorge Road between Fanita Drive and Town Center Parkway.

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The Governor’s Office of Planning and Research (OPR) has issued general guidelines on the implementation of VMT as a metric of transportation impact. In the San Diego area the Institute of Transportation Engineers (ITE) has developed local guidelines based on the OPR guidelines. The ITE Guidelines were used for the evaluation of VMT impact. Per OPR and ITE Guidelines the metric for transportation impact for residential projects was measured in VMT per capita and compared to a baseline (Citywide) VMT per capita.

Citywide VMT per capita was calculated to be 22.4 miles. Both the OPR and ITE Guidelines use 85 percent of existing Citywide per capita VMT as the threshold for the identification of a significant transportation impact. Based on this, the threshold for significant impact is 19.04 VMT per capita. The project’s VMT per capita was calculated to be 25.6 miles at project completion and 23.45 miles at year 2035 for the “School Scenario”. Under both scenarios, the project’s VMT is higher than the threshold, and therefore the Revised EIR identifies a “Significant Impact”.

To reduce the VMT impact, the project proposes
Transportation Demand Management (TDM) measures.

The most commonly applied tool to quantitatively reduce VMT is the California Air Pollution Control Officers
Association’s (CAPCOA) Quantifying Greenhouse Gas
Mitigation Measures, August 2010 handbook. The project
can achieve a 13.7% reduction in VMT as shown in the
Revised EIR by applying several feasible VMT reduction
measures, coming close to the 15% reduction target. The analysis concluded that, even with TDM Measures to
reduce VMT, the project would not reduce per capita
vehicle miles traveled to below 85% of the existing
Citywide VMT per capita. The project is conditioned to
implement the Traffic Demand Management Plan, which
includes the following components: pedestrian network,
traffic calming measures, a neighborhood electric vehicle network, bike lanes, bike parking, car-sharing and ride sharing programs and a school pool program.

Fire Protection/Public Safety:

Roughly 70% of the County of San Diego is designated as very high fire hazard severity zone (VHFHSZ), and the site is within this zone. Areas in the County that have not received this designation are primarily urbanized areas. A VHFHSZ designation does not preclude development, but indicates that additional measures are required to address the increased likelihood of wildfire. Therefore, as required by the adopted Fire Code, as amended by City of Santee Ordinance 570, a Fire Protection Plan (FPP) is included with the project. The FPP’s purpose is to evaluate the potential impacts resulting from wildland fire hazards and to identify project design features necessary to address those risks consistent with City and industry thresholds. The FPP incorporates a multi-tiered approach to fire prevention and suppression and protection of structures and life. The applicant is required to construct, equip, and staff a Staff Report, September 23, 2020
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fire station on the project site. Refer to Attachment 6 for a summary of the FPP requirements.

The project includes passive protections that separate the developed areas from the adjacent open space. The customized fuel modification zones minimize the potential that an accidental fire on the site would escape into the habitat preserve by creating low fuel, irrigated and thinned buffer areas. Maintenance of these zones would be performed on an ongoing basis and inspected by a third-party inspector twice annually to confirm maintenance in conformance with the FPP, at the expense of the HOA. The provision for a 100-foot FMZ along the project border where existing homes occur is another line of defense that would keep flames set back from these existing homes. However, with or without the project, the potential for airborne embers currently exists.

The landscape around Fanita Ranch would no longer consist of large, contiguous, fire-prone shrublands. While the fuels in the open space would have the potential to burn (especially under hot and dry Santa Ana wind conditions), the irrigated, maintained landscape around the proposed Fanita Ranch development would retard the spread and intensity of wildfires as they would burn with reduced intensity and in a spotty manner. There would not be a uniform fire front as would be expected in an uninterrupted fuel bed.

This project’s Wildland Fire Evacuation Plan incorporates concepts and protocols practiced throughout San Diego County for evacuation. The San Diego County Evacuation Annex (County of San Diego 2014) follows basic protocols set forth in the County’s Operation Area EOP and the California Master Mutual Aid Agreement, which dictate who is responsible for an evacuation effort and how regional resources will be requested and coordinated. Evacuation during a wildfire is not necessarily directed by the fire agency (i.e. Santee Fire Department), except in specific areas where fire personnel may enact evacuations on scene. The San Diego County Sheriff’s Department in coordination with other law enforcement agencies, as needed, is the lead agency for evacuations in Santee. Agencies work closely within the unified Incident Command (IC) system, with the County OES, and responding fire department personnel who assess fire behavior and spread, which should ultimately guide evacuation decisions.

One of the primary methods for successful evacuation is “downstream” roadway intersection control. By controlling intersections in the direction traffic is being moved, evacuation managers can move the highest risk areas and quickly adjust to changing fire conditions. The ability of ignition resistant master planned communities like the project to temporarily refuge residents on site, in their protected homes, or at designated buildings (school, Village Center) provides needed flexibility and optionality that is not available in older, more fire vulnerable communities.

Additionally, evacuation and early warning systems are now in place. San Diego County offers a robust emergency notification system. The system, operated by the Office of Emergency Services, is known as Alert San Diego, and is capable of notifying tens of thousands of numbers in a very short timeframe of an impending emergency. The system has the capacity to push out emergency notices to both land lines and cell phones. In both instances, residents must “opt-in” the program by registering individual phones. In addition, there are many local Staff Report, September 23, 2020
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news sources including television, radio, public broadcast, and social media that are used to reach affected citizens.

Fanita Ranch, the Santee Fire Department and San Diego County all incorporate the “Ready, Set, Go!” evacuation protocol. Part of this protocol is understanding when fire threat is at its peak. Red Flag Warnings declared by the National Weather Service provide emergency responders and residents with a warning that they should be prepared to mobilize if a wildfire develops.

The focus of the “Ready, Set, Go!” program is on
public awareness and preparedness, especially for
those living in the wildland-urban interface (WUI)
areas. The program is designed to incorporate the
local fire protection agency as part of the training
and education process in order to ensure that
evacuation preparedness information is
disseminated to people subject to the potential
impact from a wildfire. There are three components
to the program:
“READY” – Preparing for the Fire Threat: Take personal responsibility and prepare long before the threat of a wildfire so you and your home are ready when a wildfire occurs. Create defensible space by clearing brush away from your home as detailed in the Fanita Ranch FPP (Dudek 2020). Use only fire-resistant landscaping and maintain the ignition resistance of your home. Assemble emergency supplies and belongings in a safe spot. Confirm you are registered for Reverse 911, AlertSanDiego, and DSFPD alert system. Make sure all residents residing within the home understand the plan, procedures and escape routes. “SET” – Situational Awareness When a Fire Starts: If a wildfire occurs and there is potential for it to threaten Fanita Ranch, pack your vehicle with your emergency items. Stay aware of the latest news from local media and your local fire department for updated information on the fire. If you are uncomfortable, leave the area.
“GO!” – Leave Early! Following your Action Plan provides you with knowledge of the situation and how you will approach evacuation. Leaving early, well before a wildfire is threatening your community, provides you with the least delay and results in a situation where, if a majority of neighbors also leave early, firefighters are now able to better maneuver, protect and defend structures, evacuate other residents who couldn’t leave early, and focus on citizen safety.

During an emergency evacuation from the project site, the primary and secondary roadways would be capable of providing resident egress while responding emergency vehicles are traveling inbound. In addition, bicycle lanes in both directions would accommodate emergency lanes for first responders and evacuation lanes for project occupants. Because the roadways are designed to meet or exceed the 2019 California Fire Code such as unobstructed travel lanes and extremely wide roadside fuel modification zones, potential conflicts that could reduce roadway efficiency would be minimized, allowing for smooth evacuations.

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Habitat Preserve:

The project preserves approximately 63%
(approximately 1,650 acres) of the site in a
permanent Habitat Preserve and an
additional 256 acres of open space. The
Preserve would be managed and protected
through a permanently funded Preserve
Management Plan administered by a
Preserve Manager.

The Habitat Preserve furthers the City’s
goal to establish 2,600 acres of
permanently preserved open space for the
preservation of habitats and species.

Specifically, with the addition of 1,650 acres to the existing 614 acres in the managed preserve system, the City would achieve 87% of this target, representing 2,264 acres. The contribution of 1,650 acres also furthers the biological goals and objectives for broader conservation of natural communities, ecological functions, habitat connectivity and local biodiversity set forth in the MSCP.

The project proposes to close and revegetate a large proportion of the existing trails within the Habitat Preserve and realign existing trails to avoid sensitive resources within the Habitat Preserve. Where these realignments are made, the old trails would be closed and restored.

Without the implementation of the project, indirect impacts to biological resources would continue to occur due to unauthorized motorized and non-motorized vehicles using the site, causing degradation of the natural habitat and sensitive species. The project includes planting with certain plant species (e.g., cacti) (Mitigation Measure BIO-9), fencing (Mitigation Measure BIO-1 and BIO-20), CC&Rs regarding wildlife, and disclosure and signage (Mitigation Measure BIO-20) to deter human intrusion into open space areas.

The primary duty of the Preserve Manager would be to manage and monitor the Habitat Preserve pursuant to the approved Preserve Management Plan. The Preserve Manager would also report periodically to the City-appointed Santee MSCP Subarea Plan Coordinator and/or Preserve Steward regarding the status of the Habitat Preserve, progress of active management actions, and issues that need addressing. The City will be required to oversee implementation of the Preserve Management Plan through the review of annual reports and onsite inspections, and to coordinate with regional information gathering efforts. The City will support enforcement needs recommended by the Preserve Manager through appropriate law enforcement actions
Public outreach and education are critical for ensuring successful management and public support. The Preserve Manager would initiate and sustain community outreach and educational programs that are designed to increase community awareness of the preserve, its biological resources, and community value. The Preserve Manager would provide educational brochures, kiosks, interpretive centers, and signs to educate the public about the Habitat Staff Report, September 23, 2020
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Preserve’s conservation goals, biological/physical resources, and appropriate uses on and adjacent to the Habitat Preserve, including appropriate trail user etiquette.

Additionally, per the Preserve Management Plan, the HOA would provide all member homeowners information, prepared by the Preserve Manager, about the Habitat Preserve; the importance of protecting its natural resources; the rights and responsibilities of HOA members in using and protecting the Habitat Preserve (i.e., compatible uses and prohibited activities); self-policing and monitoring; and who to contact if HOA members observe prohibited activities in the Habitat Preserve, either by other HOA members or by the general public. In addition, the HOA may establish voluntary member patrols and implement other activities that promote protection and management of the Habitat Preserve by investing residents in the care of the Habitat Preserve.

Consistency with the City’s Draft MSCP Subarea Plan:

Although the draft Santee MSCP Subarea Plan has not yet been approved or permitted, it is still used as the guidance document for projects occurring in the City. Therefore, the Revised EIR is also consistent with the draft Santee MSCP Subarea Plan, which would serve as a Habitat Conservation Plan (HCP) pursuant to Section 10(a)(1)(B) of FESA and as a Natural Communities Conservation Plan (NCCP) pursuant to the California NCCP Act of 1991.

However, because the draft Santee MSCP Subarea Plan is still a draft and is not complete, the EIR cannot rely upon the protections of the plan.

If the draft Santee MSCP Subarea Plan is not approved
before implementation of the project, the project would seek take authorization through Section 7 of the federal Endangered Species Act or an individual Section 10
permit. Take authorization is separate from the CEQA
review process and is one of the subsequent regulatory
approvals needed for the project, as identified in the
Revised EIR. The Revised EIR adequately identifies the
project impacts to biological resources in Section 4.3, Biological Resources, and recommends mitigation
measures that would reduce impacts to less than
significant. With implementation of these required measures, whether through the City’s Subarea Plan or separate permitting process, impacts would be reduced to less than significant. The project’s mitigation does not depend on the completion of the draft Santee MSCP Subarea Plan.

The project site has been subject to environmental review and land use planning since City incorporation, and there are many factors that enter into development planning of a project.

Biological goals include preserving one of the largest coastal California gnatcatcher populations in the region (an NCCP focal species), preserving special-status plant species, and providing suitable habitat for the Quino checkerspot and Hermes copper butterflies within the proposed Habitat Preserve. The southern portion of the project site was removed as an impact area from the previous Barratt American (2007) design and included within the Habitat Staff Report, September 23, 2020
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Preserve, creating a 900-acre habitat block that reduces impacts to occupied habitat for coastal California gnatcatcher and other species that use coastal sage scrub. Additionally, having a 900-acre block of habitat would be self-sustaining for the vast majority of species using, or potentially using the area.

Non-biological factors were also considered in determining the location of the Villages and Special Use Area. Some of the soils on the proposed southern 900-acre habitat block are landslide prone; adjacent neighbors objected to development immediately adjacent to their homes. While competing development considerations were considered in planning the project, the Revised EIR is based upon a Biological Resources Technical Report prepared by expert biologists who extensively analyzed the project. The biologists concluded that the project, with mitigation, would have less than significant impacts across all potential biological resource impact areas.

Sustainable Santee Plan/Greenhouse Gases Emissions:

The City developed a Sustainable Santee Plan that provides greenhouse gas (GHG) emissions reduction goals and strategies focused on reducing resource consumption, improving alternative modes of transportation, and reducing overall emissions throughout the City. The Sustainable Santee Plan was adopted in January 2020. The Sustainable Santee Plan presents the City’s community-wide GHG inventories for the years 2005, 2008, 2012, and 2013 and municipal GHG inventories for the years 2005 and 2013.

The “Business as Usual” (BAU) and adjusted BAU forecasts are presented for the years 2020, 2030, and 2035. An interim goal consistent with SB 32, which is to reduce emissions to 40 percent below 2005 levels, was created for 2030. A longer-term goal was established for 2035, which is to reduce emissions to 49 percent below 2005 levels. The interim and longerterm goals will put the City on a path toward the state’s long-term goal to achieve net carbon neutrality statewide by 2045. The Sustainable Santee Plan also identifies GHG reduction strategies to help the City achieve its long-term GHG reduction targets.

With implementation of the mitigation measures recommended in Section 4.7.5, the Revised EIR determined that “per capita emissions from the preferred land use plan with school would be 1.51 MT CO2e . . ., and per capita emissions from the land use plan without school would be

1.62 MT CO2e.” These levels are below the 1.77 MT CO2e threshold for either land use plan; therefore, impacts to GHG emissions were found to be mitigated to a less than significant level.

In general terms, the project proposes the reduction of natural gas consumption through construction of “all-electric” homes, installation of both fixed-position and rooftop photovoltaic panels; installation of 1,203 electric vehicle supply equipment (EVSE) in each garage provided for “Low Density Residential”, 354 EVSE in the parking areas of the remaining residential units and 15 EVSE within the commercial parking lots; places a limit on the number of wood-burning stoves and fireplaces to six (6) in the Village community areas; utilization of purified water to meet project needs; planting of at least 26,705 trees throughout the project site to maximize “carbon storage” and provide shade; utilization of traffic roundabouts on site that eliminate traffic signal operations and vehicular idling; and establishment of 63% of the site to permanent open space.

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The project's energy demand is 12.147 megawatts (MW) for the preferred land use plan with school and 12.083 MW for the land use plan without school. Mitigation Measure GHG-1 requires that the project “provide on-site [photovoltaic] renewable energy generation with a total design capacity of at least 12.147 megawatts (MV) for the Preferred Land Use Plan with School, or 12.083 MW for the Land Use Plan without School at full buildout.” As such, the onsite solar facilities will provide 100 percent of the project's energy demand. An additional provision for battery storage is a project condition of approval.

In brief, Revised EIR Table 4.7-13 demonstrates consistency with the GHG reduction strategies from the Sustainable Santee Plan with implementation of mitigation. As shown in Table 4.7-13, with implementation of mitigation, the project would be consistent with the applicable GHG reduction strategies in the Sustainable Santee Plan, and this impact would be mitigated to a less than significant level.

Noise:

Section 8.1 of the City’s General Plan Noise
Element, Local Regulations, establishes noise
levels up to 65 dBA CNEL as normally
compatible with noise-sensitive development.

The Noise Element also establishes a CEQA
threshold that a significant impact would occur
if the project would cause noise levels to
exceed the City’s noise compatibility
guidelines. Where noise levels exceed the
compatible noise level without project
implementation, an increase in noise level of 3
dBA or more, directly attributable the project,
would be significant. Implementation of the
project will increase vehicular transportation
noise, as well as project noise and vibration
associated with construction. The project is not
required to mitigate the ambient (existing)
noise.

Noise associated with an increase in the number of vehicles on roads is typically reduced through the construction of noise walls. These act as barriers, and, to be effective, must be of sufficient unbroken length, material and height to reduce noise. The posted speed limit is another way to reduce noise; the lower the speed, the lower the noise.

The potential for the project to permanently increase traffic noise is addressed in the Revised EIR under the following traffic impact analysis scenarios: Existing + Project Buildout, NearTerm + Project Buildout, and Year 2035 + Project Buildout. Noise levels with and without project implementation are provided in Addendum to the Noise Technical Report Table 2 and Table 3, Existing + Project Traffic Noise Levels; Addendum to the Noise Technical Report Table 4 and Table 5, Near-Term Traffic Noise Levels; and EIR Table 4.12-13, Year 2035 Staff Report, September 23, 2020
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Traffic Noise Levels. As shown in these tables, noise levels on segments of Mast Boulevard, Mission Gorge Road, Fanita Parkway, Carlton Hills Boulevard, Cuyamaca Street, and SR-52 are calculated to be 70 dBA CNEL or above under existing or future conditions. The project would not directly result in a significant contribution (3 dBA or higher) to noise levels on Mast Boulevard, Mission Gorge Road, Carlton Hills Boulevard, or SR-52. No noise mitigation measures are required for these roadways.

Regarding noise impacts on Fanita Parkway and Cuyamaca Street, the Revised EIR identifies Mitigation Measure NOI-6, Noise Barrier Installation, to mitigate noise impacts to these roadways. Mitigation Measure NOI-6 would reduce impacts to some, but not all, receptors to a less than significant level. Section 4.12.5.1, under the Operational Noise Mitigation Measures heading, includes an evaluation of other mitigation measures that were considered but rejected for the project, including additional noise barriers and installation of asphalt rubber.

Feasible mitigation is not available to reduce all significant traffic noise increases to below the City’s CEQA thresholds; therefore, Section 4.12.5.1 identifies a significant and unavoidable operational traffic noise impact on Fanita Parkway and Cuyamaca Street.

Where noise walls are feasible, the project will construct noise walls concurrently with road construction at the following locations:
• The west side of Fanita Parkway from Mast Boulevard to just south of the development area of Orchard Village
• The east side of Cuyamaca Street from Mast Boulevard to El Nopal The heights of these walls will vary depending on topographical conditions and vehicle volumes, generally from 4 to 8 feet. The upper portions of such walls may utilize clear materials to preserve views outward from private properties while functioning as a noise reduction measure.

Construction activities are anticipated to occur during the City’s allowable hours of operation; however, some nighttime construction within roadways may be required to avoid traffic impacts. Section 4.12.5.1 evaluates construction noise impacts as result of the project.

Nighttime construction, if necessary, would require approval by the Director of Development Services approval consistent with Section 5.04.090 of the City’s Noise Ordinance. This requirement, and a commitment to sound reduction measures, is included in Mitigation Measure NOI-4, Nighttime Noise Sound Management Plan. Additionally, Mitigation Measure NOI-3, Roadway Construction Notification, requires written notification to any existing uses within 300 feet of roadway construction activities be provided no later than 10 days before the start of construction activities. The notification would provide a point of contact to resolve noise complaints. The notification process would allow residents to voice concerns to the City prior to the start of construction, and during construction activities.

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Air Quality:

Air quality laws and regulations have divided air pollutants into two broad categories: criteria air pollutants and Toxic Air Contaminants (TACs). Criteria air pollutants are a group of common air pollutants regulated by the federal and state governments by means of ambient standards based on criteria regarding public health and environmental effects of pollution (USEPA 2016). TACs are pollutants with the potential to cause significant adverse health effects. In California, the California Air Resources Board (CARB) identifies exposure thresholds for TACs that indicate the level below which no significant adverse health effects are anticipated from exposure to the identified substance. However, thresholds are not specified for TACs that have no safe exposure level, or where insufficient data is available to identify an exposure threshold (CARB 2011).

Some members of the population are especially sensitive to air pollutant emissions and are given special consideration when evaluating air quality impacts from projects. Air quality regulators typically define sensitive receptors as schools (preschool–12th grade), hospitals, resident care facilities, daycare centers, or other facilities that may house individuals with health conditions that would be adversely impacted by changes in air quality.

Criteria Air Pollutants: Individual air pollutants at certain concentrations may adversely affect human or animal health, reduce visibility, damage property, and reduce the productivity or vigor of crops and natural vegetation. The U.S. Environmental Protection Agency (USEPA) and CARB have identified six air pollutants of concern at nationwide and statewide levels:
carbon monoxide (CO), NOx, O3, particulate matter (PM), sulfur dioxide (SO2), and lead1.

Additionally, hydrogen sulfide is a state criteria pollutant that is relevant to the discussion of odor-related impacts.

The San Diego Air Pollution Control District (SDAPCD) is also responsible for establishing and enforcing local air quality rules and regulations that address the requirements of federal and state air quality laws. Development projects in the City are subject to the following SDAPCD rules (as well as others):
• Rule 50, Opacity: Prohibits activities that will create air contaminant emissions darker than 20-percent opacity for more than an aggregate of 3 minutes within a 60-minute period. • Rule 51, Nuisance: prohibits emissions that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public; or which endanger the comfort, repose, health, or safety of any such persons or the public; or which cause injury or damage to business or property.
• Rule 52, Particulate Matter (PM): establishes limits to the discharge of any PM from non‐ stationary sources.
• Rule 54, Dust and Fumes: establishes limits to the amount of dust or fume discharged into the atmosphere in any one (1) hour.

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• Rule 55, Fugitive Dust Control: sets restrictions on visible fugitive dust from construction and demolition projects.
• Rule 67, Architectural Coatings: establishes limits to the VOC content for coatings applied within the SDAPCD.

Criteria pollutant emissions associated with the project would occur over the short-term from construction activities (e.g., fugitive dust from site preparation and grading) and emissions from equipment exhaust. Long-term regional emissions would be associated with projectrelated vehicular trips and energy consumption by the project. Construction and operational emissions are addressed separately below.

Construction: Construction activities produce combustion emissions from various sources (e.g., site preparation, grading, utilities construction, surface improvements, and motor vehicles transporting the construction crew). Exhaust emissions from construction activities that would occur onsite would vary daily as construction activity levels change. The use of construction equipment on site would result in localized exhaust emissions.

Table 4.2-5 in the Revised EIR summarizes the maximum daily emissions that would be expected to occur during each construction year, including on and off-site emissions. As shown in Table 4.2-5, peak annual emissions would be below the annual thresholds for each year of construction, and daily emissions of VOC, NOx, CO, and SOx would not exceed the daily significance thresholds during any construction year. However, daily exceedances of PM10 would occur from 2021 to 2028 and in 2030 during construction phases 1 through 4, and PM2.5 from 2021 to 2029, and in 2030–2031 during construction phases 1 through 4. The exceedance of the daily County thresholds for PM10 and PM2.5 would be primarily due to the hauling trips on internal, unpaved roads during site preparation, grading, and utilities construction. PM10 and PM2.5 emissions would be higher in 2023–2024 than in other years because Phase 1 grading would involve a large number of trips within the project boundary due to the large aggregate quantities required by mass grading in Phase 1 for that initial phase. Impacts associated with criteria air pollutant emissions during construction would be potentially significant and mitigation measures are included in the MMRP.

Valley Fever is an illness caused by the Coccidioides fungus that usually affects the lungs.

The fungal spores are generally found in the upper 20 to 30 centimeters of the soil horizon, especially in virgin, undisturbed soils. Coccidioides fungus thrives in arid environments.

Without water the Coccidioides fungus eventually desiccates into spores. Watering during earth disturbance activities significantly reduces airborne spores and the ability of workers to inhale spores, which is the route of infection.

The project is required to implement the dust control measures listed in compliance with SDCAPCD Rule 55, which prohibits discharges of visible dust emissions into the atmosphere beyond the property line for periods longer than 3 minutes in any 60-minute period. Vehicle speeds on unpaved roads on the site shall be limited to 20 miles per hour (mph), unless high winds in excess of 20 mph are present, in which case a reduced speed limit of 15 mph shall apply. Vehicle speeds are limited to 30 mph for onsite haul roads that are paved with gravel to suppress dust or where visual dust is watered and monitored frequently enough to ensure Staff Report, September 23, 2020
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SDAPCD Rule 55 compliance. Furthermore, water shall be applied at least three times a day at all active earth disturbance areas sufficient to confine dust plumes to the immediate work area.

SDCAPCD also requires use of any of the following or equally effective trackout/carry-out and erosion control measures that apply to the project or operation: track-out grates or gravel beds at each egress point, wheel-washing at each egress during muddy conditions, soil binders, chemical soil stabilizers, geotextiles, mulching, or seeding; and for outbound transport trucks:
using secured tarps or cargo covering, watering, or treating of transported material.

The construction contractor shall provide to all employees a fact sheet entitled “Preventing Work-related Coccidioidomycosis (“Valley fever”) by the California Department of Public Health, and ensure all employees are aware of potential risks and inform them of all Valley Fever protocols, occupational responsibilities and requirements such as contained in these measures to reduce potential exposure to spores.

Operation: Long-term air pollutant emissions impacts are those associated with stationary sources and mobile sources involving any project-related changes. Operation of the project would result in net increases in stationary, area, and mobile source emissions. Stationary sources of emissions include the use of architectural coatings, consumer products, landscape equipment, and energy use. Area-source emissions would be associated with activities such as natural gas for heating and other sources. Mobile source emissions of air pollutants would include project-generated vehicle trips. Operational emissions calculated for the preferred land use plan with school and the land use plan without school are reported separately below.

Table 4.2-6 in the Revised EIR shows the long-term operational emissions associated with the project. Table 4.2-6 shows that buildout year project-related emissions of VOC, CO, and PM10 would exceed daily and annual County thresholds for criteria pollutants. Therefore, criteria air pollutant direct impacts during long-term operation of the preferred land use plan with school would be potentially significant. Impacts related to VOC and PM10 emissions would also be cumulatively considerable because of the SDAB’s nonattainment status for O3 and PM10.

Table 4.2-7 in the Revised EIR shows that the buildout year project-related emissions of VOC, CO, and PM10 under the land use plan without school would exceed daily and annual County thresholds for criteria pollutants. Therefore, criteria air pollutant direct impacts during long-term operation of the land use plan without school would be potentially significant. Impacts related to VOC and PM10 emissions would also be cumulatively considerable because of the SDAB’s nonattainment status for O3 and PM10.

Mitigation Measures AIR-1 through AIR-5, would reduce significant construction emissions of PM10 and PM2.5 associated with the project. However, as shown in Table 4.2-8 in the Revised EIR, construction emissions of PM10 and PM2.5 would not be reduced to below the applicable daily thresholds. Therefore, construction impacts would remain significant and unavoidable after implementation of mitigation measures.

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Mitigation Measures AIR-6 through AIR-10, listed in Section 4.2.5.1, and Mitigation Measure GHG-4 in Section 4.7 would reduce significant daily and annual operational emissions of VOC, CO, and PM10 associated with the project. Tables 4.2-9 and 4.2-10 show the mitigated operational emissions under the preferred land use plan with school and the land use plan without school, respectively. As shown in Tables 4.2-9 and 4.2-10, operational CO emissions from implementation of the project would be reduced to a less than significant level. However, VOC and PM10 emissions would remain cumulatively considerable and unavoidable under both land use plans after implementation of mitigation measures.

Mitigation Measures AIR-11 and AIR-12 respectively address construction buffer areas on the project site during early phase earthwork to minimize effects to new residents within the Village Center, and restrictions on the size and location of a gas station should one be constructed onsite.

The project includes all feasible Mitigation Measures to reduce construction and operational impacts but air quality impacts remain significant and unavoidable.

Water Supply/Infrastructure:

Development of the project site would increase the demand for water. Water service for the project would be provided by PDMWD. Based on a Water Supply Assessment prepared for the project, it was concluded that PDMWD’s total projected water supplies are sufficient to serve the demand of all customers, including the increased demand from the project in normal, single- and multiple-dry year scenarios over a 20-year planning horizon. Furthermore, the San Diego County Water Authority confirmed in electronic correspondence to PDMWD, dated January 28, 2020, that it has allocated “Accelerated Forecasted Growth” supplies for the additional demand associated with the project.

In addition, PDMWD’s East County Advanced Water Purification Project (ECAWP) is currently in the project procurement and permitting phase. The ECAWP is anticipated to treat the combined 2025 wastewater flow of approximately 15 million gallons per day (MGD) and produce up to 12,880 acre-feet per year (AFY), or 11.5 MGD, of new, reliable, and locally controlled potable water supply. If the ECAWP Project is commissioned by 2025, the project would utilize water from the ECAWP Project within the 20-year water supply planning horizon and beyond. But, notably, the ECAWP Project is not necessary for PDMWD to meet the demand associated with the project; it only provides an additional supply source for further water supply security for all PDMWD customers if it is implemented.

The proposed water system would be designed and installed per PDMWD and Santee Fire Department requirements as a public water system throughout the project site. A limited number of private hydrants would be installed in coordination with PDMWD. The project would construct a redundant, or looped, water supply system for fire protection and system reliability.

The project would also construct new public sewer infrastructure that would be owned, operated, and maintained by PDMWD. Sewage generated on the project site would be treated at the existing Ray Stoyer Water Recycling Facility (WRF) or at the new WRF to be constructed as part of the ECAWP Project. In instances where the WRF is offline for Staff Report, September 23, 2020
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maintenance or capital improvement, sewage generated on the project site would be diverted to the City of San Diego’s Metropolitan Sewerage System.

Landform Alteration/Grading:

Construction of the project would involve extensive excavation and grading into the native terrain. Earthwork would involve approximately 27 million cubic yards of cut and fill materials, which would be balanced on site. An on-site aggregate plant would help balance the cut and fill by producing approximately 300,000 cubic yards of building materials required for the project.

Construction would include cuts up to 165 feet and fills up to 142 feet.

Improvements associated with Fanita Parkway would consist of grading along the eastern side of the proposed parkway from Mast Boulevard to Ganley Road, and placing additional embankments at several locations along the western edge of the existing roadway. Proposed grading would generally consist of cut and fill slopes of less than 10 feet. Several retaining walls measuring equal to or less than 12 feet in height are also proposed.

Improvements to Cuyamaca Street would cross at least three easterly draining ravines. Cut and fill on the order of 85 feet and 70 feet, respectively, are proposed. It is anticipated that the proposed embankments would be constructed from materials excavated from the roadway cut areas. Due to extensive alteration of the natural ground surface during grading operations associated with the construction of the proposed villages and roadway improvements, there is a high possibility for erosion and topsoil loss.

In consideration of the above, prior to the
issuance of a grading permit by the City of
Santee, the applicant must demonstrate that
the recommendations and specifications
contained in the geotechnical investigations
conducted for the project site and off-site
areas have been incorporated into the final
project design and construction documents
as minimum project requirements. The
geotechnical recommendations include but
are not limited to general geotechnical
recommendations, recommendations for the
Special Use area, soil and excavation
characteristics, terrace drains, grading,
seismic design criteria, slope stability,
corrosive potential, foundation and concrete slab on-grade, retaining walls and lateral loads, slope maintenance, site drainage and moisture protection, and recommended grading specifications.

The proposed project includes a drainage network designed to control and filter stormwater runoff in conformance with State Regional Water Quality Control Board and City’s requirements, which call for retention first, then biofiltration. The proposed stormwater system Green: fill areas
White: cut areas
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would include the use of biofilters, on-site storage of stormwater in basins with outlets that regulate the flow rate and duration of stormwater released, and the use of both retention and detention basins to slow and store runoff. Hydromodification management would occur through storage of stormwater in proposed on-site basins, with outlets to regulate the flow rate and duration of stormwater released.

Runoff would be collected in storm drain inlets from street surfaces and routed toward multipurpose basins and treated for stormwater quality, flow control for hydromodification, and flood attenuation to maintain or reduce the existing peak-flow rates during a 100-year storm event.

The pre-development project 100-year flows are estimated at 3,312 cubic feet per second.

Through project design, stormwater runoff upon project completion would result in an estimated 2,729 cubic feet per second 100-year flows. Thus, project design would help to reduce flows by approximately 583 cubic feet per second versus existing conditions.

Cultural Resources:

The Conservation Element of the Santee General Plan discusses water resources, land resources, archaeological and cultural resources, biological resources, and open space.

Specifically, Objective 8.0 addresses the preservation of significant cultural resources, and Policies 8.1 and 8.2 read as follows:

Policy 8.1. The City shall require either the preservation of significant historic or prehistoric sites, or the professional retrieval of artifacts prior to the development of a site, consistent with the provisions of the California Environmental Quality Act. Preservation may include various measures including avoidance, preservation in place, incorporation into open space, or covering or capping. The type of preservation would depend upon the nature and significance of the archaeological resource and the practical requirements of the proposed land use.

Policy 8.2. The City should require curation of any recovered artifacts as a condition of any cultural resources mitigation program.

Cultural resources are districts, buildings, sites, structures, areas of traditional use, or objects that represent the physical evidence of human activities. Cultural resources can be divided into three categories: archaeological resources (prehistoric and historic), built environment resources (architectural), and Tribal Cultural Resources (TCRs). Of the three, TCRs were previously documented and new resources were discovered. The property is devoid of structures, but the Stowe Trail is recognized as a historic resource. Typically, projects are conditioned to have qualified archaeological monitors on the site when ground disturbing activity begins, and this applies to the Fanita Ranch approvals. There are eleven (11) mitigation measures to ensure that the project protects cultural resources, including a Native American Monitor during ground-disturbing activities for project construction. These mitigation measures have been developed in consultation with Kumeyaay representatives and San Diego Archaeological Society.

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F. REMOVAL OF MAGNOLIA EXTENSION AS A PROJECT DESIGN FEATURE Project Change and Redirection of Funds to SR-52 Improvements:

The City initially noticed a public hearing on the project and related approvals for August 26, 2020. On August 20, 2020, the applicant requested that the extension of Magnolia Avenue be removed from the project for reasons explained in a letter to the City included as Attachment

9. The applicant also requested cancellation of the August 26 hearing to enable the City to process this project change.

Magnolia Avenue is an existing north–south City street that currently terminates at the northern edge of existing development approximately 500 feet north of Princess Joann Road, southeast of the project site. The project had formerly proposed to improve and extend this street approximately 0.5 mile from its current northerly terminus, curving west to intersect with the extended off-site segment of Cuyamaca Street south of the project site boundary. The extension of Magnolia Avenue would not provide direct access to the project site. Though the extension is not required for the project to comply with CEQA, the applicant agreed to implement it as a project design feature. Without the Magnolia Avenue extension, project trips would instead utilize streets such as Princess Joann Road, Woodglen Vista Drive, El Nopal and Mast Boulevard. Until such time as Magnolia Avenue is extended to connect with Cuyamaca Street, the project is conditioned to prohibit southbound left-turn movements from Cuyamaca Street to these local streets (except in the event of emergency) in order to reduce potential disturbance to residents from cut-through traffic.

The applicant has committed to using the funds it would have expended on the Magnolia Avenue extension for improvements to SR-52 to relieve existing and future congestion, as memorialized in the proposed Development Agreement discussed above.

Revisions to Revised EIR to Reflect Removal of Magnolia Extension:

Prior to the elimination of the Magnolia Avenue extension, the Final Revised EIR, including the Revised EIR Errata (now referred to as the First Errata), Appendices Errata, and the Responses to Comments, as well as the Mitigation, Monitoring, and Reporting Program, were nearly complete and in the process of being finalized. To address the project change, the City has prepared a Second Errata to the Final Revised EIR summarizing the change to the project description and providing a discussion of the potential effects that the change has on the impact analysis provided in the Final Revised EIR. The Second Errata is supported by technical memorandums from various consultants analyzing the project change.

Any reference to the previously proposed Magnolia Avenue extension as a project feature contained in the Draft or Final Revised EIR or Appendices has been deleted from the Revised EIR. The extension of Magnolia Avenue is still included in the Mobility Element of the General Plan as part of the City’s circulation network. Therefore, it is still assumed to be completed as part of the General Plan buildout in the long-term scenarios analyzed in the Revised EIR for impact areas such as air quality, energy, greenhouse gas emissions, noise, and traffic.

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As discussed in further detail in the Second Errata (Section 1.3.2.6, amending Section 4.16 of the Final Revised EIR), Magnolia Avenue was assumed not to be constructed from the future Cuyamaca Street extension to its existing terminus just north of Princess Joann Road. Without this connection, two network scenarios were analyzed. The first would allow full access movements from Cuyamaca Street to Princess Joann Road, Woodglen Vista Drive, and El Nopal connecting to Magnolia Avenue. The second condition, which is recommended by City staff and included as a condition of project approval, would prohibit southbound left-turn movements from Cuyamaca Street to these local streets (except in the event of emergency) in order to reduce potential disturbance to residents from cut-through traffic.

To analyze potential traffic effects, the Second Errata evaluates the operations specific to the Cuyamaca Street and Magnolia Avenue corridors, where a change in project trips would occur.

Without the connection of the Magnolia Avenue extension, one segment impact would be a direct impact instead of a cumulative impact (Cuyamaca Street between Woodglen Vista Drive and El Nopal). The mitigation recommended in the Revised EIR for improving Cuyamaca Street between Woodglen Vista Drive and El Nopal to four lanes (Mitigation Measure TRA-25) would fully mitigate this impact. Therefore, no new impacts would occur by deleting the extension of Magnolia Avenue and the previously recommended mitigation would be unchanged. In addition, the VMT analysis and conclusion would not change as a result of the deletion of the extension of Magnolia Avenue. The grid-like pattern of the north/south corridors of Cuyamaca Street and Magnolia Street intersecting with the east/west roadways of Princess Joann Road, Woodglen Vista Drive, El Nopal, and Mast Boulevard would result in a de minimis change in the distances traveled between the project site and destinations to the south.

Regarding air quality, greenhouse gas emissions and energy (fuel use), the Second Errata concludes that the de minimis increase in VMT (0.67 percent) resulting from the removal of the Magnolia Avenue extension results in minor increases in GHG emissions (0.01 MT CO2e per service population increase) and fuel use but does not change the findings in the Revised EIR related to these potential impact areas.

The significant impacts to noise levels on Magnolia Avenue from Princess Joann Road to El Nopal previously identified during project operation would be eliminated with removal of the Magnolia extension. Additionally, construction noise and vibration impacts associated with construction of the Magnolia Avenue extension would be eliminated. A significant impact to the existing Magnolia Avenue roadway segment of Princess Joann Road to Woodglen Vista Drive during building construction and interim operation would continue to occur with removal of the Magnolia Avenue extension and would be mitigated to less than significant with implementation of Mitigation Measure NOI-2. All other impacts remain the same as with the Magnolia Avenue extension.

Regarding potential effects related to Wildfires, with the Magnolia Avenue extension there were two points of ingress/egress to the project site, and without the Magnolia Avenue extension there remain two points of ingress/egress. In no case in the Fire Protection Plan, the Wildland Fire Evacuation Plan, or the Revised EIR, was the Magnolia Avenue extension considered a critical component to fire protection, fire response, or evacuation of the project.

The 2019 California Fire Code, Appendix D and the Santee Fire Code require projects with Staff Report, September 23, 2020
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greater than 200 dwelling units to include two separate access routes. Without the Magnolia Avenue extension, the project has two access points: Fanita Parkway and Cuyamaca Street.

Thus, even absent the Magnolia Avenue extension, the project meets fire code requirements for secondary access. Further, without the Magnolia Avenue extension, emergency managers would retain the ability to route traffic to Magnolia Avenue via three existing two lane roadways (Princess Joann Road, Woodglen Vista Drive, and El Nopal) and other more circuitous available options intersecting these east-west routes. While the Magnolia Avenue extension would potentially allow emergency managers to route a percentage of evacuating project vehicles to Magnolia Avenue north of the existing neighborhoods, it would not necessarily result in more efficient evacuations. Without the Magnolia Avenue extension, the same primary roadways would be used to move vehicles out of the area. Existing residents and proposed project residents would be routed to Cuyamaca Street and Magnolia Avenue via existing and project-provided roadways, while existing residents may also be moved south via the neighborhood-internal Timberlane Way, an additional north–south connection to Mast Boulevard.

Accordingly, the Second Errata concludes that the removal of Magnolia Avenue extension as a project design feature would not increase existing impacts or cause new impacts to occur under the preferred land use plan with school or land use plan without school. Notably, removal of the Magnolia extension results in fewer potential impacts related to biological resources, cultural resources, and geology, soils and paleontological resources. None of the clarifications as a result of the removal of the Magnolia Avenue extension as a project feature results in “significant new information” pursuant to State CEQA Guidelines Section 15088.5(a) requiring recirculation of the Draft Revised EIR.

G. SIGNIFICANT AND UNAVOIDABLE IMPACTS UNDER CEQA
As discussed in detail in the Revised EIR, the following impact areas would remain significant and unavoidable even after implementation of all feasible mitigation measures:
• Air Quality:
o Conflict with applicable air quality plans. The project would exceed the number of residential units identified for the project site in the 2013 Santee General Plan Housing Element Amendment projections. In addition, with implementation of all feasible mitigation measures, criteria air pollutant emissions would be reduced but the project would still exceed the regional significance threshold for PM10 and PM2.5 during project construction and would exceed the thresholds for VOC and PM10 during project operation. Therefore, due to the exceedance of SANDAG’s growth assumptions assumed for the project site and the exceedance of nonattainment pollutants, the project is considered inconsistent with the San Diego Regional Air Quality Strategy. o Significant net increase in criteria pollutant emissions during construction and operation. Peak annual emissions would be below the annual thresholds for each year of construction, and daily emissions of VOC, NOx, CO, and SOx would not exceed the daily significance thresholds during any construction year. But daily exceedances of Staff Report, September 23, 2020
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PM10 would occur from 2021 to 2028 and in 2030 during construction phases 1 through 4, and PM2.5 from 2021 to 2029, and in 2030–2031 during construction phases 1 through 4. The exceedance of the daily County thresholds for PM10 and PM2.5 would be primarily due to the hauling trips on internal, unpaved roads during site preparation, grading, and utilities construction. Mitigation Measures AIR-1 through AIR-5 would reduce significant construction emissions of PM10 and PM2.5 associated with the project. However, construction emissions of PM10 and PM2.5 would not be reduced to below the applicable daily thresholds. Therefore, construction impacts would remain significant and unavoidable after implementation of mitigation measures. Buildout year project-related emissions of VOC, CO, and PM10 would exceed daily and annual County thresholds for criteria pollutants. Therefore, criteria air pollutant direct impacts during long-term operation of the preferred land use plan with school as well as the land use plan without school would be potentially significant. Impacts related to VOC and PM10 emissions would also be cumulatively considerable because of the San Diego Air Basin’s nonattainment status for O3 and PM10. Mitigation Measures AIR-6 through AIR-10 and Mitigation Measure GHG-4 would reduce significant daily and annual operational emissions of VOC, CO, and PM10 associated with the project.

Operational CO emissions from implementation of the project would be reduced to a less than significant level. But VOC and PM10 emissions would remain cumulatively considerable and unavoidable under both land use plans after implementation of mitigation measures.
• Noise: Conflict Permanent increase in traffic noise levels. Vehicle noise levels on Fanita Parkway under all scenarios would be within the conditionally compatible noise level range of 70 dBA Ldn or below for residential development but would exceed the applicable threshold of significance of 65 dBA Ldn (the normally acceptable noise level). Noise levels on the segment of Cuyamaca Street from El Nopal to Mast Boulevard would also potentially exceed the conditionally compatible noise level range. Mitigation Measure NOI6 requires the installation of a noise barrier on some impacted segments of Fanita Parkway and Cuyamaca Street. Due to the difference in elevation between the proposed Fanita Parkway improvements and the sensitive receptors at the Santee Lakes Recreation Preserve campground (vertical difference of approximately 12 feet), a 4-foot wall at the western edge of the Fanita Parkway roadway right-of-way for the entire length of the campground would break the line of sight between the source and receptor and is calculated to reduce noise levels to 60 dBA Ldn at the nearest campsites. Noise barriers in the roadway right-of-way are anticipated to be feasible on the western side of Fanita Parkway from the project entrance to Mast Boulevard and from El Nopal to Mast Boulevard on the eastern side of Cuyamaca Street. However, it is not feasible to construct noise barriers on all impacted segments identified in Addendum to the Noise Technical Report Table 12 and EIR Table 4.12-16 due to existing cross streets, driveways, and differences in grade between the roadways and receptors that would make barriers installed within the roadway right-of-way ineffective. Noise walls up to approximately 20 feet in height in the roadway right-of-way would be required on the eastern side of Fanita Parkway to break the line of sight and provide noise attenuation at adjacent receptors.

Noise walls up to approximately 23 feet in height would be required on the western side of Cuyamaca Street. At these heights, noise walls would be visually incompatible with the Staff Report, September 23, 2020
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surrounding community and above the Caltrans maximum noise barrier height of 14 to 16 feet, depending on distance from travel lanes. Additionally, the City’s Zoning Ordinance generally limits noise walls to a maximum height of 8 feet (Santee Municipal Code, Section

13.10.050[F][2]). Therefore, noise walls are not considered feasible along these segments of Fanita Parkway and Cuyamaca Street. Additional noise barriers may be feasible on Fanita Parkway and Cuyamaca Street if barriers can be negotiated with private property owners to be installed at existing fence lines rather than in the roadway right-of-way; however, such agreements cannot be guaranteed at this time, and even if some property owners agree, the barriers would need to be continuous across multiple properties to be effective. Therefore, this is not considered to be a feasible mitigation measure. Operational impacts to some segments of Fanita Parkway and Cuyamaca Street would remain significant and unavoidable.
• Transportation:
o Significant increase in traffic at intersections located outside Santee’s jurisdiction, or no funding mechanism is currently available, or no feasible mitigation is available. Direct impacts were calculated under Existing + Project and Existing + Cumulative Projects + Project conditions where project-added traffic would result in the degradation from acceptable LOS D or better operations to LOS E or F conditions or, for those locations currently operating at LOS E or F, in an increase greater than the allowable thresholds identified in EIR Tables 4.16-6 through 4.16-9. Cumulative impacts were calculated where project-added traffic would result in a significant increase in intersection delay or street segment volume-to-capacity ratios over the allowable thresholds mentioned above under Year 2035 + Project conditions. Based on Table 2 of the Fanita Ranch – No Magnolia Avenue Extension Analysis Traffic Memorandum, the segment of Cuyamaca Street between Woodglen Vista Drive and El Nopal would change from a cumulative impact to a direct impact. However, the mitigation measure recommended in the EIR for this segment is still required. The equivalent dwelling unit triggers were developed in a mitigation phasing analysis in the Traffic Impact Analysis. EIR Figure

4.16-2, Project Design Features, Impacts, and Mitigation Measures, illustrates where the project design features and impacts would be distributed and where the mitigation measures would mitigate those impacts. Implementation of Mitigation Measures TRA6, TRA-9, TRA-10, TRA-13, TRA-14, TRA-19, TRA-20, TRA-21, TRA-22, TRA-28, TRA-29, and TRA-30 would reduce operational traffic impacts but not to a level less than significant. These intersections, street segments, and freeway mainline segments lie within one of the following jurisdictions: Caltrans, County of San Diego, or City of San Diego. Therefore, the City of Santee is without jurisdiction to ensure implementation of the recommended improvements. Mitigation Measure TRA-15 would reduce the impact at the West Hills Parkway/Mission Gorge Road intersection but not to a less than significant level until a proper funding mechanism is established for the improvement. Mitigation Measure TRA-16 would not be expected to reduce the impact to Mission Gorge Road at Carlton Hills Boulevard because Adaptive Traffic Signal Controls along this corridor may not reduce delays to below pre-project levels.

Mitigation Measures TRA-19 and TRA-22 would reduce the impacts on El Nopal from Magnolia Avenue to Los Ranchitos Road and Carlton Oaks Drive from Fanita Parkway Staff Report, September 23, 2020
Fanita Ranch

to Carlton Hills Boulevard, respectively, but not to less than significant as widening of these segments is considered infeasible. Therefore, impacts to these intersections, street segments, and freeway mainline segments would remain significant and unavoidable.
o Increase in Vehicle Miles Traveled above the calculated threshold. Based on the applied VMT significance criteria for the preferred land use plan with school and land use plan without school, a significant impact would occur under both land use plans.

Mitigation Measure AIR-6 would require the implementation of the TDM Plan prepared for the project. With the assistance and guidance of the California Air Pollution Control Officers Association Resource Manual (2010), the VMT reduction that would result from the strategies and measures set forth in the TDM Plan, considering the maximum allowable sub-category, category, and global reductions, has been calculated as 13.7 percent reduction in VMT with a school and 12 percent reduction without a school.

While this measure would lessen project VMT, it would not reduce impacts to a less than significant level. Therefore, this impact would remain significant and unavoidable after mitigation.
• Recreation: Air quality, noise and transportation impacts related to construction of new recreational facilities. The project would include the construction of recreational facilities, including parks and trails. Specific recreational facilities proposed include the construction of approximately 78 acres of Community, Neighborhood, and Mini-Parks and over 35 miles of various trails. Some impacts of the construction of recreational facilities would be reduced to a less than significant level with mitigation, while others (air quality and transportation) would remain significant and unavoidable after all feasible mitigation is applied.
• Utilities: Air quality, noise and transportation impacts related to construction of new and expanded utilities. Some impacts from construction of new utilities infrastructure to facilitate water, wastewater, stormwater, electric power, natural gas, and telecommunications facilities would be reduced to a less than significant level with mitigation, while others (air quality and transportation) would remain significant and unavoidable after all feasible mitigation is applied.

H. STATEMENT OF OVERRIDING CONSIDERATIONS
Under State CEQA Guidelines section 15043, a public agency may approve a project even though the project would cause a significant effect on the environment if the agency makes a fully informed and publicly disclosed decision that (1) there is no feasible way to lessen or avoid the significant effect (see Section 15091), and (2) specifically identified expected benefits from the project outweigh the policy of reducing or avoiding significant environmental impacts of the project (see Section 15093). The proposed Resolution certifying the Revised EIR includes Findings of Fact and a Statement of Overriding Considerations finding that economic, legal, social, technological or other benefits, including region-wide benefits, of the project outweigh the unavoidable adverse environmental effects, rendering adverse environmental effects “acceptable.”
Staff Report, September 23, 2020
Fanita Ranch

STAFF RECOMMENDATIONS

1. Conduct and close the Public Hearing; and

2. Certify the Revised Environmental Impact Report (SCH # 2005061118) for the Fanita Ranch Project; adopt Findings of Fact, a Statement of Overriding Considerations, and a Mitigation Monitoring and Reporting Program under CEQA; and approve the Project, per the attached Resolution No.093-2020; and

3. Approve General Plan Amendment (GPA2017-2) per the attached Resolution No.094- 2020; and

4. Introduce for First Reading Ordinance No. 580 amending Chapter 13.04 (“Administration”) and adding Chapter 13.20 (“Specific Plan District)” to Title 13 of the Santee Municipal Code, and adopting the Fanita Ranch Specific Plan; and

5. Approve Vesting Tentative Map (TM2017-3) per the attached Resolution No.095-2020; and

6. Approve Development Review Permit (DR2017-4) per the attached Resolution No. 096-2020; and

7. Approve Conditional Use Permits P2017-5 and P2020-2 per the attached Resolution Nos 097-2020 and 098-2020; and

8. Introduce for First Reading Ordinance No. 581 approving and authorizing the City Manager to execute the Development Agreement with HomeFed Fanita Rancho LLC.

ATTACHMENTS

1. Ownership Disclosure

2. Santee MSCP Subarea Plan

3. Roadway Network and Circulation Improvements

4. Park Locations

5. Trip Generation Table 4.16-10

6. Fire Protection Measures

7. Late Comments Submitted by Southwest Regional Council of Carpenters and Response

8. Late Comments Submitted by Center for Biological Diversity and Response

9. August 20, 2020 Letter from HomeFed Fanita Rancho LLC re Project Change City of Santee
Development Services Dept.
10601 Magnolia Avenue
Santee, CA 92071-1222
(619) 258-4100)

OWNERSHIP DISCLOSURE

STATEMENT
Projec'T'f': F5tffl'4L bCu
Project Address:

Legal Status (please check):

Project No. For City Use Only
[] Corporation ([nLimited Liability -or- 0 General) What State? D4lAAA{AJfe, Corporate Identification No.:
[] Partnership (list names below) 0 Individual
(Type or Print Name of Partner)
(Type or Print Name of Partner)
(Type or Print Name of Partner)
(Type or Prlnt Name of Partner)
Please list below the owner(s) and tenants(s) (if applicable) of the above referenced property. The list must include the names, titles and addresses of all persons who have an interest in the property, recorded or otherwise, and state the type of property interest (e.g., tenants, if known, who will benefit from the permit, all individuals, all corporate officers, and all partners in partnership who own the property).

Note: The applicant is responsible for notifying the Project Manager of any changes in ownership during the time the application is being processed or considered. Changes in ownership are to be given to the Project Manager at least thirty days prior to any public hearing on the subject property.

Title/Property Intere)st (type or print)
Sfr6et Address:

City/Staje/;Zip: U
Phone No.: a Fax No.

Name (type or print):

Title/Property Interest (type or print)
Street Address:

City/State Zip:

Phone No.: Fax No.:

Signature:

FOR ADDITIONAL NAMES, PLEASE WRITE ON BACK OF THIS FORM - THANK YOU Attachment No. 1: Ownership Disclosure
De[aware
'& 'First5tate
PAGE 1
I, D7J'H'REY Tfl- BULLOCK, SECRETARY OF STATE OF THE STATJ;: OF DmATffARH, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AHD CORRECT COPY OF THE CERTIFICATE OF AMENDMENT OF "HOr4EFED FRMJKLIN LLC", CHARGING ITS NAME FROM "HOMEFED FRAfiLIN LLC" TO "HOMEHED FANITA RANCHO, LLC", FILED IN THIS OFFICE ON THE EIGHTH DAY OF FEBRUMIY, A-D- 2011, AT 7:27 0'CLOCJC P.M4898849 8100
110131730
You may verify this certfficate online
at cozp. delaware. gov/authver. shtml
AUT
Jeffrey W. Bullock, Secretary of State ' "%
ION: 8548075
DATE: 02-OS-11
State of Dalaware
Di4esZne'o7C:orfposr'anons
Delivered 07:33 PM 02/0872011
FulD 07:27 PH 02/08/2011
SRV 110231730 - 4898849 flu
8T ATE OF DELAWARE
UER'l'l!'IUAIE OF AMENDMENT

1. The name of the limited liability company is HOMBFED FRANKLn4 LLC.

2. The Certifiaate of Formation for HOMEFHD IN [LC was filed with the Delaware Secretary of State onNoyember 15, 2010, asFileNo. 4898849.

3. TheCertificateofFomationisherebyamendedbydeletingArticleFirstthereofinits entirety and substituting in lieu thereof:
"FIRST: The name of the limited liability company is HomeFed Faita Rancho, LLC." IN WITNESS WHE,REOF, die undersigned has executed this Certificate of Amendment on the :ij;j day of Febniary,2011.

Paul J,Bo""rded'e'nrt
761a67.D1/50
1MS40-aOaaf
City of Santee
Development Services Dept.
10601 Magnolia Avenue
Santee, CA 92071-1222
(619) 258-4100)

OWNERSHIP DISCLOSURE

STATEMENT
ProjectTitle: .k POazxtk
Project Address:

Project No. For City Use Only
Legal Status (please check):
0 Corporation ([21'Limited Liability -Or- 0 General) What State? r)-e-luahi[e, Corporate Identification No.:
[] Partnership (list names below) [1 Individual
(Type or Print Name of Partner)
(Type or Print Name of Partner)
(Type or Print Name of Partner)
(Type or Print Name of Partner)
Please list below the owner(s) and tenants(s) (if applicable) of the above referenced property. The list must include the names, titles and addresses of all persons who have an interest in the property, recorded or otherwise, and state the type of property interest (e.g., tenants, if known, who will benefit from the permit, all individuals, all corporate officers, and all partners in partnership who own the propertV)-
Note: The applicant is responsible for notifying the Project Manager of any changes in ownership during the time the application is being processed or considered. Changes in ownership are to be given to the Project Manager at least thirty days prior to any public hearing on the subject property.

Name (type or p71nt)
Title/Prop@rty Interegt (type qr print)
Strbet Address:

Phone No.: Fax No.

Signature:

Name (type or print):

Title/Property Interest (type or print)
Street Address:

City/State Zip:

Phone No.: Fax No.:

Signature:

FOR ADDITIONAL NAMES, PLEASE WRITE ON BACK OF THIS FORM - THANK YOU City of Santee
Development Services Dept.
10601 Magnolia Avenue
Santee, CA 92071-1222
(619) 258-4100)

OWNERSHIP DISCLOSURE

STATEMENT
ProjecfT'fle: %'4a- KmcL
Project Address:

Project No. For City Use Only
Legal Status (please check):
0 Corporation ([2{ Limited Liability -or- 0 General) \/Vhat State? [)2ll-k'eCorporate Identification No.:
[] Partnership (list names below) [l Individual
(Type or Print Name of Partner) (Type or Print Name of Partner) (Type or Print Name of Partner) (Type or Print Name of Partner) Please list below the owner(s) and tenants(s) (if app)icable) of the above referenced propefy. The list must include the names, titles and addresses of all persons who have an interest in the property, recorded or otherwise, and state the type of property interest (e.g., tenants, if known, who will benefit from the permit, all individuals, all corporate officers, and all partners in partnership who own the propem).

Note: The applicant is responsible for notifying the Project Manager of any changes in ownership during the time the application is being processed or considered. Changes in ownership are to be given to the Project Manager at least thirty days prior to any public hearing on the subject property.

Name (type or print):

Title/Property Interest (type or print)
Street Address:

City/State Zip:

Phone No.:
{760') qgg-8ub
Signature:

Phone No.:

Signature:

Fax No.:

FOR ADDITIONAL NAMES, PLEASE WRITE ON BACK OF THIS FORM - THANK YOU Attachment No. 2: Draft MSCP Subarea Plan
Preserve Subunits
Attachment No. 3: Roadway Exhibits

Attachment No. 4: Park Lands
Attachment No. 5: REIR Trip Generation Table
Attachment No. 6: Fire Protection Measures
Source: Fire Protection Plan
P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
VIA U.S. MAIL & E-MAIL
July 13, 2020
Via E-Mail & U.S. Mail
Chris Jacobs, Principal Planner
City of Santee
Mitchell M. Tsai
Attorney At Law
Department of Development Services
City Hall, Building 4
Santee, CA 92071
Em: cjaco [email protected]
155 South El Molino Avenue
Suite 104
Pasadena, California 91101
RE: Fanita Ranch Project, State Clearinghouse No. 2005061118 Dear Mr. Jacobs,
On behalf of the Southwest Regional Council of Carpenters ("Commenters" or "Carpenters"), my Office is submitting these comments on the City of Santee ("City" or "Lead Agency") Revised Draft Environmental Impact Report ("RDEIR") (SCH No. 2005061118) for the Fanita Ranch Project, a proposed development on 2,638 acres of land in the northern portion of the City to include up to 3,008 residential units and up to 80,000 square feet of commercial space ("Project").

The Southwest Carpenters is a labor union representing 50,000 union carpenters in six states, including in southern California, and has a strong interest in well ordered land use planning and addressing the environmental impacts of development projects.

Individual members of the Southwest Carpenters live, work, and recreate in the City of Santee and surrounding communities and would be directly affected by the Project's environmental impacts. Commenters expressly reserve the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code§ 65009(b); Cal. Pub. Res. Code§ 21177(a); Baker.ifi,eld Citizens for Local Control v. Baker.ifi,eld (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vinryards v. Monterry LT7ater Dist. (1997) 60 Cal. App. 4th 1109, 1121.

The City should seriously consider proposing that tl1e Applicant provide additional ATTACHMENT 7
City of Santee - Fanita Ranch RDEIR
July 13, 2020

community benefits such as requiring local hire and paying prevailing wages to benefit the City. Moreover, it would be beneficial for the City to require the Applicant to hire workers: (1) who have graduated from a Joint Labor Management apprenticeship training program approved by the State of California, or have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state approved apprenticeship training program and; (2) who are registered apprentices in an apprenticeship training program approved by the State of California.

Commenter expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code§ 65009(b); Cal. Pub. Res. Code§ 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

Commenter incorporates by reference all comments raising issues regarding the EIR submitted prior to certification of the EIR for the Project. Citizens for Clean Energy v Ciry e
f
U;7oodland (2014) 225 CA4th 173, 191 (finding that any party who has objected to the Project's environmental documentation may assert any issue timely raised by other parties).

Moreover, Commenter requests that the Lead Agency provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act ("CEQA"), Cal Public Resources Code ("PRC") § 21000 et seq, and the California Planning and Zoning Law ("Planning and Zoning Law"), Cal. Gov't Code §§ 65000-65010. California Public Resources Code Sections 21092.2, and 21167(£) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency's governing body.

I. THE CITY SHOULD CONTINUE THE DRAFT EIR'S COMMENT

DEADLINE TO FACILITATE PUBLIC PARTICIPATION
Due to the closure of many public facilities, the general public has not been able to receive public notice of this Project as required under the California Environmental Quality Act, Cal. Public Resources Code§ 21100 et seq ("CEQA"). CEQA requires that the Notice of Availability for the Project's Draft EIR / EA "be posted in the Office of the County Clerk for a period of at least 30 days." 14 Cal. Code of Regulations ("CEQA Guidelines")§ 15087(d). However, the San Diego County Clerk-Recorder City of Santee - Fanita Ranch RDEIR
July 13, 2020

has been closed to the public since July 6, 2020, and was previously closed to the public before the most recent closure. Since the Notice of Availability for the Project's Draft EIR was released on May 29, 2020, the general public has not had a full opportunity to see public notices concerning this Project as required by CEQA.

The City of Santee Department of Development Services website notes the Draft EIR may only be viewed in the Department by appointment only, aside from electronic access. This also fails to meet CEQA's public notice requirements.

In addition, CEQA requires that a lead agency "furnish copies of draft EIRs to public library systems serving the area involved." CEQA Guidelines§ 15087(g). However, the San Diego County Library in Santee is also closed to the public and only offers doorside service by appointment since June 15, 2020. The Project's Draft EIR does not appear to be among the materials available for curbside pickup from the San Diego County library in Santee.

The Project's Draft EIR has been released for public comment at a time when public facilities remain closed to the general public, or closed again after the initial round of closures due to renewed concerns about the spike in the number of COVID-19 cases, and it would be an appropriate and reasonable step to facilitate public participation on a Project that will have a significant impact on this region by extending the public comment period.

II. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. Background Concerning the California Environmental Quality Act CEQA has two basic purposes. First, CEQA is designed to inform decision makers and the public about the potential, significant environmental effects of a project. 14 California Code of Regulations ("CCR" or "CEQA Guidelines")§ 15002(a)(1). "Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR 'protects not only the environment but also informed self-government.' [Citation.]" Citizens o f Goleta
Valley v. Board of Supervisors (1990) 52 Cal. 3d 553, 564. The EIR has been described as "an environmental 'alarm bell' whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return." Berkeley Keep Jets Over the Bqy v. Ed o f Porl Comm'rs. (2001) 91 Cal.

App. 4th 1344, 1354 ("Berkeley Jets''); County o
f If!Jo v. Yorry (1973) 32 Cal.App.3d 795,
City of Santee - Fanita Ranch RDEIR
July 13, 2020

810.

Second, CEQA directs public agencies to avoid or reduce environmental damage when possible by requiring alternatives or mitigation measures. CEQA Guidelines § 15002(a)(2) and (3). See also, Berkelry Jets, 91 Cal. App. 4th 1344, 1354; Citizens of Goleta Vallry v. Board ef Supervisors (1990) 52 Cal.3d 553; L£utrel Heights Improvement Ass'n v.

Regents e
f the Universiry e
f
California (1988) 47 Cal.3d 376,400. The EIR serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to "identify ways that environmental damage can be avoided or significantly reduced." CEQA Guidelines § 15002(a)(2). If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has "eliminated or substantially lessened all significant effects on the environment where feasible" and that any unavoidable significant effects on the environment are "acceptable due to overriding concerns" specified in CEQA section 21081. CEQA Guidelines§ 15092(b)(2)(A-B).

While the courts review an EIR using an "abuse of discretion" standard, "the reviewing court is not to 'uncritically rely on every study or analysis presented by a project proponent in support of its position.' A 'clearly inadequate or unsupported study is entitled to no judicial deference."' Berkelry Jets, 91 Cal.App.4th 1344, 1355 (emphasis added) (quoting Laurel Heights, 47 Cal.3d at 391, 409 fn. 12). Drawing this line and determining whether the EIR complies with CEQA's information disclosure requirements presents a question of law subject to independent review by the courts. (Sierra Club v. Cnry. ef Fresno (2018) 6 Cal. 5th 502, 515; Madera Oversight Coalition, Inc. v.

Counry ef Madera (2011) 199 Cal.App.4th 48, 102, 131.)As the court stated in Berkelry Jets, 91 Cal. App. 4th at 1355:

A prejudicial abuse of discretion occurs "if the failure to include relevant information precludes informed decision-making and informed public participation, thereby thwarting the statutory goals of the EIR process.

The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. The EIR's function is to ensure that government officials who decide to build or approve a project do so ·with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate City of Santee - Fanita Ranch RDEIR
July 13, 2020

opportunity to comment on that presentation before the decision to go forward is made. Communitiesfor a Better Environment v. Richmond (2010) 184 Cal. App. 4th 70, 80 (quoting VinryardArea Citizens for ReJponsib!e Growth, Inc. v. Ciry efRancho Cordova (2007) 40 Cal.4th 412, 449-450).

B. The RDEIR Does Not Adequately Describe the Project
An EIR must be "prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of environmental consequences." Dry Creek Citizens Coalition v. Counry ef Tu!are (1999) 70 Cal.App.4th 20, 26. An EIR's description of the project should identify tl1e project's main features and other information needed for an assessment of the project's environmental impacts. Citizens for a Sustainable Treasure Island v Ciry & Counry ef San Francisco (2014) 227 Cal.App.4tl1 1036, 1053.

The RDEIR fails to adequately describe the proposed Project because it fails to identify a specific project proposal for construction on the site. The RDEIR proposes "a community consisting of approximately 2,949 residential units ... or 3,008 units ... [with] up to 80,000 square feet of commercial uses ... " (RDEIR, p. 1-1.) One plan also proposes a new school, anotl1er does not. The RDEIR is proposing two different projects, and does not describe with any degree of specificity how much commercial space will be constructed, including only a maximum figure. And what might take the place of the commercial square footage if it is not used, or will the maximum number of approximate residential units only be constructed if the maximum commercial space is not used, the RDEIR is not clear or complete on tl1ese issues in the description.

Furthermore, the Project consists of three villages centered around a farm space "vith an approximate number of units per village, but fails to describe what type of residential units will be constrncted beyond residential units of "varying densities and housing types." (See, e .. g, RDEIR, p. 3-22.) Without a description of the affordability levels of the units, height and type of housing set to be built, the Project' EIR cannot meaningfully evaluate the Project's greenhouse gas, transportation, land use or aesthetic impacts.

For tl1e reasons described above, the Project description is not accurate, stable, or finite and should be amended to include additional requisite details.

City of Santee - Fariita Ranch RDEIR
July 13, 2020

C. Due to the Current Public Health Crisis, the City must Adopt a Mandatory Finding of Significance that the Project's Construction Activities may cause a substantial Adverse Effect on Human Beings and Require Additional Safety Measures to Mitigate Potential Community Spread of COVID-19
CEQA requires that an agency make a finding of significance when a Project may cause a significant adverse effect on human beings. PRC§ 21083(b)(3); CEQA Guidelines§ 15065(a)(4).

Public health risks related to construction work requires a mandatory finding of significance under CEQA. Construction work has been defined as a Lower to Highrisk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several construction sites have been identified as sources of community spread of COVID-19.

SWRCC recommends that the Agency adopt additional CEQA mitigation measures to mitigate public health risks from the Project's constrnction activities. SWRCC requests tl1at the Agency require safe on-site construction work practices as well as training and certification for any construction workers on the Project Site.

In particular, based upon SWRCC's experience with safe construction site work practices, SWRCC recommends that the Agency require that while construction activities are being conducted at the Project Site:

Construction Site Design:
• The Project Site ·will be limited to two controlled entry points. •
•
Entry points will have temperature screening technicians taking temperature readings when the entry point is open.

The Temperature Screening Site Plan shows details regarding access to tl1e Project Site and Project Site logistics for conducting temperature screerung.
• A 48-hour advance notice ·will be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating tl1e appropriate 6-foot social distancing position for when you approach tl1e screening area. Please reference tl1e Apex temperature screening site map for additional details.

City of Santee - Fanita Ranch RDEIR
July 13, 2020

• There will be clear signage posted at the project site directing you through temperature screening.
• Provide hand washing stations throughout the constrnction site.

Testing Procedures:
•
•
•
•
•
•
•
•
•
The temperature screening being used are non-contact devices .

Temperature readings will not be recorded .

Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.

Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before temperature screening.

Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be refused access to the Project Site.

Screening will be performed at both entrances from 5:30 am to 7 :30 am.; main gate [ZONE 1] and personnel gate [ZONE 2]
After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.

If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.

If the second reading confirms an elevated temperature, DHS will instruct the individual that he/ she will not be allowed to enter the Project Site.

DHS will also instruct the individual to promptly notify his/her supervisor and his/her human resources (HR) representative and provide them 'vvith a copy of Annex A (attached hereto).

Planning:
• Require the development of an Infectious Disease Preparedness and Response Plan that -will include basic infection prevention measures (requiring the use of City of Santee - Fariita Ranch RDEIR
July 13, 2020

personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no more than 10 people including all-hands meetings and allhands lunches) communication and training and workplace controls that meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health Administration, Cal/ OSHA, California Department of Public Health or applicable local public health agencies.

The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The Agency should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.

D. The
Minimize
RDEIR Must Describe All Feasible Mitigation Measures That Can the Project's Significant and Unavoidable Environmental Impacts
A fundamental purpose of an EIR is to identify ways in which a proposed project's significant environmental impacts can be mitigated or avoided. Pub. Res. Code§§ 21002.l(a), 21061. To implement this statutory purpose, an EIR must describe any feasible mitigation measures that can minimize the project's significant environmental effects. PRC§§ 21002.l(a), 21100(b)(3); CEQA Guidelines§§ 15121(a), 15126.4(a).

If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has "eliminated or substantially lessened all significant effects on the environment where feasible" 1 and find that 'specific overriding economic, legal, social, technology or other benefits of the project outweigh the significant effects on the environment." 2 "A gloomy forecast of environmental degradation is of little or no value without pragmatic, concrete means to minimize the impacts and restore ecological equilibrium." Environmental Council of Sacramento v. City o f
Sacramento (2006) 142 Cal.App.4th 1018, 1039.
1 PRC§§ 21002; 21002.1, 21081; CEQA Guidelines§§ 15091, 15092(b)(2)(A). 2 PRC§§ 21002; 21002.1, 21081; CEQ,\ Guidelines§§ 15091, 15092(b)(2)(B).

City of Santee - Fanita Ranch RDEIR
July 13, 2020

1. The RDEIR Does Not ivlitigate The Prqject's Significant and Unavoidable Greenhouse Gas Emissions
The RDEIR concludes that the Project will have significant Greenhouse Gas (GHG) emissions impacts since the estimated total emissions from the Project's construction and operation and from mobile sources will exceed annual per capita emissions of 1.77 MT C02e, a threshold developed pursuant to the Sustainable Santee Plan or the data accumulated in the development of that plan. (RDEIR, p. 4.7-12.) The Project proposes to follow certain regulatory requirements to reduce operational emissions, and proposes GHG mitigation measures 1-6 to further reduce operational emissions, however, these are not the only feasible means of mitigating GHG emissions. (See RDEIR, pp. 4.7-15-19, 4.7-24-26.)
The Southern California Association of Government's ("SCAG") 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy ("2016 RTP /SCS") and the California Air Resources Board ("CARB") 2017 Climate Change Scoping Plan ("2017 Scoping Plan") outline numerous measures for reducing Project GHG emissions which the RDEIR fails to consider.3
In September 2008, SB 3 7 5 (Gov. Code § 65080(b) et seq.) was instituted to help achieve AB 32 goals through strategies including requiring regional agencies to prepare a Sustainable Communities Strategy ("SCS") to be incorporated into their Regional Transportation Plan ("RTP"). The RTP links land use planning with the regional transportation system so that the region can grow smartly and sustainably, while also demonstrating how the region will meet targets set by CARB that reduce the per capita GHG emission from passenger vehicles in the region. To comply with SB 375, SANDAG's 2050 RTP includes a Sustainable Communities Strategy to guide tl1e San Diego region toward meeting the state's regional GHG emissions reduction targets.4 As outlined in SANDAG's 2050 RTP Plan, the state's targets for the San Diego region are a 7 percent reduction, per capita, in greenhouse gas emissions from automobiles and light trucks by 2020 (compared with a 2005 baseline); and a 13 percent reduction by 2035. These targets were set by the CARB on September 23, 2010.

In April 2012, SCAG adopted its 2012-2035 RTP / SCS ("2012 RTP /SCS"), which proposed specific land use policies and transportation strategies for local governments 4 SANDAG 2050 Regional Transportation Plan (RTP), p. 2-11, https:/ /www.sandag.org/uploads/2050RTP /F2050rtp all.pdf (attached as Exhibit J\).

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to implement that will help the region achieve GHG emission reductions of 9 percent per capita in 2020 and 16 percent per capita in 2035. In April 2016, SCAG adopted the 2016-2040 RTP /SCS ("2016 RTP /SCS") 5
, which incorporates and builds upon the
policies and strategies in the 2012 RTP /SCS6
,that will help the region achieve GHG
emission reductions that would reduce the region's per capita transportation emissions by eight percent by 2020 and 18 percent by 2035. 7 Both SCAG's and SANDAG's RTP /SCS plans are based upon the same requirements outlined in CARB's 2017 Scoping Plan and SB 375. Commenters utilize SCAG's plan as an example of GHG emissions reduction measures that can be taken for the purpose of this Project.

For both the 2012 and 2016 RTP /SCS, SCAG prepared Program Environmental Impact Reports ("PEIR") that include Mitigation Monitoring and Reporting Programs ("MMRP") that list project-level environmental mitigation measures that directly and/ or indirectly relate to a project's GHG impacts and contribution to the region's GHG emissions. 8 These environmental mitigation measures serve to help local municipalities when identifying mitigation to reduce impacts on a project-specific basis that can and should be implemented when they identify and mitigate project-specific environmental impacts. 9
The sections below outline applicable land use policies, transportation strategies, and project-level GHG measures identified in the 2012 and 2016 RTP /SCS and PEIRs which the RDEIR should consider (note that tlus is not an exhaustive list):

Land Use and Transportation
• Providing transit fare discounts 10;
• Implementing transit integration strategies 11; and
• Anticipating shared mobility platforms, car-to-car communications, and automated velucle technologies.12
5 Co1llpare ivith SANDAG 2050 RTP.
6 SCAG (Apr. 2016) 2016 RTP/SCS, p. 69, 75-115, http://scagrtpscs.net/Documents/'J016/Einal/f2016RTPSCS.pdf (attached as Exhibit B).
7 Id., p. 8, 15, 153, 166.
8 Id., p. 116-124; see also SCAG 2012 RTP /SCS, supra fn. 38, p. 77-86. 9 SCAG 2012 RTP /SCS, supra fn. 38, p. 77; see also SCAG 2016 RTP /SCS, supra fn. 41, p. 115. 10 SCAG 2012 RTP /SCS, supra fn. 38, Tbls. 4.3 - 4.7; see also SCAG 2016 RTP /SCS, supra fn. 41, p. 75-114. 11 Jd.
12 Jd.

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GHG Emissions Goals 13
• Reduction in emissions resulting from a project through implementation of project features, project design, or other measures, such as those described in Appendix F of the State CEQA Guidelines, 14 such as:
o Potential measures to reduce wasteful, inefficient and unnecessary consumption of energy during constmction, operation, maintenance and/ or removal. The discussion should explain why certain measures were incorporated in the project and why other measures were dismissed. o The potential siting, orientation, and design to minimize energy consumption, including transportation energy.
o The potential for reducing peak energy demand.
o Alternate fuels (particularly renewable ones) or energy systems. o Energy conservation which could result from recycling efforts. • Off-site measures to mitigate a project's emissions.
• Measures that consider incorporation of Best Available Control Technology (BACT) during design, construction and operation of projects to minimize GHG emissions, including but not limited to:
o Use energy and fuel-efficient vehicles and equipment; o Deployment of zero- and/ or near zero emission technologies; o Use cement blended with the maximum feasible amount of flash or other materials that reduce GHG emissions from cement production; o Incorporate design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse; 13 SCAG 2012 RTP /SCS (Mar. 2012) Final PEIR MMRP, p. 6-2-6-14 (including mitigation measures ("MM") AQ3, BIO/OS3, CUL2, GE03, GHG15, HM3, LU14, N01, POP4, PS12, TR23, W9 [stating "�Jocal agencies can and should comply with the requirements of CEQA to mitigate impacts to [the environmental) as applicable and feasible ... [and) may refer to Appendi..'- G of this PEIR for examples of potential mitigation to consider when appropriate in reducing environmental impacts of future projects." (Emphasis added))), http://rtpscs.scag.ca.gov/Documents/ peir/2012/ final/ Final2012PEIR.pdf; see also id., Final PEIR Appendi.." G (including i\lIMs AQ1-23, GHG 1-8, PS1-104, TR1-83, Wl-62), http://rtpscs.scag.ca.gov/Documents/ peir /2012/ final/2012 fPEIR_AppendixG _Example J\Ieasures.pdf; SCAG 2016 RTP /SCS (Mar. 2016) Final PEIR MMRP, p. 11-63 (including MMs AIR-2(b), AIR-4(b), EN2(b), GHG-3(b), HYD-l(b), HYD-2(b), HYD-B(b), TRA-1(b), TRA-2(b), USS-4(b), USS-6(b)), http://scagrtpscs.net/Documen ts/2016 / peir/ final/2016 fPEIR_ExhibitB _J\ThIRP .pdf. 1 � CEQA Guidelines, Appendi..'- F-Energy Conservation, http://resources.ca.gov/ ceqa/ guidelines/ ,\ppendi..'-_F.html.

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o Incorporate design measures to reduce energy consumption and increase use of renewable energy;
o Incorporate design measures to reduce water consumption; o Use lighter-colored pavement where feasible;
o Recycle construction debris to maximum extent feasible; • Adopting employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, providing end-of-trip facilities, and telecommuting programs.
• Designate a percentage of parking spaces for ride-sharing vehicles or highoccupancy vehicles, and provide adequate passenger loading and unloading for those vehicles;
• Land use siting and design measures that reduce GHG emissions, including:
o Measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles, or reduce the carbon content of fuels, including constructing or encouraging construction of electric vehicle charging stations or neighborhood electric vehicle networks, or charging for electric bicycles; and
o Measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse.

Hydrology & Water Quality Goals
• Incorporate measures consistent in a manner that conforms to the standards set by regulatory agencies responsible for regulating water quality/ supply requirements, such as:
o Reduce exterior consumptive uses of water in public areas, and should promote reductions in private homes and businesses, by shifting to droughttolerant native landscape plantings(xeriscaping), using weather-based irrigation systems, educating other public agencies about water use, and installing related water pricing incentives.
o Promote the availability of drought-resistant landscaping options and provide information on where these can be purchased. Use of reclaimed water especially in median landscaping and hillside landscaping can and should be City of Santee - Fanita Ranch RDEIR
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implemented where feasible.
o Implement water conservation best practices such as low-flow toilets, waterefficient clothes washers, water system audits, and leak detection and repair. o Ensure that projects requiring continual dewatering facilities implement monitoring systems and long-term administrative procedures to ensure proper water management that prevents degrading of surface water and minimizes, to the greatest extent possible, adverse impacts on groundwater for the life of the project. Comply with appropriate building codes and standard practices including the Uniform Building Code.
o Maximize, where practical and feasible, permeable surface area in existing urbanized areas to protect water quality, reduce flooding, allow for groundwater recharge, and preserve ·wildlife habitat. Minimized new impervious surfaces to the greatest extent possible, including the use of in-lieu fees and off-site mitigation.
o Avoid designs that require continual dewatering where feasible. o Where feasible, do not site transportation facilities in groundwater recharge areas, to prevent conversion of those areas to impervious surface. • Incorporate measures consistent in a manner that conforms to the standards set by regulatory agencies responsible for regulating and enforcing water quality and waste discharge requirements, such as:
o Complete, and have approved, a Stormwater Pollution Prevention Plan ("SWPPP") before initiation of consttuction.
o Implement Best Management Practices to reduce the peak stormwater runoff from the project site to the maximum extent practicable. o Comply with the Caltrans stormwater discharge permit as applicable; and identify and implement Best Management Practices to manage site erosion, wash water runoff, and spill control.
o Complete, and have approved, a Standard Urban Stormwater Management Plan, prior to occupancy of residential or commercial sttuctures. o Ensure adequate capacity of the surrounding stormwater system to support stormwater mnoff from new or rehabilitated sttuctures or buildings.

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o Prior to construction within an area subject to Section 404 of the Clean Water Act, obtain all required permit approvals and certifications for construction within the vicinity of a watercourse ( e.g., Army Corps § 404 permit, Regional Waterboard § 401 permit, Fish & Wildlife§ 401 permit).
o Where feasible, restore or expand riparian areas such that there is no net loss of impervious surface as a result of the project.
o Install structural water quality control features, such as drainage channels, detention basins, oil and grease traps, filter systems, and vegetated buffers to prevent pollution of adjacent water resources by polluted runoff where required by applicable urban stormwater runoff discharge permits, on new facilities.
o Provide strnctural stormwater runoff treatment consistent with the applicable urban stormwater runoff permit where Caltrans is the operator, the statewide permit applies.
o Provide operational best management practices for street cleaning, litter control, and catch basin cleaning are implemented to prevent water quality degradation in compliance with applicable stormwater runoff discharge permits; and ensure treatment controls are in place as early as possible, such as during the acquisition process for rights-of-way, not just later during the facilities design and construction phase.
o Comply with applicable municipal separate storm sewer system discharge permits as well as Caltrans' stormwater discharge permit including long-term sediment control and drainage of roadway rnnoff.
o Incorporate as appropriate treatment and control features such as detention basins, infiltration strips, and porous paving, other features to control surface rnnoff and facilitate groundwater recharge into the design of new transportation projects early on in the process to ensure that adequate acreage and elevation contours are provided during the right-of-way acquisition process.
o Design projects to maintain volume of runoff, where any downstream receiving water body has not been designed and maintained to accommodate the increase in flow velocity, rate, and volume without impacting the water's beneficial uses. Pre-project flow velocities, rates, volumes must not be City of Santee - Farlita Ranch RDEIR
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exceeded. This applies not only to increases in stormwater runoff from the project site, but also to hydrologic changes induced by flood plain encroachment. Projects should not cause or contribute to conditions that degrade the physical integrity or ecological function of any downstream receiving waters.
o Provide culverts and facilities that do not increase the flow velocity, rate, or volume and/ or acquiring sufficient storm drain easements that accommodate an appropriately vegetated earthen drainage channel.
o Upgrade stormwater drainage facilities to accommodate any increased runoff volumes. These upgrades may include the construction of detention basins or structures that will delay peak flows and reduce flow velocities, including expansion and restoration of wetlands and riparian buffer areas. System designs shall be completed to eliminate increases in peak flow rates from current levels.
o Encourage Low Impact Development ("LID") and incorporation of natural spaces that reduce, treat, infiltrate and manage stormwater runoff flows in all new developments, where practical and feasible.
• Incorporate measures consistent with the provisions of the Groundwater Management Act and implementing regulations, such as:
o For projects requiring continual dewatering facilities, implement monitoring systems and long-term administrative procedures to ensure proper water management that prevents degrading of surface water and minimizes, to the greatest extent possible, adverse impacts on groundwater for the life of the project, Construction designs shall comply witl1 appropriate building codes and standard practices including the Unifo1m Building Code. o Maximize, where practical and feasible, permeable surface area in existing urbanized areas to protect water quality, reduce flooding, allow for groundwater recharge, and preserve wildlife habitat. Minimize to the greatest extent possible, new impervious surfaces, including the use of in-lieu fees and off-site mitigation.
o Avoid designs tl1at require continual dewatering where feasible. o A void construction and siting on groundwater recharge areas, to prevent City of Santee - Fartita Ranch RDEIR
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•
conversion of those areas to impervious surface.
o Reduce hardscape to the extent feasible to facilitate groundwater recharge as appropriate.

Incorporate mitigation measures to ensure compliance with all federal, state, and local floodplain regulations, consistent with the provisions of the National Flood Insurance Program, such as:
o Comply with Executive Order 11988 on Floodplain Management, which requires avoidance of incompatible floodplain development, restoration and preservation of the natural and beneficial floodplain values, and maintenance of consistency with the standards and criteria of the National Flood Insurance Program.
o Ensure that all roadbeds for new highway and rail facilities be elevated at least one foot above the 100-year base flood elevation. Since alluvial fan flooding is not often identified on FEMA flood maps, the risk of alluvial fan flooding should be evaluated and projects should be sited to avoid alluvial fan flooding.

Delineation of floodplains and alluvial fan boundaries should attempt to account for future hydrologic changes caused by global climate change.

Transportation, Traffic, and Safety
• Institute teleconferencing, telecommute and/ or flexible work hour programs to reduce unnecessary employee transportation.
• Create a ride-sharing program by designating a certain percentage of parking spaces for ride sharing vehicles, designating adequate passenger loading and unloading for ride sharing vehicles, and providing a web site or message board for coordinating rides.
• Provide a vanpool for employees.
• Provide a Transportation Demand Management (TDM) plan containing strategies to reduce on-site parking demand and single occupancy vehicle travel.

The TDM shall include strategies to increase bicycle, pedestrian, transit, and carpools/vanpool use, including:
o Inclusion of additional bicycle parking, shower, and locker facilities that exceed the requirement.

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o Direct transit sales or subsidized transit passes.
o Guaranteed ride home program.
o Pre-tax commuter benefits (checks).
o On-site car-sharing program (such as City Car Share, Zip Car, etc.). o On-site carpooling program.
o Distribution of info1matio11 concerning alternative transportation options. o Parking spaces sold/leased separately.
o Parking management strategies; including attendant/valet parking and shared parking spaces.
• Promote ride sharing programs e.g., by designating a certain percentage of parking spaces for high-occupancy vehicles, providing larger parking spaces to accommodate vans used for ride-sharing, and designating adequate passenger loading and unloading and waiting areas.
• Encourage the use of public transit systems by enhancing safety and cleanliness on vehicles and in and around stations, providing shuttle service to public transit, offering public transit incentives and providing public education and publicity about public transportation services.
• Build or fund a major transit stop within or near transit development upon consultation with applicable CTCs.
• Work with the school districts to improve pedestrian and bike access to schools and to restore or expand school bus service using lower-emitting vehicles. • Purchase, or create incentives for purchasing, low or zero-emission vehicles. • Provide the necessary facilities and infrastructure to encourage the use of low or zero-emission vehicles.
• Promote ride sharing programs, if determined feasible and applicable by the Lead Agency, including:
o Designate a certain percentage of parking spaces for ride-sharing vehicles. o Designate adequate passenger loading, unloading, and waiting areas for ridesharing vehicles.

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o Provide a web site or message board for coordinating shared rides. o Encourage private, for-profit community car-sharing, including parking spaces for car share vehicles at convenient locations accessible by public transit. o Hire or designate a rideshare coordinator to develop and implement ridesharing programs.
• Support voluntary, employer-based trip reduction programs, if determined feasible and applicable by the Lead Agency, including:
o Provide assistance to regional and local ridesharing organizations. o Advocate for legislation to maintain and expand incentives for employer ridesharing programs.
o Require the development of Transportation Management Associations for large employers and commercial/ industrial complexes.
o Provide public recognition of effective programs through awards, top ten lists, and other mechanisms.
• Implement a "guaranteed ride home" program for those who commute by public transit, ridesharing, or other modes of transportation, and encourage employers to subscribe to or support the program.
• Encourage and utilize shuttles to serve neighborhoods, employment centers and major destinations.
• Create a free or low-cost local area shuttle system that includes a fixed route to popular tourist destinations or shopping and business centers. • Work with existing shuttle service providers to coordinate tl1eir services. • Facilitate employment opportunities tl1at minimize the need for private vehicle trips, such as encourage telecommuting options with new and existing employers, through project review and incentives, as appropriate. • Organize events and workshops to promote GHG-reducing activities. • Implement a Parking Management Program to discourage private vehicle use, including:
o Encouraging carpools and vanpools with preferential parking and a reduced City of Santee - Fanita Ranch RDEIR
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parking fee.
o Institute a parking cash-out program or establish a parking fee for all singleoccupant vehicles.

Utilities & Service Systems
• Integrate green building measures consistent with CALGreen (Title 24, part 11), U.S. Green Building Council's Leadership in Energy and Environmental Design, energy Star Homes, Green Point Rated Homes, and the California Green Builder Program into project design including, but not limited to the following:
o Reuse and minimization of construction and demolition (C&D) debris and diversion of C&D waste from landfills to recycling facilities. o Inclusion of a waste management plan that promotes maximum C&D diversion.
o Development of indoor recycling program and space.
o Discourage exporting of locally generated waste outside of the SCAG region during the construction and implementation of a project. Encourage disposal within the county where the waste originates as much as possible. Promote green technologies for long-distance transport of waste ( e.g., clean engines and clean locomotives or electric rail for waste-by-rail disposal systems) and consistency with SCAQMD and 2016 RTP /SCS policies can and should be required.
o Develop ordinances that promote waste prevention and recycling activities such as: requiring waste prevention and recycling efforts at all large events and venues; implementing recycled content procurement programs; and developing opportunities to divert food waste away from landfills and toward food banks and composting facilities.
o Develop alternative waste management strategies such as composting, recycling, and conversion technologies.
o Develop and site composting, recycling, and conversion technology facilities that have minimum environmental and health impacts.
o Require the reuse and recycle construction and demolition waste (including, but not limited to, soil, vegetation, concrete, lumber, metal, and cardboard).

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o Integrate reuse and recycling into residential industrial, institutional and commercial projects.
o Provide recycling opportunities for residents, the public, and tenant businesses.
o Provide education and publicity about reducing waste and available recycling services.
o Implement or expand city or county-wide recycling and composting programs for residents and businesses. This could include extending the types of recycling services offered ( e.g., to include food and green waste recycling) and providing public education and publicity about recycling services ..

As the above tables indicate, the RDEIR fails to mention or demonstrate consistency 'vvith all the above listed measures and strategies of the SCAG RTP /SCS Plan. Thus, the RDEIR fails to demonstrate that all feasible mitigation measures were considered.

To the extent that the Project fails to comply with the measures mentioned above, the Project RDEIR has failed to mitigate GHG emissions to the extent feasible.

Furthermore, the RDEIR fails to integrate or consider many GHG reduction measures outlined in the California Air Pollution Control Officers Association (CAPCOA) August 2010 Report which the South Coast Air Quality Management District has recognized as a "comprehensive guidance document for quantifying the effectiveness of GHG mitigation measures."15
The RDEIR must analyze the effectiveness and feasibility of a number of greenhouse gas mitigation measures proposed by the CAPCOA Report, including greenhouse gas mitigation measures for building energy use, lighting, alternative energy generation, land use, landscaping, waste, vegetation, construction and miscellaneous measures including carbon sequestration or other off-site mitigation measures.

E. The RDEIR Improperly Defers Formulation and Imposition of Performance-Based Mitigation Measures
CEQA mitigation measures proposed and adopted into an environmental impact report are required to describe what actions that will be taken to reduce or avoid an l5 South Coast Air Quality Management District (2019) "Greenhouse Gases, accessed on March 22, 2019, available at https: //www.aqmd.gov/home /rules-compliance/ ceqa /air-quality-analnis-handbook/mitiga tion-measures-and-controlefficiencies /greenhouse-gases (attached as Exhibit C); California Air Pollution Control Officers Association (CAPCOA) August 2010 Report (attached as Exhibit D).

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environmental impact. (CEQA Guidelines§ 15126.4(a)(l)(B) [providing "[f]ormulation of mitigation measures should not be deferred until some future time."].) While the same Guidelines section 15126.S(a)(l)(B) acknowledges an exception to the rule against deferrals, but such exception is narrowly proscribed to situations where "measures may specify performance standards which would mitigate the significant effect of the project and which may be accomplished in more than one specified way." (Id.) Courts have also recognized a similar exception to the general rnle against deferral of mitigation measures where the performance criteria for each mitigation measure is identified and described in the EIR. (Sacramento Old Ciry Ass'n v.

Ciry Council (1991) 229 Cal.App.3d 1011.)
Impermissible deferral can occur when an EIR calls for mitigation measures to be created based on future studies or describes mitigation measures in general terms but the agency fails to commit itself to specific performance standards. (Preserve Wild Santee v. Ciry of Santee (2012) 210 Cal.App.4th 260,281 [city improperly deferred mitigation to butterfly habitat by failing to provide standards or guidelines for its management]; San Joaquin &ptor Rescue Center v. Counry of Merced (2007) 149 Cal.App.4th 645, 671 [EIR failed to provide and commit to specific criteria or standard of performance for mitigating impacts to biological habitats]; see also Cleveland Nat'! Forest Found. v San Diego Ass'n of Gov'ts (2017) 17 Cal.App.5th 413,442 [generalized air quality measures in the EIR failed to set performance standards]; California Clean Energy Comm. v Ciry of Woodland (2014) 225 Cal.App.4th 173, 195 [ agency could not rely on a future report on urban decay vvith no standards for determining whether mitigation required]; POET, LLC v. State Air Resources Bd. (2013) 218 Cal.App.4th 681, 740 [agency could not rely on future rulemak.ing to establish specifications to ensure emissions of nitrogen oxide would not increase because it did not establish objective performance criteria for measuring whether that goal would be achieved]; Grqy v. Counry of Madera (2008) 167 Cal.App.4th 1099, 1119 [rejecting mitigation measure requiring replacement water to be provided to neighboring landowners because it identified a general goal for mitigation rather than specific performance standard]; Endangered Habitats League, Inc. v. Counry o f Orange (2005) 131
Cal.App.4th 777, 794 [requiring report without established standards is impermissible delay].)
In addition, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential City of Santee - Fanita Ranch RDEIR
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impacts and the effect of regulatory compliance. In Californians for Alternatives to Toxics v.

Department o
f Food & Agrt"c. (2005) 136 Cal. App. 4th 1, the court set aside an EIR for a statewide crop disease control plan because it did not include an evaluation of the risks to the environment and human health from the proposed program but simply presumed that no adverse impacts would occur from use of pesticides in accordance ·with the registration and labeling program of the California Department of Pesticide Regulation. See also Ebbetts Pass Forest LVt7atch v Department of Forestry & Fire Protection (2008 ) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain herbicides in general did not excuse failure to assess effects of their use for specific timber harvesting project).

First, the RDEIR identifies a potentially significant hazards and hazardous materials impact relating to accidental release of hazardous materials from an existing groundwater well on the Project site and provides mitigation measure HAZ-1 to reduce that impact to less than significant. However, no plan is provided for the groundwater well abandonment other than a provision that "the applicant shall provide documentation to the City of Santee Development Services Department showing the proper abandonment. .. in accordance \vith the County of San Diego's Well Ordinance." (RDEIR, p. 1-53.) The RDEIR defers formulation of a well abandonment plan until after certification of the EIR. Mere statements of future compliance with regulatory requirements is inadequate and deferred mitigation.

Second, the RDEIR defers formulation of noise impact mitigation measures NOI-4 and NOI-8. NOI-4 proposes a nighttime noise sound management plan that relies upon a sound management plan for the Project that is deferred until such time it will be "included in the construction documents"; and the sound management plan lacks any objective performance criteria and defers any details as would be "deemed necessary by a qualified acoustical engineer, to minimize noise at nearby receptors." (RDEIR, pp. 1-58-59 .) Any details are deferred until after certification of the EIR.

Regarding mitigation measure NOI-8 for vibration, the RDEIR defers any detail and formulation of a plan to such time as a "qualified acoustician [identifies] best management practices to be implemented ... to reduce vibration levels to below 80 vibration decibels at the nearest residence." (RDEIR, p. 1-61.) Once again, there is no objective performance criteria for a plan, nor is there any plan to reduce vibration noise other than stating best practices will be utilized.

Lastly, the RDEIR defers mitigation of significant impacts to aesthetics. The RDEIR City of Santee - Fanita Ranch RDEIR
July 13, 2020

admits that the Project would involve "extensive excavation and grading into the native terrain" causing significant impacts to aesthetics. (DEIR, p. 4.1-55.) But, the RDEIR fails to demonstrate how the extensive excavation and grading required would conform to the City's hillside development guidelines, or how the methods or areas chosen for grading and excavation will minimize to maximum extent feasible the damage to the hills, canyons, and outcroppings. The RDEIR simply states it plans to comply with municipal code and General Plan guidelines, but that fails to demonstrate consistency with the goals and objectives of the General Plan. (See RDEIR, p. 4.1-56.) The DEIR needs to be amended to include specific noise mitigation measures based on objective performance criteria that are not deferred until after the EIR is already certified.

F. Discussion of Mitigation Measures to Reduce Impacts of New Utilities Infrastructure is Inadequate and Not Based on Substantial Evidence An EIR must propose and describe mitigation measures to minimize the significant environmental effects identified in the EIR. Cal. Pub. Res. Code §§ 21002.1 (a), 21100(b)(3); CEQA Guidelines§ 15126.4. CEQA Guidelines§ 15126.4 requires that mitigation measures be identified for each significant effect described in the EIR.

The substantial evidence test applies to any conclusions or findings in the EIR's analysis of a topic. See, e.g., Residents Against Specific Plan 380 v. Coimry of Riverside (2017) 9 Cal. App 5th 941, 968. Substantial evidence is defined as "enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached." CEQA Guidelines §15384(a); Laurel Heights ImprovementAss'n v. Regents of Univ. of Cal. (1988) 47 Cal. App. 3d 376,393,409; Save Round VallryA!liance v. Counry of Irryo (2007) 157 Cal. App. 4th 1437, 1446. Substantial evidence includes facts, reasonable assumptions predicated on facts, and expert opinion supported by facts, but does not include argument, speculation, or unsubstantiated opinion. Cal. Pub.

Res. Code §§ 21080(e), 21082.2(c).

Here, the RDEIR identifies potentially significant impacts relating to the construction of infrastructure for the proposed Project, yet fails to develop any mitigation measures for these impacts. (RDEIR, p. 4.17-21.) Instead, without any analysis whatsoever, the RDEIR states that mitigation measures developed for other resource topics will also ameliorate the impacts of new infrastmcture to less than significant and no additional City of Santee - Fanita Ranch RDEIR
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Page24of31
mitigation is required. Even if that could be the case, the RDEIR does not include any fact-based and individualized analysis of how other mitigation measures can reduce these impacts to less than significant. The RDEIR needs to be amended to either include additional mitigation measures that cover these impacts, or else analyze using substantial evidence how mitigation measures for other resource topics apply to reduce the level of the impact for a different topic.

II. THE PROJECT VIOLATES THE STATE PLANNING AND ZONING

LAW AS WELL AS THE CITY'S GENERAL PLAN
A. Background Regarding the State Planning and Zoning Law Each California city and county must adopt a comprehensive, long-term general plan governing development. (Napa Citizensfor Honest Gov. v. Napa County Bd. of Supervisors (2001) 91 Cal. App.4th 342, 352, citing Gov. Code§§ 65030, 65300.) The general plan sits at the top of the land use planning hierarchy (See De Vita v. County of Napa (1995) 9 Cal. App. 4th 763, 773), and serves as a "constitution" or "charter" for all future development. (Lesher Communications, Inc. v. City of LT1'a!nut Creek (1990) 52 Cal.

App. 3d 531, 540.)
General plan consistency is "the linchpin of California's land use and development laws; it is the principle which infused the concept of planned growth with the force of law." (See Debottan· v. Norco City Council (1985) 171 Cal. App. 3d 1204, 1213.) State law mandates two levels of consistency. First, a general plan must be internally or "horizontally" consistent: its elements must "comprise an integrated, internally consistent and compatible statement of policies for the adopting agency." (See Gov.

Code§ 65300.5; Sierra Club v. Bd. o
f Supervisors (1981) 126 Cal. App. 3d 698, 704.) A
general plan amendment thus may not be internally inconsistent, nor may it cause the general plan as a whole to become internally inconsistent. (See De Vita, 9 Cal. App. 4th at 796 fn. 12.)
Second, state law requires "vertical" consistency, meaning that zoning ordinances and other land use decisions also must be consistent with the general plan. (See Gov.

Code§ 65860(a)(2) �and uses authorized by zoning ordinance must be "compatible with the objectives, policies, general land uses, and programs specified in the [general] plan."]; see also Neighborhood Action Group v. County of Calaveras (1984) 156 Cal. App. 3d 1176, 1184.) A zoning ordinance that conflicts "\vith the general plan or impedes achievement of its policies is invalid and cannot be given effect. (See Lesher, City of Santee - Fan.ita Ranch RDEIR
July 13, 2020

52 Cal. App. 3d at 544.)
State law requires that all subordinate land use decisions, including conditional use permits, be consistent with the general plan. (See Gov. Code§ 65860(a)(2); Neighborhood Action Group, 156 Cal. App. 3d at 1184.)
A project cannot be found consistent ·with a general plan if it conflicts with a general plan policy that is "fundamental, mandatory, and clear," regardless of whether it is consistent with other general plan policies. (See Endangered Habitats League v. Counry of Orange (2005) 131 Cal. App. 4th 777, 782-83; Families Unefraid to Uphold Rural El Dorado Counry v. Bd. of Supervisors (1998) 62 Cal. App. 4th 1332, 1341-42 ["FUTURE"].) Moreover, even in the absence of such a direct conflict, an ordinance or development project may not be approved if it interferes with or frustrates the general plan's policies and objectives. (See Napa Citizens, 91 Cal. App. 4th at 378-79; see also Lesher, 52 Cal.

App. 3d at 544 [zoning ordinance restricting development conflicted with growthoriented policies of general plan].) B. The Project is Inconsistent with the City's General Plan Housing Element
Since 1969, California has required that all local governments ( cities and counties) adequately plan to meet the housing needs of everyone in the community. California's local governments meet this requirement by adopting housing plans as part of their "general plan" (also required by the state). General plans serve as the local government's "blueprint" for how the city and/ or county will grow and develop and include seven elements: land use, transportation, conservation, noise, open space, safety, and housing. The law mandating that housing be included as an element of each jurisdiction's general plan is known as "housing-element law." California's housingelement law acknowledges that, in order for the private market to adequately address the housing needs and demand of Californians, local governments must adopt plans and regulatory systems that provide opportunities for (and do not unduly constrain), housing development. As a result, housing policy in California rests largely on the effective implementation of local general plans and, in particular, local housing elements.

Existing law requires the housing element to contain a program that sets a 5-year schedule of actions to implement the goals and objectives of the housing element under RHNA allocations. Existing law also requires cities and counties to review and revise their housing elements at least every 5 years for compliance. (Gov. Code § City of Santee - Fanita Ranch RDEIR
July 13, 2020

65584.)
The City of Santee General Plan includes the following objectives and policies in its Housing Element:
• Objective 3.0: Expand affordable housing options within Santee; • Objective 5.0: Provide a wide range of housing types; and • Program 10: Facilitate affordable housing development.16 The General Plan Housing Element also lists the City's quantified housing objectives per the RHNA allocation assessment for Santee, with requirements to build, through 2021, 457 units for extremely low income, 457 units for very low income, 694 units for low income, 642 units for moderate income, and 1,410 units for above moderate income.17 Per SANDAG's latest available RHNA progress report, the City of Santee is woefully behind schedule in units permitted for very low, low, and moderate income housing.1
8 The City's plan to construct approximately 3,000 housing units, and not include a1!Y affordable housing units on the Project site is not only unconscionable, it is obviously inconsistent with the City's own General Plan. Fanita Ranch is one of the largest undeveloped tracts of land in the City and an easy opportunity for the City to make some progress toward its RHNA allocation from SANDAG. The City should not only seriously consider including a fair share of affordable housing on the Project site, it needs to do so if it has any hope of meeting its RHNA obligations under the state housing law and to comply with the City's General Plan.

C. The Project is Inconsistent with the City's General Plan Conservation Element and the San Diego Multiple Species Conservation Program The City of Santee's General Plan - Conservation Element19 stipulates the following objectives and policies applicable to the Project:
16 Fanita Ranch General Plan - Housing Element, pp. 6-8, 6-12, and 6-10. Available at https://www.citvofsanteeca.gov/home/showdocument?id=8551 (attached as Exhibit E). 17 Id. at 4-l.
lB SANDAG 2017 Regional Housing Progress Report, p. 37. Available at https://www.sandag.org/uploads/publicationid/publicationid 2132 22605.pdf (attached as Exhibit F). 19 City of Santee, General Plan - Conservation Element, available at https://www.cityofsanteeca.gov/home/showdocument?id=7199 (attached as Exhibit G).

City of Santee - Fanita Ranch RDEIR
July 13, 2020

• Objective 1.020:
o Policy 1.1: The City shall encourage significant natural landforms to be maintained during development whenever possible.
o Policy 1.2 The City should encourage, through the environmental review minimize
process, the preservation of hillsides with steep slopes as appropriate to danger from landslides and mudslides, as well as to protect key visual resources.
o Policy 1.3 To protect and wisely manage hillsides and topographic resources, the City shall use the following hillside development guidelines:

Percent Natural Slope Guideline Less than 10% This is not a hillside condition. Conventional grading techniques are acceptable. 10% - 19.9% Development with grading will occur in this zone, but existing landforms should retain their natural character. Padded building sites are permitted on these slopes, but contour grading, split level architectural prototypes, with stacking and clustering are expected. 20% and over Special hillside grading, architectural and site design techniques are expected, and architectural prototypes should conform to the natural landform Compact development plans should be used to minimize grading footprints.
• Objective 2.021: Protect floodways to reduce flood hazards, protect biological resources and preserve the aesthetic quality along water corridors. o Policy 2.1 The City shall encourage the protection of the San Diego River Corridor and all other City water corridors to reduce flood hazards, protect significant biological resources and scenic values, and to provide for appropriate recreational uses.
o Policy 2.2 The City should promote open space in conjunction with other appropriate land uses along the San Diego River corridor and other water corridors found in the City.
• Objective 10.0: Preserve significant natural resources such as mineral deposits, biological resources, watercourses, groundwater, hills, canyons, and major rock 20 Id. at 6-18.
21 Id. at 6-19.

City of Santee - Fan.ita Ranch RDEIR
July 13, 2020

outcroppings such as part of a Citywide open space system. o Policy 10.2: The City should encourage the preservation of significant natural features, such as watercourses, ridgelines, steep canyons, and major rock outcroppings through the Development Review process.

The Fanita Ranch Specific Plan area is located within the 1998 San Diego Multiple Species Conservation Plan (San Diego "MSCP") area22, and hence is subject to that plan, as well as the draft Fanita Ranch Subarea MSCP which has yet to be published or finalized. The MSCP is a regional, landscape-level plan to preserve San Diego's unique, native habitats and wildlife for future generations. Projects and subarea plans within the MSCP should support the goals and objectives of the 1998 umbrella plan and should also address the conservation needs of any sensitive species federally or State listed or proposed since the MSCP was completed.

The U.S. Fish and Wildlife Service ("UFWS") and the California Department of Fish and Wildlife ("CDFW") both submitted a comment letter on the Applicant's previous attempt in 2016 to certify an EIR for this Project, and their concerns remain valid to the RDEIR.23 As proposed, the Project fails to comply vvith the San Diego MSCP and the General Plan's Conservation Element for at least the following reasons:
• The Project's fragmented and broad footprint across Fanita Ranch; • The Project's fragmented reserve areas;
• The reserve design fails to adequately minimize edge effects; • The Project should be located closer and concentrated near existing development;
• The Project fails to minimize damage to the habitats of multiple species, including but not limited to, the coastal cactus wren, Quino checkerspot butterfly, Hermes copper butterfly, and western spadefoot toad; • The Project fails to expand acreages of reserve and habitats safe from construction or disturbance, edge effects, fires, or fragmentation as designed to adequately protect biological resources;
22 San Diego MSCP, available at
https: // \V\V\V.sandiegocount:v
.gov /content/dam /sdc /pds /mscp / docs /SCl\ISCP /Finali\ ISCPProgramPlan.pd f (attached as Exhibit H).
23 UF\v'S and CDFW December 20, 2016 Comment Letter on the Proposed Fanita Ranch Project (attached as Exhibit I).

City of Santee - Fanita Ranch RDEIR
July 13, 2020
Page29of31
• The Project's proposed development and reserve areas are not fully buffered from each other and all buffer areas should be unlit, and areas adjacent to development or roadways should have minimal lighting shielded away from buffer zones and natural areas;
• The Project does not attempt to adequately minimize the use of roadways, or roadways crossing habitat or reserve areas;
• Recreational trails do not utilize wildlife corridor road crossings to reduce the total extent of development infrastructure and increase corridor crossing function and size for wildlife;
• The Project does not minimize and mitigate impacts to impacted species to the maximum extent feasible with a goal of no net loss of sensitive biological resources; and
• Vernal pools and their watersheds are not avoided to the maximum extent feasible. High-function vernal pools and their watersheds should be avoided and conserved. Moderate function vernal pools on site should be restored or enhanced.

With respect to Objectives 1.0 and 10.0 of the General Plan - Conservation Element, the Project site consists mostly of canyons, hillsides, ridgelines, rock outcroppings, and other similar natural features. The RDEIR admits that the Project would involve "extensive excavation and grading into the native terrain." (RDEIR, p. 4.1-55.) The RDEIR fails to demonstrate how the extensive excavation and grading required would conform to tl1e City's hillside development guidelines, or how the metl1ods or areas chosen for grading and excavation will minimize to maximum extent feasible the damage to the hills, canyons, and outcroppings. The RDEIR simply states it plans to comply with municipal code and General Plan guidelines, but that fails to demonstrate consistency with the goals and objectives of the General Plan. (See RDEIR, p. 4.1-56.) D. The Vesting Tentative Map Fails To Comply With The State Subdivision Map Act
The Subdivision Map Act, Government Code section 66410, et seq, ("Subdivision Map Act" or "Act") requires local agencies to review and approve all land subdivisions.

The Act regulates both the process for approving subdivisions and sets substantive requirements for approval of land subdivisions. The Act requires that a local agency City of Santee - Fanita Ranch RDEIR
July 13, 2020
Page30of31
deny approval of a land subdivision, referred to as a tentative map or a parcel map, if it makes a determination that "the proposed map is not consistent with applicable general and specific plans" or that "the design or improvements of the proposed subdivision is not consistent with the applicable general and specific plans." Cal. Gov.

Code,§ 66474(a-b).

Here, the applicant applies for and the Project requires a Vesting Tentative Map.

However, the Project is inconsistent with all the aforementioned goals, policies, or objective's the City's General Plan, therefore any approval of the Vesting Tentative Map violates the Subdivision Map Act.

Ill. CONCLUSION
Commenters request that the City revise and recirculate the Project's environmental impact report to address the aforementioned concerns. If the City has any questions or concerns, feel free to contact my Office.

Sincerely,
Mitchell �� M. Tsai
Attorneys for Southwest Regional Council of Carpenters
Attached:

SANDAG 2050 Regional Transportation Plan, available at
https://'vvww.sandag.org/uploads/2050RTP /F2050rtp all.pdf (attached as Exhibit A); SCAG 2016 Regional Transportation Plan/Sustainable Communities Strategy, available at http://scagrtpscs.net/Documents /2016 /final/ f2016RTPSCS.pdf ( attached as Exhibit B);
South Coast Air Quality Management District (2019) "Greenhouse Gases, accessed on March 22, 2019, available at h ttps: // W'vV'vV. aqmd.gov /home /rulescompliance / ceqa / air-quality-analysis-handbook/mitigation-measures-and-controlef ficiencies /greenhouse-gases (attached as Exhibit C); California Air Pollution Control Officers Association (August 2010) "Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures," accessed March 22, City of Santee - Fanita Ranch RDEIR
July 13, 2020

2020, available at https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/mitigation-measures-and-control-efficiencies/quantifyinggreenhouse-gas-rnitigation-measures.pdf?sfv rsn=O (attached as Exhibit D);
Fanita Ranch General Plan - Housing Element, available at https://www.cityofsanteeca.gov/home/showdocument?id=8551 (attached as Exhibit E);
SANDAG 2017 Regional Housing Progress Report, p. 37, available at http s: // \VvVW. s andag. org/ uploads /publica tionid /publica tionid 213 2 2260 5 .pdf (attached as Exhibit F);
City of Santee, General Plan - Conservation Element, available at https: //www.cityofsanteeca.gov/home/showdocument?id =7199 (attached as Exhibit G);
San Diego Multiple Species Conservation Program, available at https: //wvVvv.sandiegocounty.gov / content/ dam/sdc/pds /mscp / docs /SCMSCP /Fina llvISCPProgramPlan.pdf (attached as Exhibit H); and
United States Fish and Wildlife Se1-vice and California Department of Fish and Wildlife December 20, 2016 Comment Letter on the Proposed Fanita Ranch Project (attached as Exhibit I).

City Response to Late Comments
Submitted by Southwest Regional
Council of Carpenters
Response to Late Comments Submitted by
Southwest Regional Council of Carpenters
The City has considered the environmental issues raised in this comment letter and responds as follows:

1. The Draft Revised EIR Was Properly Noticed
The comment requests that the City continue the EIR's comment deadline due to the closure of many public facilities to the general public due to concerns regarding COVID-19 cases. The Notice of Availability of the Draft EIR was released on May 29, 2020. Prior to the release of the Notice of Availability, on April 22, 2020, the Governor issued Executive Order N-54-20 ("Executive Order"), which suspended for a period of 60 days (i.e., until June 21, 2020) the effect of certain public filing, posting, notice and public access requirements contained in CEQA and the CEQA Guidelines. The Executive Order provides in relevant part:

The public filing, posting, notice, and public access requirements set forth in Public Resources Code sections 21092.3 and 21152, and California Code of Regulations, Title 14, sections 15062(c)(2) and (c)(4); 15072(d); 15075 (a),(d), and (e); 15087(d); and 15094(a), (d), and (e), for projects undergoing, or deemed exempt from, California Environmental Quality Act review, are suspended for a period of 60 days. This suspension does not apply to provisions governing the time for public review. [emphasis added].

Thus, as a result of the temporary suspension of Public Resources Code Section 21092.3 and CEQA Guidelines Section 15087(d), the City's Notice of Availability was not required to be posted in the office of the County Clerk and the County Clerk was not required to post such notice within 24 hours of receipt. Despite the Executive Order's suspension, the City did file the Notice of Availability with the San Diego County Clerk on May 28, 2020 and the County Clerk posted the Notice of Availability on June 3, 2020. Thus, while not required, the City did notify the public in accordance with CEQA Guidelines Section 15087(d). The County Clerk did not post the Notice of Availability within 24 hours but did post it within five days of the start of the public review period, giving the public notice of the availability of the EIR.

The comment further claims that CEQA's public notice requirements were not satisfied because the City's Department of Development Services ("Department") website notes the EIR may only be viewed in the Department by appointment only, aside from electronic access and that the EIR was not available for curbside pickup from the San Diego County library in the City. The City in fact went above and beyond to provide public notice given the constraints due to the closure of public facilities in response to COVID-19. The Governor's Executive Order specifically provided that during the 60- day suspension period, if a lead agency, responsible agency, or project applicant 60139.18028\33290250. l
"would otherwise have been required to publicly post or file materials concerning the project with any county clerk, or otherwise make such materials available to the public," they must, as applicable:
• Post materials on the relevant agency's or applicant's public-facing website for the same period of time that physical posting would otherwise be required;
• Submit all materials electronically to the State Clearinghouse CEQAnet Web Portal; and
• Engage in outreach to any individuals and entities known by the lead agency, responsible agency, or project applicant to be parties interested in the project in the manner contemplated by CEQA and the State CEQA Guidelines.

The City satisfied the noticing requirements of the Executive Order by submitting the Notice of Availability and the EIR to the State Clearinghouse, posting all materials on the City's website, and providing notice directly to requesting parties in accordance with CEQA and the CEQA Guidelines. Additionally, to facilitate access to those that may not be able to access the document online, the City provided for viewing in the Department as well as the City Clerk's office and the City Manager's office by appointment only. By doing so, the City facilitated public access while taking care to address health concerns for both the public and City staff. The City has therefore provided an adequate public review period in compliance with CEQA and the Governor's Executive Order. There is no requirement under CEQA to extend or suspend public review periods due to the pandemic.

2. The Project Description Complies with CEQA
The comment argues that the EIR does not adequately describe the proposed project because it fails to identify a specific project proposal for construction on the project site.

The comment notes one plan proposes a school and another does not and questions how much commercial space will be constructed.

The EIR analyzes a community within the City consisting of approximately 2,949 housing units under the preferred land use plan with school, or 3,008 units under the land use plan without school. (EIR, Section 3.3.) [emphasis added] The preferred land use plan with school is the project for purposes of CEQA. As described in detail in the project description, however, because the City and HomeFed Fanita Rancho, LLC ("applicant") do not control whether the site would be acquired by the Santee School District for use as a school, the underlying land use for the School Overlay site is Medium Density Residential. If the school site is not acquired for a permitted educational use within two years of the filing of the Final Map for the phase in which the school site is located, the underlying Medium Density Residential land use designation would be implemented, and the maximum total number of units permitted 60139.18028\33290250.1
on the project site would be increased by 59 units to 3,008 units. (EIR, Section 3.3.1.5.) The project description thus identified a specific proposed project and did not present a set of significantly different alternative proposals. The project consists of the Fanita Ranch Specific Plan, which includes a School Overlay designation. The land use plan without school would only occur if the school overlay site was not acquired for a permitted educational use within two years of the filing of the Final Map. In that case, the underlying Medium Density Residential zone would apply. The EIR analyzed development utilizing the School Overlay designation for a school as the proposed project, as well as development if the school was not developed and the proposed project's underlying zoning applied. This analysis informed public participation in the CEQA process by analyzing impacts under both scenarios.

As to commercial development, the project description notes that the proposed project would establish up to 80,000 square feet of commercial uses. (EIR, Section 3.3.) Table 3-1 lists the allowable commercial square footage as 60,000 square feet in the Village Center land use designation and 20,000 square feet in the Agricultural Overlay designation. The 20,000 square feet of commercial use in the Agricultural Overlay designation is set aside for the Farm. The Farm is discussed in detail in Section 3.3.5 of the EIR. Additionally, as set forth in Section 3.3.1.6 of the EIR, the underlying land use for the Agricultural Overlay is Open Space. This ensures that no residential or commercial units would be built in those areas. The EIR provides "[t]he underlying Open Space land use designation may be implemented in the Agriculture Overlay planning area if uses permitted within the Agriculture Overlay planning area become infeasible (e.g., the Farm fails). Caretaker units (a maximum of six residential units) and commercial accessory uses are only permitted when the Agriculture Overlay is applied and would not be allowed when the Open Space land use is in effect." (EIR, Section 3.3.1.6.) Thus the EIR clearly describes what happens if the commercial square footage is not developed in the Agricultural Overlay.

The other 60,000 square feet of commercial development is allowed in the Village Center land use designation, which would be divided amongst the three proposed villages. Forty thousand square feet of commercial development is permitted in the Fanita Commons Village Center, with 10,000 square feet of commercial development permitted in Orchard Village and 10,000 square feet of commercial development permitted in Vineyard Village. (EIR, Section 3.3.2.) This breakdown of the permitted commercial development provides sufficient detail to inform decisionmakers, taking account of environmental consequences. The comment also cited Citizens for a Sustainable Treasure Island v. City & County of San Francisco (2014) 227 Cal.App.4th 1036, 1053, for the proposition that an El R's description of the project should identify the project's main features and other information needed for an assessment of the project's environmental impacts. The comment overlooks the fact that as long as these requirements are met, a project description may allow for the flexibility needed to respond to unforeseeable events and changing conditions that could affect the project's final design. Ibid. The project description here satisfies CEQA's requirements 60139. l 8028\33290250. l
on both counts. It clearly identifies the allowable commercial square footage permitted, allowing for impacts to be adequately analyzed. It sets forth a description of where such commercial square footage is permitted and it allows for flexibility.

The comment also argues that "[w]ithout a description of the affordability levels of the units, height and type of housing set to be built, the Project EIR cannot meaningfully evaluate the Project's greenhouse gas, transportation, land use or aesthetic impacts." Table 3-1 sets forth the residential units permitted by land use designation, including Village Center, Medium Density Residential, Low Density Residential and Active Adult Residential. (EIR, Section 3.3.1.) These designations are depicted on Figure 3-4. The project site is the only source for above moderate residential units in the City. (EIR, Section 4.13.5.1.) Contrary to the comment, the density, height and type of housing to be developed is set forth in detail in the project description (See EIR, Sections 3.3.1.1,

3.3.1.2, 3.3.1.3, 3.3.1.4, 3.3.1.5.) Therefore, the Project Description is accurate, stable and finite and no amendment is required.

3. COVID-19 is Not a CEQA Effect
The comment argues that due to the current public health crisis, the City must adopt a mandatory finding of significance that the proposed project's construction activities may cause a substantial adverse effect on human beings and that additional safety measures are required to mitigate potential community spread of COVID-19.

Public Resources Code Section 21083(b)(3) and CEQA Guidelines Section 15065(a)(4) provide a project may have a significant effect on the environment if the environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly. COVID-19 is not an environmental effect of the project, however, as it is already present in the population unrelated to project development. As a general rule, CEQA does not require an analysis of the impact of the existing environment on a proposed project unless the project will worsen existing environmental hazards or conditions. California Bldg. Indus. Assn. v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 377. Development of the proposed project will not worsen COVID-19 conditions.

Even so, the City is already subject to Statewide and County public health orders and follows San Diego County protocols for construction sites. See, Statewide Public Health Order (July 13, 2020)
[https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/COVI D-19/SH0%200rder%20Dimming%20Entire%20State%207-13-2020.pdf]; Order of the Health Officer and Emergency Regulations (Effective July 21, 2020) [https://www.sandiegocounty.gov/content/dam/sdc/hhsa/programs/phs/Epidemiology/H ealth0fficer0rderCOVID19.pdf] ("County Order").

Section 12 of the County Order provides that when the State of California has issued an industry guidance, or any subsequent amendments thereto, with mandatory and/or suggested measures to be implemented by a particular type of business or industry, a 60139. l 8028\33290250. l
reopened business must include in its Safe Reopening Plan all of the industry guidance mandatory measures, including, but not limited to, all of the requirements and guidance set forth in the Statewide Public Health Officer Order, issued by the California Department of Health Services on July 13, 2020, all portions of which are operative in San Diego County effective immediately, and available at {https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/COVI D19/SH0%200rder%20Dimming%20Entire%20State%207-13-2020.pdf}. The reopened business shall include all suggested measures necessary to maintain proper sanitation, employee screening, social distancing and facial coverings. Any mandatory measures required by the Statewide Public Health Officer Order must also be included in the Safe Reopening Plan.

Further, the State of California has issued COVID-19 industry guidance for construction. https://files.covid 19.ca.gov/pdf/guidance-construction.pdf (July 2, 2020) and construction industry checklist https://files.covid19.ca.gov/pdf/checklistconstruction.pdf, which the City would follow for construction of the project. The State's industry guidance provides that employers also must comply with all Cal/OSHA standards and be prepared to adhere to its guidance as well as guidance from the Centers of Disease Control and Prevention (CDC) and the California Department of Public Health (CDPH). Employers also must be prepared to alter their operations as those guidelines change. Cal/OSHA protocols can be found at https://www.dir.ca.gov/dosh/coronavirus/COVID-19-lnfection-Prevention-inConstruction. pdf.

4. The EIR's Greenhouse Gases Analysis Complies with CEQA The comment summarizes the EIR's conclusions regarding Greenhouse Gas (GHG) emissions impacts as well as provides a summary of SB 375 and the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) adopted by the Southern California Association of Governments (SCAG), as well as the RTP/SCS adopted by SANDAG. The comment notes that there are land use policies, transportation strategies, and project-level GHG measures identified in the 2012 and 2016 RTP/SCS and Program Environmental Impact Reports which the EIR should consider.

The CEQA Guidelines state that a lead agency may analyze and mitigate the significance of GHG emissions at the project level using a plan for the reduction of GHG emissions (CEQA Guidelines, Section 15183.5[a]). The City's Sustainable Santee Plan was adopted in January 2020 and includes a checklist to determine development projects' consistency with the land use assumptions and GHG reductions used in the Sustainable Santee Plan. The Sustainable Santee Plan is a qualified plan for reduction of GHGs under CEQA Guidelines, Section 15183.5(b).

Given that the Sustainable Santee Plan was in litigation (which has since been settled) at the time the EIR was released for public and agency review, the City elected to 60139. l 8028\33290250.1
independently develop a quantitative per capita GHG threshold, based upon the data accumulated during preparation of the Sustainable Santee Plan, to ensure the project would not generate significant GHG emissions under CEQA. That data is based on the demographic and land use forecast in the Santee General Plan. (See EIR Section

4.7.5.1 ).

CEQA also requires that an EIR consider whether implementation of a proposed project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. The project EIR analyzes the project's consistency with the Sustainable Santee Plan. As part of the analysis required to respond to that question, Table 4.7-13, Sustainable Santee Plan Community GHG Reduction Strategies (After Mitigation), demonstrates that the project, following implementation of the recommended mitigation measures, would be consistent with the applicable reduction strategies of the Sustainable Santee Plan. (See Section 4.7.3.)
The comment suggests the EIR consider the following Land Use and Transportation strategies found in the SCAG 2012 RTP/SCS: providing transit fare discounts; implementing transit integration strategies; and anticipating shared mobility platforms, car-to-car communications, and automated vehicle technologies. CEQA does not require analysis of every imaginable mitigation measure. Gilroy Citizens for Responsible Planning v. City of Gilroy (2006) 140 Cal.App.4th 911, 935. Here, the EIR has focused on feasible, practical and effective mitigation measures, particularly regarding GHG emissions focused on mobile sources, which compose over 60 percent of project emissions. The mitigation measures analyzed in the EIR would effectively reduce GHG emissions to less than significant levels. Of note, Mitigation Measure AIR6 includes Transportation Demand Measures including implementing car-sharing programs, providing ride-sharing programs, implementing commuter trip reduction marketing, implementing a school carpool program under the preferred land use plan with school and implementing a neighborhood electric vehicle network. Further, consistent with Goal 6 of the Sustainable Santee Plan, the project would include pedestrian paths and bike lanes that connect the residential and commercial portions of the project. In addition, the project would include neighborhood electric vehicle routes connecting the land uses of the proposed project together.

After applying Mitigation Measures GHG-1 through GHG-6, AIR-5 through AIR-8, and AIR-10, there would be a reduction in GHG emissions of 37 percent compared to unmitigated emissions (unmitigated emissions include reductions from project design features and state regulations) for the preferred land use plan with school and a 36 percent reduction compared to unmitigated emissions for the land use plan without school. Per capita emissions from the preferred land use plan with school would be

1.51 MT C02e after mitigation, and per capita emissions from the land use plan without school would be 1.62 MT C02e. Therefore, per capita emissions would be reduced to below the 1.77 MT C02e threshold for either land use plan, and impacts would be mitigated to a less than significant level. The project is thus consistent with 60139.18028\33290250. I
the numeric threshold derived from the data used to prepare the Sustainable Santee Plan and additional mitigation measures are not required. (EIR, Section 4.7.5.1.) The comment includes a list of suggested GHG emissions goals citing the SCAG 2012 RTP/SCS Final PEIR MMRP as well as Appendix F of the CEQA Guidelines. The proposed project's design features and mitigation measures are consistent with those suggested by the comment. Potential measures to reduce wasteful, inefficient and unnecessary consumption of energy are analyzed in Section 4.5 of the EIR. Estimated energy consumption with and without implementation of the mitigation measures required to reduce air quality and GHG emissions is illustrated in Table 4.5-7.

Specifically, Mitigation Measure AIR-8 would reduce energy use, and Mitigation Measure GHG-1 requires generation of renewable energy on the project site. The annual electricity consumption of the project with Mitigation Measures AIR-7, GHG-4, and GHG-6 would be higher than without mitigation measures due to the increased electricity consumption by electric vehicles (EV) and all-electric residences. Mitigation would include on-site renewable electricity generation (Mitigation Measure GHG-1), however, that would offset the higher electricity consumption of the proposed project.

By buildout, the project would generate approximately 20,472,039 kilowatt-hours (kWh) and 20,378,877 kWh of electricity per year from distributed photovoltaic solar electric generation on site, under the preferred land use plan with school and land use plan without school, respectively, which is equal to approximately 63 percent of the total electricity demand. The on-site generation of renewable energy would reduce the project's percent of County 2017 energy consumption to 0.06 percent. (EIR, Section

4.5.5.1.) This is consistent with the goals listed by the comment, such as alternate fuels (particularly renewable ones) or energy systems.

The project also would include a total of 1,203 240-volt Level 2 Electric Vehicle Supply Equipment (EVSE) in each garage provided for a Low Density Residential Unit, a total of 354 EVSE in the parking areas of the remaining residential units and 15 EVSE within the proposed project's commercial parking lots as stated in Mitigation Measure AIR-7.

Per Mitigation Measure AIR-6, the project would implement a neighborhood electric vehicle network along with other Transportation Demand Management measures. (EIR, Section 4.2.5.1.) Additionally, Mitigation Measure GHG-6 would provide 100 electric vehicles to project residents. (EIR, Section 4.7.5.2.) This is consistent with measures listed by the comment, including the use of energy and fuel-efficient vehicles and equipment; the deployment of zero- and/or near zero emission technologies; and measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles, or reduce the carbon content of fuels, including constructing or encouraging construction of electric vehicle charging stations or neighborhood electric vehicle networks, or charging for electric bicycles.

Mitigation Measure GHG-2 requires the applicant to institute recycling and composting services to divert at least 90 percent of the proposed project's operational waste, consistent with the City's performance metric. The proposed project would also recycle 60139.18028\33290250.1
or reuse at least 70 percent of the construction waste, soil, and debris by 2030 and 80 percent starting in 2030. (EIR, Section 4.7.5.2.) This is consistent with the measures cited by the comment, such as incorporating design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse and recycling construction debris to the maximum extent feasible.

Accordingly, the proposed project already incorporates many of the measures listed by the comment in Mitigation Measures AIR-5 through AIR-10 and GHG-1 through GHG6. Implementation of the proposed project's Air Quality and GHG Mitigation Measures would ensure the project is consistent with the Sustainable Santee Plan and that GHG emissions are less than significant. No additional measures are required.

5. The EIR Adequately Addresses the Comment's Hydrology and Water Quality Related Concerns
The comment lists a number of measures related to hydrology and water quality goals that it suggests be implemented by the proposed project. As to measures consistent with standards set by regulatory agencies responsible for regulating water quality/supply, the project does reduce exterior consumptive uses of water in public areas and promotes reductions in private homes and businesses as set forth in Mitigation Measure GHG-3, which requires the proposed project to implement water conservation strategies that are designed to be as efficient as possible with potable water supplies and will achieve at least 20 percent indoor and outdoor water reduction compared to the average statewide water consumption rate at the time of project approval.

The project also would incorporate measures consistent with the standards set by regulatory agencies responsible for regulating and enforcing water quality and waste discharge requirements. Hydrology and Water Quality is analyzed in Section 4.9 of the EIR. For instance, consistent with the measures set forth by the comment, the project will be subject to compliance with Construction General Permit requirements and with Chapter 9.06 of the Santee Municipal Code, which prohibits non-stormwater discharges and eliminates illicit discharges and illicit connections to the stormwater conveyance system, reduces the discharge of pollutants from the stormwater conveyance system to the maximum extent practicable in order to achieve applicable water quality objectives for surface waters in the County, and achieves compliance with TMDL regulations (City of Santee 2020). Prior to project grading or construction, the Construction General Permit requires preparation of a SWPPP. The SWPPP would include a series of specific BMPs to be implemented during construction in order to address erosion, accidental spills, and the quality of stormwater runoff.

As to operation of the project, consistent with the City's Stormwater Management Ordinance, the project is considered a priority development project and is required to identify and incorporate measures for hydromodification management to ensure that stormwater runoff rates and durations do not exceed pre-development conditions or 60139. I 8028\33290250.1
result in adverse erosion or sedimentation effects. All priority development projects are required to implement structural BMPs for stormwater pollutant control. Additionally, projects subject to hydromodification management requirements must implement structural BMPs for flow control. Structural BMPs, such as biofiltration (basins and proprietary modular units) and combined pollutant control and hydromodification control measures, have been incorporated into the proposed project design (see Figure 3-13, Conceptual Storm Drainage Plan, in Chapter 3, Project Description). The Stormwater Quality Management Plan also identifies a series of specific non-structural and structural source control BMPs to be incorporated into the project design. (EIR, Section 4.9.5.1.)
The comment also listed measures consistent with the provisions of the Groundwater Management Act. The proposed project is consistent with the measures listed by the comment as set forth in Section 4.9. The City does not rely on groundwater sources for its water supply. The project site would receive Advanced Treated Water from Padre Dam Municipal Water District through its Advanced Water Purification Program. No groundwater would be used for construction or operation of the proposed project. In order to minimize potential effects on groundwater recharge, the project would be designed to include pervious, landscaped areas, allowing groundwater recharge to continue to occur. Runoff from developed areas would drain into a proposed on-site basin system designed to slow peak flow and discharge to rates equal to or less than existing conditions. Hydromodification management would occur through storage of stormwater within the basins, with outlets that regulate the flow rate and duration of stormwater released. Source control and low-impact development measures would be implemented to incorporate pervious surfaces and maximize the amount of open space, landscaping, and vegetated swales to slow and absorb runoff, allowing for groundwater recharge. Further, the project would include a total of approximately 2,022.6 acres of undeveloped area including 256 acres of Open Space, 1,650.4 acres of Habitat Preserve, and 116.2 acres of Agriculture and Parks (Community, Neighborhood, and Mini). As such, groundwater recharge in these areas would continue after project implementation. (EIR, Section 4.9.5.2.) The project site is located in Federal Emergency Management Agency Flood Zone X, which is outside of the 100- and 500-year flood hazard areas. The project also does not propose roadbeds for new highway and rail facilities and thus the measures cited by the comment regarding floodplain regulations do not apply to the project.

6. The EIR's Transportation Analysis Complies with CEQA The comment lists a number of transportation, traffic and safety measures that it suggests should be considered for incorporation into the project. The project already incorporates many of the suggested measures, resulting in less than significant impacts regarding GHG emissions, and is consistent with the Sustainable Santee Plan. See Section 3.4.1 of the EIR regarding mobility, and particularly Section 3.4.1.3 regarding the Alternative Transportation Network.
60139.18028\33290250. l
Mitigation Measure AIR-6 implements Transportation Demand Management measures.

The strategies have been taken from the Quantifying Greenhouse Gas Mitigation Measures reported by the California Air Pollution Control Officers Association (CAPCOA). These include:
• Improve design of development to enhance walkability and connectivity • Provide pedestrian network improvements
• Provide traffic-calming measures
• Provide bike lanes in the street design
• Provide bike parking for multi-family residential uses • Implement car-sharing programs
• Provide ride-sharing programs
• Implement commuter trip reduction marketing
• Implement a school carpool program under the preferred land use plan with school
• Implement a neighborhood electric vehicle network
The TOM plan would facilitate a balanced approach to promote overall mobility with the ultimate goal of reducing to the extent possible the number of single-rider vehicle trips generated by the project and consequently the vehicle miles traveled. Pursuant to Mitigation Measure AIR-7, the project includes on-site electric vehicle charging stations and Mitigation Measure GHG-6 requires the applicant or its designee to provide a total of 100 electric vehicles to project residents. (EIR, Sections 3.4.1.3, 4.2.5.1 and

4.7.5.2.)
The project also will implement a Traffic Calming Plan throughout the project site. The plan would include a set of street designs that slow and reduce traffic speeds while encouraging walkers and cyclists to share the street. Traffic calming measures would promote pedestrian, bicycle, and vehicle safety by controlling the speed and distribution of vehicles traveling through the project site. Six roundabouts are proposed as part of the proposed project's circulation plan to reduce traffic speeds and provide connection to the internal streets and villages. The roundabouts would eliminate the need for left-turn and U-turn movements, controlling vehicle speeds and providing a safer environment for pedestrians. (EIR, Section 3.4.1.2.) Parking will be consistent with Santee Municipal Code Section 13.24.040. Parking in the Village Center land use designation would allow for shared vehicle parking between uses to reduce the need for large parking lots and pavement areas. A bicycle station would be provided with bicycle parking, access to air and water, and a bike share facility. Each Village Center would also provide electric vehicle (EV) charging stations and preferred parking per CALGreen requirements. (EIR, Section 3.3.1.1.) In the Medium Density Residential land use areas, the location of parking would consider proximity to the Village Centers and parks, and seek to promote walkability or alternative modes by providing bicycle facilities and trails to offset single-occupancy 60139. l 8028\33290250. l
vehicle use. Bicycle parking would be required for attached residential development as specified by CALGreen. (EIR, Section 3.3.1.2.)
The project thus incorporates Transportation Demand Management measures based on CAPCOA guidance, which is cited by the comment. As the project is designed to reduce vehicle miles traveled (VMT) and with mitigation, GHG impacts are reduced to less than significant levels, no further mitigation is required.

7. The Project Adequately Incorporates Sustainability Measures The comment provides suggested measures related to utilities and service systems, including that the project integrate green building measures consistent with CALGreen (Title 24, part 11 ), U.S. Green Building Council's Leadership in Energy and Environmental Design, Energy Star Homes, Green Point Rated Homes, and the California Green Builder Program into project design. The project is consistent with the suggested measures. Please refer to Section 3.8, Smart Growth and Sustainability Features, for a list of the smart growth principles applicable to the proposed project, including those related to Energy, Atmosphere, and Building System. The smart growth and sustainability features are in accordance with CALGreen requirements and include utilizing EnergyStar appliances, energy-efficient lighting fixtures, tank-less water heaters, increased insulation, and the minimization of air leaks to the building envelope by using air barriers on exterior walls in all residential and commercial construction.

Additionally, Mitigation Measure AIR-8, High-Efficiency Equipment and Fixtures, provides that prior to the issuance of building permits, the applicant or its designee shall provide evidence to the City of Santee that the applicant will utilize high-efficiency equipment and fixtures that exceed 2016 California Green Building Standards Code and 2019 Title 24, Part 6 energy conservation standards by 14 percent. When the standards are updated, the applicant shall use high-efficiency equipment and fixtures meeting or exceeding the latest standards. (EIR, Section 4.2.5.1.) Section 3.7, Solid Waste and Recycling, describes the proposed project's solid waste and recycling measures. Waste and recycling for project construction and operation would comply with CALGreen and state regulations designed to divert waste from landfills. Recycling would meet state-wide mandates that require significant recycling efforts during and after construction. Additionally, Mitigation Measure GHG-2 requires the applicant to institute recycling and composting services to divert at least 90 percent of the proposed project's operational waste, consistent with the City's performance metric. The project would also recycle or reuse at least 70 percent of the construction waste, soil, and debris by 2030 and 80 percent starting in 2030. (EIR, Section 4.7.5.2.) The project also contemplates the use and reuse of on-site rock materials, such as large boulders, rock cobble, decomposed granite, and processed rock. There are large quantities of rock cobble existing on site. Rock cobble would be collected and used in the construction of water quality and landscape features. It is also anticipated that an aggregate plant would be set up on site during construction. The aggregate plant would 60139. l 8028\33290250. l
produce roadway sub-base and other aggregate materials for use on site. In addition to rock materials, there are large deposits of decomposed granite on site, which would be reused for trails and other landscape-related purposes. Use of on-site materials would eliminate the need for importing rough or finished materials, reducing constructionrelated vehicle emissions in support of the approved Sustainable Santee Plan. (EIR, Section 3.7.)
The project thus incorporates smart growth and sustainability features as well as mitigation measures consistent with those suggested by the comment. No further mitigation is required.

8. The Project's Analysis of Hazards Complies with CEQA The comment notes impermissible deferral of mitigation occurs when an EIR calls for mitigation measures to be created based on future studies, but the agency fails to commit itself to specific performance standards. A lead agency may rely on future studies to devise the specific design of a mitigation measure when the results of later studies are used to tailor mitigation measures to fit on-the-ground environmental conditions. See City of Maywood v. Los Angeles Unified Sch. Dist. (2012) 208 Cal.App.4th 362, 411 (upholding mitigation measure, based on further investigation of contamination at project site, calling for development of hazardous materials remediation plan); City of Hayward v. Board of Trustees of Cal. State Univ. (2015) 242 Cal.App.4th 833, 855 (upholding transportation demand management program that identified measures to be evaluated and included monitoring plan, performance goals, and schedule for implementation). Mitigation performance standards are sufficient if they identify the criteria the agency will apply in determining that the impact will be mitigated. Citizens for a Sustainable Treasure Island v. City & County of San Francisco (2014) 227 Cal.App.4th 1036, 1059.

The comment argues that the EIR improperly defers formulation of a well abandonment plan until after certification of the EIR. Mitigation performance standards are sufficient if they identify the criteria the agency will apply in determining that the impact will be mitigated. Mitigation Measure HAZ-1 provides that the applicant shall provide documentation to the City of Santee Development Services Department showing the proper abandonment of the on-site groundwater well located approximately 800 feet northeast of the Padre Dam Municipal Water District Ray Stoyer Water Recycling Facility, in accordance with the County of San Diego's Well Ordinance (Section 67.441 of the Regulatory Ordinances).

Mitigation Measure HAZ-1 goes on to state "Section 67.441 outlines the permit application requirements and conditions for the purpose of construction, repair, reconstruction, and destruction of any well. These requirements include but are not limited to locational information, waste disposal systems, drainage patterns, depth of the wells, and completion of work. This section also includes the conditions of approval for a permit that must be adhered to by the applicant." Mitigation Measure 60139. l 8028\33290250.1
HAZ-1 clearly sets forth the criteria the City will apply in determining that the impact is mitigated. Therefore, it contains sufficient performance standards and does not constitute an improper deferral of mitigation.

9. The Noise Mitigation Measures Comply with CEQA
The comment argues that Mitigation Measures NOl-4 and NOl-8 do not contain objective performance criteria and constitute deferred mitigation. The comment supports this proposition by citing to portions of Mitigation Measure NOl-4, Nighttime Noise Sound Management Plan, but does not cite the entire measure, which does in fact contain objective criteria. Mitigation Measure NOl-4, Nighttime Noise Sound Management Plan, in its entirety states:

The construction contractor shall be required to obtain authorization from the Director of Development Services for any construction activities that would occur between 7:00 p.m. and 7:00 a.m. As part of the authorization process, the construction contractor shall prepare a Sound Management Plan to be included in construction documents, including the grading plan and construction contract. The Sound
Management Plan shall include all or a combination of the measures listed in Mitigation Measure NOl-3, as deemed
necessary by a qualified acoustical engineer, to minimize noise at nearby receptors. In addition to the measures listed in Mitigation Measure NOl-3, construction activities that must take place between 7:00 p.m. and 7:00 a.m. that could
generate high noise levels at residences shall be scheduled during times that would have the least impact on sensitive receptor locations, such as the evening hours between 7:00 p.m. and 10:00 p.m. rather than the nighttime hours between 10:00 p.m. and 7:00 a.m.

As stated in Mitigation Measure NOl-4, the Sound Management Plan shall include all or a combination of the measures listed in Mitigation Measure NOl-3. Additionally, Mitigation Measure NOl-4 provides criteria related to the hours of nighttime construction. If the construction activities could generate high noise levels at residences, work shall be scheduled during times that would have the least impact on sensitive receptor locations, such as the evening hours between 7:00 p.m. and 10:00 p.m. rather than the nighttime hours between 10:00 p.m. and 7:00 a.m. Thus, Mitigation Measure NOl-4 does contain objective performance criteria and does not constitute improper deferral of mitigation.

Mitigation Measure NOl-8, Vibration Best Management Practices, provides prior to the commencement of construction activities that would involve use of a vibratory roller (or equivalent equipment) within 75 feet of a residence, the applicant shall retain a 60139.18028\33290250. l
qualified acoustician to identify best management practices to be implemented by the construction contractor to reduce vibration levels to below 80 vibration decibels at the nearest residence. The best management practices shall be included in project construction documents, including the grading plan and contract with the construction contractor. Mitigation Measure NOl-8 also includes a list of best management practices which may be implemented, including: use only properly maintained equipment with vibratory isolators; operate equipment as far from sensitive receptors as possible; and use rubber-tired vehicles as opposed to tracked vehicles.

Agencies can formulate further details of a mitigation measure pending further study if there is a reasonable basis to conclude that the impact will be adequately mitigated.

Courts have upheld mitigation measures where the EIR required specific "best management practices" to be implemented as part of a plan. Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th 777, 794. Deferral may also be appropriate when the nature or extent of mitigation that may be required depends on the results of a later study. See Laurel Heights Improvement Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 418 (mitigation measure for noise impacts required evaluation of specific noise control techniques to ensure compliance with noise performance standards once ventilation system had been designed).

Mitigation Measure NOl-8 contains objective performance standards in that vibration levels must be reduced to below 80 vibration decibels at the nearest residence. It also includes a list of best management practices that may be implemented. The best management practices to be implemented are to be determined by a qualified acoustician. This mitigation measures complies with CEQA because it is unknown at this time what extent of mitigation will be required. That is dependent on a number of factors, such as distance to the nearest residence, the equipment used and duration.

Once the location of the nearest residence is known in an instance where a vibratory roller would be used within 75 feet, the type of best management practices required to reduce vibration levels to below 80 vibration decibels shall be determined by the qualified acoustician. Therefore, Mitigation Measure NOl-8 is adequate mitigation under CEQA and does not constitute improper deferral of mitigation.

10. The Aesthetics Analysis Complies with CEQA
The comment argues the EIR defers mitigation of significant impacts to aesthetics. The comment refers to the extensive excavation and grading into the native terrain as causing significant impacts to aesthetics. Please refer to Section 4.1.5.3, Visual Character, for a discussion of grading impacts on visual character. As discussed in Section 4.1.5.3, impacts to visual character are less than significant and no mitigation was required. As there are no significant impacts, no mitigation is required.

Grading for the project is described in detail in Section 3.10 of the Project Description and depicted in Figure 3-16, Conceptual Cut and Fill Plan. Grading design standards are set forth in Section 3.10.1, Grading Design Guidelines, which address the unique 60139. l 8028\33290250.1
topography of the proposed project site, m1nim1ze the development footprint, and maximize the preservation of natural Open Space areas on the project site. The Grading Design Guidelines provide that grading on the project site would be as efficient as possible to minimize the development footprint and that grading would not be excessive beyond that necessary for the use, access, and drainage of the site. As noted in both the Grading Design Guidelines and in Section 4.1.5.3, Visual Character, "public interest" slopes within the development area that are visible from the public rights-of-way would be designed to use landform grading techniques to recreate and mimic the natural contours and drainages. Compliance with the Grading Design Guidelines and the City of Santee Hillside Development Guidelines ensure that impacts on visual character due to landform alteration are less than significant and no mitigation is required.

11. The Utilities Analysis Complies with CEQA
The comment argues that the discussion of mitigation measures to reduce impacts of new utilities infrastructure is inadequate and not based on substantial evidence. The construction of new utility infrastructure to facilitate water, wastewater, stormwater, electric power, natural gas, and telecommunications facilities is analyzed in Section

4.17 and addressed throughout the EIR, as utility infrastructure is included as part of the proposed project. The project's water supply is described in Section 3.4.2, Water Supply. The stormwater drainage system is described in Section 3.4.3, Stormwater Drainage System, and dry utilities are discussed in Section 3.4.4, Dry Utilities. Figure 3-11, Conceptual Potable Water Plan, Figure 3-12, Conceptual Sanitary Sewer Plan, and Figure 3-13, Conceptual Storm Drainage Plan depict the necessary infrastructure improvements. Accordingly, construction impacts addressed throughout the EIR under the various resource topics in Section 4.2, Air Quality; Section 4.3, Biological Resources; Section 4.4, Cultural and Tribal Cultural Resources; 4.6, Geology, Soils, and Paleontological Resources; Section 4.7, Greenhouse Gas Emissions; Section

4.12, Noise; Section 4.16, Transportation; and Section 4.18, Wildfire include the construction of utility infrastructure. As described in these EIR sections, some impacts would be reduced to a less than significant level with mitigation, while others (air quality, noise, and transportation) would remain significant and unavoidable after all feasible mitigation is applied. No additional mitigation measures are required. (EIR, Section 4.17.5.1.)

12. The Project Complies with the Housing Element
The comment argues that the project is inconsistent with the City's General Plan Housing Element and that the City needs to consider including a fair share of affordable housing on the project site to meet its RHNA obligations under the state housing law and to comply with the City's General Plan.

The RHNA has identified housing needs based on income level for the City. The comment notes that Santee's RHNA allocation through 2021 is to build 457 units for 60139. I 8028\33290250. l
extremely low income, 457 units for very low income, 694 units for low income, 642 units for moderate income, and 1,410 units for above moderate income. The Santee General Plan Housing Element lists the project site as the only source for above moderate income residential units. Other sites are identified to meet RHNA requirements for the other income levels, as illustrated on Table 4-4 of the General Plan Housing Element. The Santee General Plan Housing Element specifically states "Santee's remaining RHNA for above moderate income households will be accommodated on the 2,600-acre Fanita property, which is located in the PD (Planned Development) zone in the northern part of the City." Additionally, "[t]he Fanita Ranch area shall not be subdivided until a Planned Development is adopted by the City of Santee. The exact number of parcels and unit count are not specified for the PD zone in Fanita Ranch; however, based on the gross acreage and on the unit counts of recent development proposals, the City estimates that at least 1,395 dwelling units can be constructed in this area, and is committed to ensuring that this unit count is achievable within the planning period." (Santee General Plan Housing Element, p. 4-7.) The project would satisfy the RHNA requirements for above moderate residential units and provide additional residential units to meet the anticipated future deficiencies in the City. Therefore, the project is consistent with the City's General Plan Housing Element, and the project will be developed as specifically contemplated in the City's Housing Element.

13. The Project is Consistent with the San Diego MSCP and the Conservation Element in the General Plan
The comment states that the project fails to comply with the San Diego MSCP and the General Plan's Conservation Element. The project development would be clustered into three villages to preserve natural open space areas, drainages, and key wildlife corridors. (EIR Section 3.3, Project Components.) The Habitat Preserve land use designation would apply to open space areas outside the limits of the clustered development and would include approximately 1,650.4 acres (approximately 63 percent of the total project site). It would include areas undisturbed from planned development and specific revegetated slopes at the edge of the planned development area. (EIR Section 3.3.1.10, Habitat Preserve.) The Habitat Preserve area is depicted on Figure 3-3, Conceptual Site Layout.

Mitigation Measures BI0-1 (Preserve Management Plan), which would provide a longterm management plan for the Habitat Preserve, and BI0-6 (Land Use Adjacency Guidelines), BI0-9 (Habitat Preserve Protection), BI0-10 (Weed Control Treatments), and BI0-11 (Argentine Ant Control and Monitoring) would reduce the potential impacts of edge effects, maintain suitable habitat, and provide fire management. (EIR, Section

4.3.6.6, Habitat Conservation Plans, Table 4.3-20.)
The comment claims that the project should be located closer and concentrated near existing development. A Modified Development Footprint Alternative, which consists of development exclusively in the southern half of the project site was analyzed in the 60139.18028\33290250. l
EIR. While avoiding some potential impacts to biological resources, the Modified Development Alternative had greater environmental impacts in other areas, such as aesthetics and public services than the proposed project. It also failed to meet several key project objectives. (EIR, Section 6.2.3, Modified Development Footprint Alternative.)
The comment also claims the project fails to minimize damage to the habitats of multiple species, including but not limited to, the coastal cactus wren, Quino checkerspot butterfly, Hermes copper butterfly, and western spadefoot toad. For further discussion, see Thematic Responses in the Final EIR for these species. The EIR contains mitigation to minimize damage to each of the species listed by the comment.

Specifically, potentially significant impacts to coastal cactus wren would be reduced to less than significant through the proposed project's on-site Habitat Preserve outlined in Mitigation Measure 810-1, which would conserve 0.42 acre of suitable habitat containing 2 coastal cactus wren clusters; Mitigation Measure 810-2, which would restore 0.02 acre of temporary impacts to cactus patch areas; Mitigation Measure 810- 14, which would require nesting bird surveys; Mitigation Measure 810-16, coastal cactus wren management plan; and through Mitigation Measure 810-9, which would require planting of cactus patches along brush management zones.

Suitable habitat associated with the covered Quino checkerspot butterfly would be directly impacted by project implementation. The 2016 focused surveys for this species were negative, however. The 2009 model (581.39 acres) was used to determine significance for this species. Impacts would be reduced to less than significant through the project's on-site Habitat Preserve outlined in Mitigation Measure 810-1, which would conserve 1,096.57 acres of suitable habitat; and Mitigation Measure 810-18, which would restore/enhance suitable habitat within temporary impact areas and through habitat management, including success criteria, specifically for this species.

Suitable habitat associated with the covered Hermes copper butterfly would be directly impacted by project implementation. The 2016 focused surveys for this species were negative, however. Impacts are based on the 2004 survey and 2014 and 2016 host plant mapping. Impacts would be reduced to less than significant through the proposed project's on-site Habitat Preserve outlined in Mitigation Measure 810-1 and Mitigation Measure 810-18, which would conserve 94.77 acres of potential suitable habitat containing two historical locations.

Potentially significant direct impacts to western spadefoot would be reduced to less than significant through the proposed project's on-site Habitat Preserve, outlined in Mitigation Measure 810-1, which would conserve 24 occupied features and 146.24 acres of suitable habitat in a configuration that preserves genetic exchange and species viability; Mitigation Measure 810-12, which would require a Vernal Pool Mitigation Plan for enhancing and restoring 0.50 acre of vernal pool resources; and Mitigation Measure 810-13, which would relocate individuals within impact areas to 60139. l 8028\33290250. l
suitable breeding habitat outside of impact areas. (EIR, Table 4.3-Sa, Direct Impacts to Special Status Wildlife Species.)
The comment further claims the project fails to expand acreages of reserve and habitats safe from construction or disturbance, edge effects, fires, or fragmentation as designed to adequately protect biological resources. To the contrary, Mitigation Measures BI0-1 (Preserve Management Plan), which would provide a long-term management plan for the Habitat Preserve, and BI0-6 (Land Use Adjacency Guidelines), BI0-9 (Habitat Preserve Protection), BI0-10 (Weed Control Treatments), and BI0-11 (Argentine Ant Control and Monitoring) would reduce the potential impacts of edge effects, maintain suitable habitat, and provide fire management. (EIR, Section

4.3.6.6, Habitat Conservation Plans, Table 4.3-20.)
The comment then claims the project's proposed development and reserve areas are not fully buffered from each other and all buffer areas should be unlit, and areas adjacent to development or roadways should have minimal lighting shielded away from buffer zones and natural areas. Mitigation Measure BI0-6 provides Land Use Adjacency Guidelines, including lighting. Lighting of all developed areas adjacent to the Habitat Preserve shall be directed away from the Habitat Preserve wherever feasible and consistent with public safety. Low-pressure sodium lighting shall be used whenever possible. (EIR, Section 4.3.5.1, Candidate, Sensitive, or Special-Status Species.)
The comment claims the project does not attempt to adequately minimize the use of roadways, or roadways crossing habitat or reserve areas. Roadways would be limited in the Habitat Preserve area. This area currently includes a network of private dirt roads and trails, many of which are subject to frequent illegal off-road vehicular traffic and unauthorized human activities that have been detrimental to the sensitive habitats in the Habitat Preserve. The project would close existing, informally established, and potentially harmful trails and provide revegetation in those areas. (EIR, Section 3.3.4 Habitat Preserve.)
The comment claims recreational trails do not utilize wildlife corridor road crossings to reduce the total extent of development infrastructure and increase corridor crossing function and size for wildlife. Trails are depicted on Figure 3-6. Trail locations throughout the project site would be coordinated to minimize conflicts with sensitive habitat areas by using existing trails and dirt roads and providing signage, well-defined trail markers, fencing, and community education to protect habitat areas. (EIR, Section

3.4.1.3, Trails.)
The comment claims the project does not minimize and mitigate impacts to impacted species to the maximum extent feasible with a goal of no net loss of sensitive biological resources: Impacts to candidate, sensitive, or special-status species are examined in Section 4.3.5.1, Candidate, Sensitive, or Special-Status Species. Impacts have been 60139.18028\33290250. I
mitigated to less than significant levels with the implementation of Mitigation Measures 810-1 through 810-21.

The comment claims vernal pools and their watersheds are not avoided to the maximum extent feasible. Impacts to vernal pools would be mitigated to a less than significant level through implementation of Mitigation Measure 810-12, which would require rehabilitation or enhancement and creation of new seasonal basin resources within the Habitat Preserve. (EIR, Section 4.3.5.2, Riparian Habitat or Other Sensitive Natural Communities.)
60139. l 8028\33290250.1
CENTER for BIOLOGICAL DIVERSITY
July 28, 2020
Chris Jacobs
Principal Planner
Department of Development Services
City Hall, Building 4
10601 Magnolia Ave.

Santee, CA 92071
Email: [email protected]
Re: Fanita Ranch Project Revised EIR
Dear Mr. Jacobs:

BY EMAIL
The Center for Biological Diversity has retained SW APE to provide the attached additional comments on the Fanita Ranch Project Draft Revised EIR (DREIR). The comments focus on DREIR's greenhouse gas and health risk impacts, and conclude that the DREIR fails to adequately evaluate these impacts.

Specifically, the SW APE comments conclude that "emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. An updated EIR should be prepared to adequately assess and mitigate the potential greenhouse gas and health risk impacts that the project may have on the surrounding environment."
Sincerely,
John Buse
Senior Counsel
Center for Biological Diversity
Arizona • California • Colorado • Florido • Minnesota • Nevada • New Mexico • North Carolina • Oregon • Washington • Washington, DC John Buse, Senior Counsel• 1212 Broadway, Suite 800 • Oakland, CA 94612 Phone: 323-533-4416 • Fax: 510-844-7150 • [email protected] Attachment 8
July 24, 2020
Aruna Prabhala
Technical Consultation, Data Analysis and
Litigation Support for the Environment
Center for Biological Diversity
660 S. Figueroa Street #1000
Los Angeles, CA 90017
(408) 497-7675
Subject: Comments on the Fanita Ranch Project {SCH No. 2005061118) Dear Ms. Prabhala,
2656 291h Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949} 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
We have reviewed the May 2020 Revised Draft Environmental Impact Report ("RDEIR") for the Fanita Ranch Project ("Project") located in the City of Santee ("City"). The Project proposes to construct either (1) the land use plan with school, which includes 2,949 housing units, 80,000-SF of commercial uses, and a 15-acre school for up to 700 students; or (2) the land use plan without school, which includes 3,008 housing units and 80-SF of commercial land uses. The Project also includes 78-acres of parks, 256-acres of open space, and 31.09-acres of special use on the 2,638-acre Project site.

Our review concludes that the REDIR fails to adequately evaluate the Project's greenhouse gas and health risk impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. An updated EIR should be prepared to adequately assess and mitigate the potential greenhouse gas and health risk impacts that the project may have on the surrounding environment.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The RDEIR concludes that the Project would generate greenhouse gas ("GHG") per service population efficiency values of approximately 1.5 metric tons of carbon dioxide equivalents per service population per year ("MT CO,e/SP/year") for the land use plan with school and approximately 1.61 MT CO,e/SP/year for the land use plan without school (p. 4.7-26, 4.7-27). As a result, the RDEIR concludes that the Project's GHG emissions would not exceed the per capita GHG significance threshold of 1.77 MT CO,e/SP/year, and the Project's GHG impact would be less than significant (p. 4.7-26, 4.7- 27). Furthermore, the RDEIR concludes that the Project would result in a less than significant GHG impact as a result of the Project's consistency with the Sustainable Santee Plan (p. 4.7-31). However, the RDEIR's GHG analysis should not be relied upon for three reasons. (1) The DEIR's quantitative GHG analysis relies upon an incorrect and unsubstantiated air model; (2) The DEIR fails to demonstrate the Project's consistency with the Sustainable Santee Plan; and (3) Updated analysis demonstrates significant impacts.
1) Unsubstantiated Input Parameters Use to Estimate Project Emissions According to the RDEIR, the Project's GHG analysis relies on emissions calculated from the California Emissions Estimator Model Version CalEEMod.2016.3.2 ("CalEEMod") (p. 4.7-14).1 CalEEMod provides recommended default values based on site specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project-specific values, but CEQA requires that such changes be justified by substantial evidence.2 Once all of the values are inputted into the model, the Project's construction and operational emissions are calculated, and "output files" are generated. These output files disclose to the reader what parameters were utilized in calculating the Project's air pollutant and GHG emissions and make known which default values were changed as well as provide a justification for the values selected.3 When we reviewed the Project's CalEEMod output files, provided as Appendix H to the RDEIR, we found that several of the values inputted into the model are not consistent with information disclosed in the RDEIR and associated documents. As a result, emissions associated with the Project are underestimated.

An updated EIR should be prepared that adequately assesses the potential impacts that construction and operation of the proposed Project may have on regional and local air quality.

Unsubstantiated Reductions to CH4, N20, and CO2 Intensity Factors The Project's CalEEMod output files demonstrate that both the mitigated and unmitigated models for both plans incorrectly include several changes to the Project's CH4, N20, and CO2 intensity factors. As a result, the models may underestimate the Project's emissions and should not be relied upon to determine Project significance.

Review of the Project's Cal EE Mod output files demonstrates that both the unmitigated land use plan with school and land use plan without school models include manual changes to the Project's CH4, N20, and CO2 intensity factors (see excerpt below) (Appendix H, pp. 408,435). 1 CalEEMod website, available at: http://www.caleemod.com/ 2 CalEEMod User Guide, p. 2, 9, available at: http://www.caleemod.com/ 3 "CalEEMod User's Guide." CAPCOA, November 2017, available at: http://www.caleemod.com/ (A key feature of the CalEEMod program is the "remarks" feature, where the user explains why a default setting was replaced by a "user defined" value. These remarks are included in the report.) , p. 7, 13.
2 Unmitigated Land Use Plan with School and Land Use Plan without School:

Table Name I Column Name I Default Value I New Value
l ..................... ili'
f
ProJe
eicfiaracieiis\lcs"·""'"""""'""""""l
"""'"""""'cf-i4iiiiaisii;;;Fa·aoi"""'"'""""l
'""""""""'""""""o:o:l'§'"'"'""'"""""""" 0.001
.............................. iii.r, iolec
ictiar.ic
i
ert
'
s
i
lc's'""'"""""'""""'""'f"'"""""""co2iiii'ensiiyi=ai:\oi""'"'"""'"'i """'"""'""""'"""l
2 il
'

4. 9
'""'"""'""'""'"" ........................... 2
as2"""'""""'"""""
.............................. i
i
iPioieciciiariiciei\s
i
i
cs ................................ l ............ i·fioi iii'ensi
/yFa
'dcii""""'""'""l
· ............................. ii:aa·
1 r .... ...................... ..................... ........ ii ............................ .. 1111111111111111111,1111,n11u11111111111111111111111111111111111111111u11111111111111111111111111u111l11111u11u11,1t11111111111,11111111111111111111111111111111111111111,h111111111111111111111111111n11111111111111111111111111111111111111 As you can see in the excerpt above, the CH4, CO2, and N20 intensity factors were reduced by approximately 97%, 60%, and 100%, respectively. Furthermore, review of the Project's CalEEMod output files demonstrates that both the mitigated land use plan with school and land use plan without school models include manual changes to the Project's CH4, N20, and CO2 intensity factors (see excerpts below) (Appendix H, pp. 463, 491)
Mitigated Land Use Plan with School and Land Use Plan without School:

Table Name I
Column Name I Default Value New Value
tblProjectCharacteristics l CH41ntensityFactor l 0.029 0.004 ....................................................................... j ................................................................. ,,,t, .................................................................. ........................................................... . tblProjectCharacteristics ! C021nlensit>;Factor ! 720.49 . 29.602 "'""''"•''''""""''·"""H'"''·""""'"""·""" .. ''"'•""i""''"·"'"'•uuoHuoo,HouoHno,u•••n•••"''''"''""•'•••i••"••••""" ... '"''"'"'""'"'""'""'•'""n•n.,,.,.,.,,.,. ••••••••••"'"'"''"""''"''"'''"'"""''"'"'''"'""' .. tblProjectCharacteristics ; N201ntensityFactor ; 0.006 0.001 .......................................................................... .i .................................................................... i .................................................................. ---------1111 As you can see in the excerpt above, the CH4, CO2, and N20 intensity factors were reduced by approximately 86%, 96%, and 83%, respectively. As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.4 According to the User Entered Comments and NonDefault Data table, the justifications provided for this changes are: "60% renewable" and "Santee CCA in combination with SDG&E for year 2035 (SDG&E Renewabe Portfolie = 60%)"5 (Appendix H, pp. 404, 431, 458,487). However, these justifications are insufficient for two reasons. First, as demonstrated above, the CH4, CO2, and N20 intensity factors were reduced by far more than 60%. Second, assuming the justification is referring to the state's renewable portfolio standard ("RPS"), just because the state has a 60% renewable goal does not guarantee that it will be achieved. Furthermore, without a substantial justification, the proposed Project cannot claim that the statewide RPS goal will result in a project-level reduction of the Project's actual emissions. Finally, the RDEIR acknowledges that this goal is for 2035, which is 15 years away. As a result, we cannot verify the model's use of the reduced CH4, CO2, and N20 intensity factors.

This presents an issue, as the CH4, CO2, and N20 intensity factors are used by CalEEMod to calculate the Project's GHG emissions associated with electricity use. 6 As such, by including unsubstantiated changes to the Project's CH4, CO2, and N20 intensity factors, the model underestimates the Project's GHG emission and should not be relied upon to determine Project significance. 4 Cal EE Mod User Guide, available at: http://www.caleemod.com/, p. 2, 9 5 *Note: The rest of the justification was not legible. 6 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 3 Failure to Model All Proposed Land Uses
According to the RDEIR, the Project includes 20,000-SF of "Agricultural Overlay" space (p. 3-22, Table 3- 3). However, review of the CalEEMod output files for the land use plan with school demonstrates that this land use was not included (see excerpt below) (Appendix H, pp. 404, 458). ses el!IC
:;1u ent :::i.
1 ,o . :
...
.
...................
.
.... ....
.
.................
.
................... • ... \ ........................
.. 1 OOOSQft .
.
....................... � ............ j 1.90 ........... ( ........ 1.389, 564 00
........ ( ...............
0 ............ ..

Cily Park 7 1 Acre 1 78.60 1 3,423,816.00 1 0
....
. ..... · · ... .
.
...
.
. �:::�: �:·:� .....
.
..
.
.
...... · ·· !" .
.
....
.........
.
.
...
.
..... 435 0
0 ...
.....
.
...........
...
..... r .... ·· ....... :::·:::·�:: ................. ,..... .. :::: .. ...... ! ........... :::�::: .. ...... 1 ............ �:: ..... .. .. .
· -- ··=== ··· ·· I··· ·,I�-- ·I· -��: · l ��--l·-o'.::::-1--�r As you can see in the excerpt above, the 20,000-SF of "Agricultural Overlay" space was not included in the CalEEMod model for the land use plan with school. Furthermore, review of the CalEEMod output files for the land use plan without school demonstrates that this land use was not included (see excerpt below) (Appendix H, pp. 431, 487).

I Lana uses :stze
General Light Industry 1,389.56
I Memc � I Lot Acreage I t-ioor ::;unace Area I t-'opu1auon 1000sqft 31.90 ! 1,389,564.00 o
. .; .

Apartn��::::w Rise
... -...................... :
6 :: ............................ 1
, ............. Cffl
e
:
i
: Unit
.................... 1-.......... :: :: ........... , ......... 3 �
::��
:�6
�
�
o
··--·f-··-24
�
7 ······-···
................ Apartm·
entsTOW'RiS"
e
····............
4 3

5.00 i Dwelling Unit i 35.00 � 435,000.00 i 1244
...................................................................... ..................................................................... � .................................................................... 1 ................................. s ......................................... f ............................... ..

Retirement Community 445.00 ! Cmelling Unit ! 30.90 ! 445,000.00 ! 1273 Single Family Housing
Regional Shopping Center
.......... -.... · .. ···-··-·-···-························· ... J ........................................... .
....................... + ... -............................ 1 .... -............. _, ___ , .... -i--·-.. ·---·· .. ·-· 1,262.00 I Cfflell!ng Unit j 256.30 j 2,271,600.00 j 3609 .......................... ,-50�00·-·-··· .................... ! .. ,-...................... 1000s· q
·
ii·"''""''"""'"''"'"'"''""1
'"'""'"''"'';:so·--···-.. ·
1 ··-· .. -·5o�oocroo-·-·r------o .. ··-····-···
; : : :

As you can see in the excerpt above, the 20,000-SF of "Agricultural Overlay" space was not included in both CalEEMod models for the land use plan with and without school. This presents an issue, as the land use type and size features are used throughout CalEEMod to determine default variable and emission factors that go into the model's calculations. 7 For example, the square footage of a land use is used for certain calculations such as determining the wall space to be painted (i.e., VOC emissions from architectural coatings) and volume that is heated or cooled (i.e., energy impacts). Furthermore, CalEEMod assigns each land use type with its own set of energy usage emission factors.8 Thus, by failing to include the proposed "Agricultural Overlay" space, the model underestimates the Project's construction and operational emissions and should not be relied upon to determine Project significance. 7 "CalEEMod User's Guide." CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsou rce/ ca leemod/upgrades/2016.3/01 user-39-s-guide2016-3-l.pdf?sfvrsn=2, p. 17 8 "CalEEMod User's Guide, Appendix D.11 CAPCOA, September 2016, available at:
http://www. aq md .gov/docs/ d efa u It -source/ ca I ee mod/ u pg rad es/2 016. 3/05 append ix-d 2016-3-1. pdf?sfvrs n =2 4 Failure to Evaluate the Feasibility of Obtaining Tier 4 Final Equipment Review of the Project's CalEEMod output files demonstrates that the Project's emissions were modeled assuming that construction equipment would be equipped with Tier 4 Final engines (see excerpt below) (Appendix H, pp. 61-62, 143-144, 220-221, 315-316).

Table Name I Column Name I Default Value New Value
tblConstEquipMitigation j NumberOfEquipmentMitigated J 0.00 2.00 tblConstEquipMitigation J NumilerOfEquipmentMitigated J 0.00 .........................

44. oo
........................ .
tblConstEquipMitigation ( NumberOfEquipmentMitigated ( 0.00 ' 33.00 . .
,,,.,,,.,,.,,,,.,.,,,,,,.,,,.,,.,,.,,..,,11,n11110,•1••u•••••u••u•·,.,.,,.,.,.,,,,.,.,,,,.,,,.,,.,.,,,, • .,,,,,.,,,,,,.,.,.,,.,,,.,,.,,·,..,.,,,,.,,.,,,.,.,,,,.,,.,,,.,,..,,.,,,,,,.,,.,,, • .,,,,,,,,,,u, tblConstEquipMitigation 1 NumberOfEquipmentMitigated � 0.00 1

0.00 tblConstEquipMitigation � NumberOfEquipmentMitigated j 0.00 '
""""""'""
"'"' 1

26.o
O"
"""'"""
""
""
'
"
tblConstEquipMitigation j NumberOfEquipmentMitigated ·

0.00 2.00
tblConstEquipMitigation j NumberOfEquipmentMitigated j 0.00 2.00 tblConstEquipMitigation : NumberOfEquipmentMitigaled ( 0.00 3.00 . .
lblConstEquipMitigation j NumberOfEquipmentMitigated 1 0.00 .........................

14.00 ........................ .
tblConstEquipMitigation [ NumberOfEquipmentMitigated j 0.00 ............ ............
2 1
.00
........................ .
' tblConstEquipMitigation ! NumberOfEquipmentMitigaled 1 0.00 3.00 tblConstEquipMitigation j NumberOfEquipmentMitigated j 0.00 .........................

32.oo
"
'
"'"'""'''"'"""""
tblConstEquipMitigation J NumberOfEquipmenfMitigaled j 0.00 .........................

25.00 ........................ .
'··" ' tblConstEquipMitigation ( Tier ' ' ( ' ' ' 'No Change ' ' ' " • """"""""""Tier'4' Finai"'""""'"""" . .
tblConstEquipMitigation i Tier j
No Change · Tier 4
' Final
................... .
tblConstEquipMitigation 1 Tier j
No Change · • Tier'i Final
.......
............ .
lblConstEquipMrtigation i Tier ! No Change Tier 4 Final tblConstEquipMrtigation · Tier · No Change Tier 4 Final tblConstEquipMitigation j Tier j
No Change Tier 4 Final
tblConstEquipMitigation ( Tier j No Change Tier 4 Final ' •• . .
tblConstEquipMitigation j Tier 1 No Change Tier 4 Final tblConstEquipMiligation t Tier j No Change Tier 4 Final tblConstEquipMitigation 1 Tier � No Change Tier 4 Final ' " " """"" tblConstEquipMitigation j Tier : No Change · · Tier 4
'
Final
" ..
.
. ........... .
tblConstEquipMitigation J Tier j No Change Tier 4 Final tblConstEquipMrtigation ( Tier ( No Change I Tier 4 Final ,,,,,.,,..,,.,,,,.,,.,.,.,,,,,.,,,,.,.,,.,,.,.,,,,,.,.,,.,,.,,..,,,.,.,,.,,.,,,:,.,,,,,,,.,,,,,,,.,,,,,,,.,,,,,,.,,,,,,..,.,,,,.,,.,,,.,.,,.,.,,..,,.,,:,, • .,,,, •• ,,,.,, • .,,,,,.,,.,,,.,,.,. •• ,,,.,,.,..,, ••• ,,.,,,,,.,,,.,.,.,,.,.,..,.,,,.,,.,,,.,, • .,,,,,.,,.,.,.,,,,,,.,,..,, • .,,.,u As you can see in the excerpt above, the model assumed that 317 pieces of off-road construction equipment would be equipped with Tier 4 Final mitigation. As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.9 According to the RDEIR, MM AIR-3 requires the use ofTier 4 construction equipment (p. 1-9 -1-10). Specifically, MM AIR-3 states:
"AIR-3: Tier 4 Construction Equipment. The City of Santee shall require heavy-duty, dieselpowered construction equipment used on the project site during construction to be powered by California Air Resources Board-certified Tier 4 (Final) or newer engines and diesel-powered haul trucks to be 2010 model year or newer that conform to 2010 U.S. Environmental Protection 9 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 5 Agency truck standards. This requirement shall be included in the construction contractor's contract specifications and the project construction documents, including the grading plan, which shall be reviewed and approved by the City of Santee prior to issuance of a grading permit. This mitigation measure applies to all construction phases" (p. 1-9 -1-10).

However, due to the limited amount of Tier 4 Final equipment available, the RDEIR should have assessed the feasibility in obtaining equipment with Tier 4 Final engines (see excerpt below). 10 Rgure 4: 2014 Statewide All Fleet Sizes (Pieces of Equipment) Tier 4F
6,816
Total Pieces of Equipment: 16"1,420
Key:

XX,XXX = Total pieces of equipment in that tier
XX% = Percent of total pieces of equipment in that tier As demonstrated in the figure above, the Tier 4 Final equipment only accounts for 4% of all off-road equipment currently available in California. Thus, emissions are modeled assuming that the Project will be able to obtain 317 pieces of Tier 4 Final equipment even though this equipment only accounts for 4% of available off-road equipment currently available in California. As a result, the model represents the best-case scenario even though obtaining this type of equipment may not be feasible. This is incorrect, as CEQA requires the most conservative analysis. Thus, by failing to evaluate the feasibility in obtaining Tier 4 Final equipment, the RDEIR may underestimate the Project's construction-related emissions and should not be relied upon.

Unsubstantiated Reductions to Acres of Grading
Review of the CalEEMod output files demonstrates that both models for Construction Phase 1-2 and for Construction Phase 3-4 include unsubstantiated reductions to the Project's anticipated Acres of Grading (see excerpts below) {Appendix H, pp. 65-66, 147-148, 224-225, 319-320).

Fanita Ranch Construction Phase 1-2:
10 "San Francisco Clean Construction Ordinance Implementation Guide for San Francisco Public Projects." August 2015, available at:
https://www.sfdph.org/dph/files/EHSdocs/AirQuality/San Francisco Clean Construction Ordinance 2015.pdf, p.

6. 6
Table Name I Column Name I Default Value
UJIGrading j AcresOfGrading j 1,671.00
. -
New Value
208.50
tblGrading j AcresOfGrading j 1,091.25 253.00
tblGrading i AcresOfGrading 1 3,102.00 240.00
tblGrading � AcresOfGrading � 0.00 253.00
....................................................................... • ......................... ,,.,H,0,,, ............................... -........................................... H,oo,,, ............... ........................................... ,H,,, .......... . tblGrading � AcresOfGrading ) 0.00 208.50
tblGrading i AcresOfGrading ! 0.00 240.00
""''''''''''''"''''''''''''''"''''''''''''''''''''''''''''''''''''''',,,,.,,,.,,,.,,,,,,,,,,Ho•o,u,,,,,,,,,,,,,,,.,,,,,.,,,,,,,.,,,,,,,,,',,,.,,,,,,,.,,,,,,,.,.,,,.,,,,,,.,,.,,,,,,.,,,,,,,,,.,,,,,,,,,,,,,, Fanita Ranch Construction Phase 3-4:

Table Name I Column Name I Default Value New Value I
tlllGrading j AcresOfGrading ! 1,671.00
-�·-'••••nu,,,..,,. _ •• ,..,�,...,.LO_.,..._,._,,,,,,.,., ,,_ _.,.,u,.__.•••• tblGrading l AcresOfGrading �
1,671.00 208.50
,, .. u,,, ................................................................ - ..................................................................... - ......................................................................... ................................................................ . tblGrading j AcresOfGrading � 0.00 208.50
...........................
tblGrading
"""""""""""""! """""" """
AcresOfGrading
'""""" "'"" � ........... " ""' '""""

0.00 "'""""""' "" " ' ' ' 208.50
"
'
""
'
""""
"
"""
............................................................................... -....................................................................... -........................................................................... .................................................................. .

As you can see in the excerpts above, both models for Construction Phases 1-2 and 3-4 included reductions to the Project's Acres of Grading. As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.11 According to the "User Entered Comments & NonDefault Data" table, the justification provided for these changes is: "grading acreage provided by developer" (Appendix H, pp. 61,143,220, 315). However, this change is unaddressed in the Grading Plan (p. 3-78). Furthermore, the Acres of Grading is not just the Project site acreage, but the "cumulative distance traversed on the property by the grading equipment, assuming a blade width of 12 feet."1 2 As a
result, we cannot verify the revised Acres of Grading values, and the model may underestimate the Project's construction-related emissions.

Unsubstantiated Changes to Off-Road Construction Equipment Horsepower and Usage Hours Review of the CalEEMod output files demonstrates that both models for Construction Phase 1-2 and Construction Phase 3-4 include manual changes to the Project's anticipated off-road construction equipment usage hours and horsepower values (Appendix H, pp. 66-74, 148-156, 225-233, 320-328). As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.13 According to the "User Entered Comments & Non-Default Data" table, the justification provided for these changes is: "construction equipment list provided by developer" (Appendix H, pp. 65, 143, 220, 315). However, while the Air Quality Analysis, provided as Appendix Cl to the RDEIR, provides a construction equipment list, many of the usage hours and horsepower values are provided in ranges (see excerpt below) (Appendix Cl, p. 18-20, Table E).
11 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 1 2 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 33 13 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 7 Table E: Diesel Construction Equipment Utilized by Construction Phase Phase Off-Road Off-Road Equipment Hours Used Horse- load No. Phase Name Equipment Type Unit Amount per Day power Factor Rubber-Tired 1 Dozers 5.1 436 0.4
1 Site Preparation
Rubber-Tired 1 5.1 249 0.36 Loaders
Excavators 1 0.2 760 0.38
Graders 2 0.2-2.3 275 0.41
Off-Highway Trucks 8 0.2-8.0 300-1025 0.38
Plate Compactors 1 2.3 554 0.43
1 Grading Rubber-Tired
Dozers 6 0.2-2.3 35�600 0.4
Scrapers 10 2.3 600 0.48
Trractors/loade:rs/ 1 0.6 249 0.37 Backhoes
Excavators 15 0.2-3.0 85-417 0.38
As you can see in the excerpt above, many of the usage hours and horsepower values are provided in ranges. As such, and in order to conduct the most conservative analysis, the RD El R's modeling should have included the greatest usage hours and horsepower values provided in the Air Quality Analysis.

However, review of the Project's CalEEMod output files demonstrates that this is not the case. Until an updated EIR is prepared to provide a revised equipment list specifying the usage hours and horsepower for each piece of equipment, the models may underestimate the Project's construction-related emission and should not eb relied upon to determine Project significance.

Unsubstantiated Changes to Vendor and Worker Trips
Review of the CalEEMod output files demonstrates that the models for both Construction Phase 1-2 and Construction Phase 3-4 include manual changes to the Project's anticipated vendor and worker trip numbers (see excerpts below) (Appendix H, pp. 75,157,234,329).

Fanita Ranch Construction Phase 1-2:

Table Name I Column Name I Default Value
tblTripsAndVMT VendorTripNumber 858.00
I New Value
1v;.,.UU
tlllTripsAndVMT j VendorTripNumber j 858.00 312.00
...................... tlJITr
ipsAndVMT ' ( WorkerTrip umber ( 15.
00 5.00
. -
tlJITripsAndVMT j WorkerTlip umber § 15.00 5.00
tblTlipsAndVMT 1 WorkerTlipNumber 1 3,050.00 588.00
tlJITlipsAndVMT i WorkerTlipNumber 1 3,050.00 1,099.00
tlJITlipsAndVMT j WorkerTlipNumber j 15.00 5.00
Fanita Ranch Construction Phase 3-4:

Table Name Column Name Default Value New Value
8 tblTripsAndVMT J VendorTripNumber J 858.00 312.00
tblTripsAndVMT j VendorTripNumber � 858.00
...... .. · ·
147.00
...................... .
tblTripsAndVMT j VendorTripNumber � 858.00 235.00
tblTripsAndVMT j VendorTripNumber j 858.00 165.00
tblTripsAndVMT \ WorkerTripNumber \ 3,050.00 1,099.00
......................
lb
lTripsAndVMT"""
"""
'"'"" ("'" '"'' WorkerTripNumber ('' 3,050.00 " 525.00 ' ''' - -
tblTripsAndVMT j WorkerTripNumber i 3,050.00 838.00
tblTripsAndVMT t WorkerTripNumber ! 15.00 5.00
"
""'"""'" • 'tb1TripsAndVMT
0 '" 1 WorkerTripNumber � 3,050.00 588.00
tblTripsAndVMT j WorkerTripNumber j 15.00 5.00
As you can see in the excerpt above, the models for both Construction Phase 1-2 and Construction Phase 3-4 include manual reductions to the Project's anticipated vendor and worker trip numbers. As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified. 14 According to the "User Entered Comments & Non-Default Data" table, the justifications provided are:
"assume 1 hauling trip per day, 10 miles per trip (cut and fill balanced onsite)" (Appendix H, pp. 61, 143, 220, 315). However, this justification fails to address any change to the Project's vendor and worker trip numbers. Furthermore, the Air Quality Analysis, provided as Appendix Cl to the RDEIR, states:
"[B]ased on CalEEMod defaults and the number of residential units and floor area of commercial buildings to be built during each phase, the project would generate a maximum of approximately 1,099 worker trips and 312 vendor trips per day" (Appendix Cl, 21).

However, this statement is contradictory to the changes in the model, as the model did not rely upon default vendor and worker trip numbers, but instead on manually reduced vendor and worker trip numbers. Furthermore, it should be noted that the vendor and worker trip numbers indicated in the Air Quality Analysis are per day, while the "Trips and VMT" table in the CalEEMod model should include total vendor and worker trips throughout Project construction. As such, the manual reductions to the vendor and worker trip numbers are unsubstantiated. By including unsubstantiated reductions to the Project's vendor and worker trip numbers, the model may underestimate the Project's constructionrelated emissions and should not be relied upon to determine Project significance.

Incorrect Application of Construction Dust Mitigation Measures Review of the CalEEMod output files reveals that the models for both Construction Phase 1-2 and Construction Phase 3-4 include unsubstantiated construction-related mitigation measures. As a result, the model may underestimate the Project's construction-related emissions and should not be relied upon to determine Project significance.

The following construction-related mitigation measures were included in the models: "Water Exposed Area" and "Water Unpaved Roads," (see excerpt below) (Appendix H, pp. 86, 167, 247, 340). 14 CalEEMod User Guide, available at: http:
//www.caleemod.com/, p. 2, 9
9 3.1 Mitigation Measures Construction
Use Cleaner Engines for Construction Equipment
Use Soil Stabilizer
Replace Ground Cover
ater Exposed Area
ater Un aved Roads
Reduce Vehicle Speed on Unpaved Roads
Clean Paved Roads
As you can see in the excerpt above, the model includes five construction-related mitigation measures.

Furthermore, the model also includes a 26% reduction in particulate matter ("PM") as a result of the "Clean Paved Roads" measure, a moisture content of 0.5 as a result of the "Water Unpaved Roads" measure, and a reduced vehicle speed of 15 miles per hour ("MPH") as a result of the "Reduce Vehicle Speed on Unpaved Roads" measure (see excerpt below) (Appendix B, pp. 61, 143,220,315).

I Table Name I Column Name I Default Value New Value
tlllCoostDustMitigation 1 CleanPavedRoadPercentReduction 1 O 26 tblConstDustMitigation 1 WaterUnpavedRoadMoistureContent 1 O 0.5 tblConstDustMitigation j WaterUnpavedRoadVehicleSpeed j O 15 ............ .... ..... .... ....................... ·........................ .......................... -.............................................. ---------ol!J As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.1
s According to the "User Entered Comments & Non-Default Data" table, the justifications provided are: "fugitive dust control" and "clean engine and dust control" (Appendix H, pp. 61,143,220, 315). Furthermore, while the RDEIR includes MM AIR-1 and MM AIR-2, these air quality measures fail to require the proposed Project to water exposed areas or water unpaved roads. Furthermore, MM AIR-1 and MM AIR-2 fail to mention the 26% reduction in PM, 0.5 moisture content, or a reduced vehicle speed of 15 MPH. As such, we cannot verify that these measures will actually be implemented, monitored, and enforced on the Project site. By including unsubstantiated construction-related mitigation measures, the models may underestimate the Project's construction-related emissions and should not be relied upon to determine Project significance.

Underestimated Number of Natural Gas Fireplaces
Review of the Project's CalEEMod output files demonstrates that the number of fireplaces included in both the mitigated land use plan with school and land use plan without school was reduced to zero (see excerpt below) (Appendix H, pp. 459, 488).

Table Name Column Name Default Value New Value
15 CalEEMod User Guide, available at: http:
//www.caleemod.com/, p. 2, 9
10 tblFireplaces ( NumberGas j 244.75 0.00
.
....
.......
..............................
...
...................
.....
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....
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...............
.................
...
....... i, .. , .......................
...
......................................... .
..............
.............................
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tblFireplaces 1 NumberGas 1 661.65 0.00
........................................................................ .; ....................................................................... r ................................................................... ............................................................. . tblFireplaces ; NumberNoFireplace ; 130.10 0.00
= =
...................................................................... , .................................................................... , .................................................................. ........................................................... , tblFireplaces ! NumberNoFireplace ! 44.50 0.00
: :
tblFireplaces j NumberNoFireplace j 120.30 0.00
.
............................
.......
........
..
.......
......
........
.........
. j ...........
......
.
........
..........
...
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...
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..........
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...................
........................
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................
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.......................................
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tlJIFireplaces j NumberWood j 455.35 0.00
...................................................................... J ... , ................................................................ , ............................................................................................................................ .. tblFireplaces 1 NumberWood 1 155. 75 0.00 ........................................................................... ; .......................................................................... , .......................................................................... ............................................................. .. tblFireplaces j NumberWood j 421.05 0.00 tblFleetMix j HHD j 0.03 0.02
................................................................................................................................................................................................................ -. ................. _"""""'"""=-"' As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified. 16 However, no justification was provided in the "User Entered Comments & Non-Default Data" table for these models (Appendix H, pp. 458-459, 487-488). Furthermore, the GHG Analysis contradictorily states:
"The project has been designed to prohibit wood stoves and fireplaces and to allow a total of six natural gas fire pits / fireplaces within the community areas of the villages (Project Design Feature (PDF)-AQ/GHG-1)" (p. 22).

As such, the Project is expected to include 6 natural gas fire pits/fireplaces, while the models include 0.

This presents an issue, as CalEEMod uses the number of fireplaces to calculate the Project's area-source operational emissions. 17 Thus, by including unsubstantiated reductions to the Project's anticipated number of fireplaces, the model underestimates the Project's area-source operational emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Energy Use Values
Review of the Project's CalEEMod output files demonstrates that the mitigated land use plan with school and mitigated land use plan without school included several changes to the Project's energy use values, including the Nontitle-24 Electricity Energy Intensity ("NT24E"), Nontitle-24 Natural Gas Energy Intensity ("NT24NG"), Title-24 Electricity Energy Intensity ("T24E"), and the Title-24 Natural Gas Energy Intensity ("T24NG") (see excerpt below) (Appendix H, pp. 459,488).

Table Name Column Name Default Value
16 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 17 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 41 11 New Value
tblEnergyUse / NT24E f 3,172.76 3,490.04
•••u1u11111,,,.,11u1•11ouo11u1111111011111uoo111011111111111011uj1,01u1111,111111111011u11,1,n111111n1111n1111,11un1n1u11111i,111011111111u11u1101,11111uu1n110no,.,,,.,,1,01,u11111111,1 1H11t1111111111111u111111 .. 11u1u111111101u11t111n1u10 tblEnergyUse l NT24E i 3,172
.
76 3,490.04
,,.,,,,.,.,,,,,,.,,,,,,.,,,,,.,.,,,.,,,,,,.,,, . .,,,,,,.,,.,, .. ,.,,, .. ,,.,j • .,,,.,.,.,,.,.,,,.,,.,,,.,,.,,,.,,.,.,,,..,,,.,, .. ,,,,,HooooHoHoi•uo,,.e,uoooaoo,,,,.,,.,,..,,,.,, • .,,,.,.,,.,,,.,,,.,, .. .,,,..,. ''"'''"'"''"''""''"'"'"''"''"'"'""'''"'"'''"'" .. ""'''"' tblEnergyUse j NT24E j 6,155.97 6,771.57
......................................................................... ; ......................................................................... i, ..................................................................... ............................................................... . tblEnergyUse !
NT24NG !
4,180.00 0.00
"""""'"""""""
tblEnergyUse
""""""""""""" l
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G
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l """""""""""""'"
4, 180
.
00 '""""""' """"""" """" •" """ "'" '
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oo
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tblEnergyUse i NT24 G l 4,180.00 0.00
tblEnergyUse !
T24E j
260.86 300.04
..................................................................... ,1 ... , ................................................................ , ................................................................... ........................................................... . tblEnergyUse l T24E i 260.86 300.04
........................................................................ j .......................................................................... ( ..................................................................... .............................................................. .. tblEnergyUse j T24E j 331 .
07 380.75
tblEnergyUse i T24NG r 7,045.49 0.00
tblEnergyUse j T24NG j 7,045.49 0.00
.......................
tblEnergyUse
...•......•......•... L .................

T24NG
..•......•......•......•.... L ................. 1
9 ,
206
.
92 •......•......•......•..
o.oo
As you can see in the excerpt above, the natural gas energy intensity values, including NT24NG and T24NG, were reduced to zero, while the electricity energy intensity values, including NT24E and T24E, were minimally increased. As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.18 According to the "User Entered Comments & Non-Default Data" table, the justifications provided for these changes are: "All electric homes increased electrical usage an natural gas usage set at zero" and "All Electric homes" (Appendix H, pp. 459,488). Furthermore, the RDEIR states that the Project would include:
"All-Electric Homes. Prior to the issuance of building permits, the applicant or its designee shall provide evidence to the City of Santee that the proposed project will include all-electric homes.

No natural gas shall be provided to the residential portion of the proposed project" (p. 4.7-25).

However, the RDEIR and associated appendices fail to disclose any information to demonstrate how the above energy use values were calculated, or even substantiate their inclusion in the model. Until an updated EIR is prepared to provide calculations for the revise energy use values, we cannot verify these changes. This presents an issue, as the energy use values are used by CalEEMod to calculate the Project's emissions associated with building electricity and non-hearth natural gas usage. 19 Thus, by
including unsubstantiated energy use values, the models may underestimate the Project's operational emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Vehicle Emission Factors
Review of the CalEEMod output files for both the land use plan with school and the land use plan without school demonstrates that the operational vehicle emission factors were manually altered (Appendix H, pp. 408-410, 435-437, 463-465, 493-493). As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.20 However, the RDEIR and associated appendices fail to justify these changes for three reasons. 18 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 19 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 43 2 ° CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 12 First, while no justification was provided in the "User Entered Comments & Non-Default Data" table for the changes to the Project's vehicle emission factors, the justification provided for the changes to the Project's fleet mix is: "from EMFAC for SD air basin 2035" (Appendix H, pp. 404-405, 431-432, 458-459, 487-488). However, this justification is insufficient, as EMFAC refers to an entire database, not a specific set of vehicle emission factors.21 Thus, the RDEIR and associated appendices should have specified which input parameters were used to obtain the vehicle emission factors inputted in the model. Without specific input parameters, we cannot verify the altered vehicle emission factors, and the changes may be incorrect.

Second, the GHG Analysis, provided as Appendix H to the DEIR, states:
"Emission factors representing the vehicle mix and emissions for 2035 were used to estimate emissions associated with full buildout of the project" (Appendix H, p. 4).

However, this justification fails to justify the specific changes made the Project's anticipated vehicle emission factors. As such, we cannot verify the altered vehicle emission factors, and the changes may be incorrect.

Third, contradictorily, the GHG Analysis states:
"Accounted for in EMFAC 2016 vehicle emission factors as part of CalEEMod Version 2016

3.2.25" (Appendix H, p. 25, Table H).

As you can see in the excerpt above, the RDEIR's GHG Analysis indicates that CalEEMod default values for vehicle emission factors were utilized to estimate the Project's mobile-source operational emissions.

As such, the changes made to the Project's operational vehicle emission factors are inconsistent with the information provided in the GHG Analysis.

As discussed above, we cannot verify the changes made to the Project's operational vehicle emission factors. This presents an issue, as the vehicle emission factors are used by CalEEMod to calculate the Project's emissions associated with operational on-road vehicles.22 Thus, by including unsubstantiated changes to the Project's operational vehicle emission factors, the models may underestimate the Project's operational emissions and should not be relied upon to determine Project significance.

Underestimated Daily Vehicle Trips
According to the Transportation Impact Analysis ("TIA"), provided as Appendix N to the RDEIR, the Project is estimated to generate 26,272 daily vehicle trips, including pass-by and internal trip reductions, throughout the Project's operation (see excerpt below) (Appendix N, p. 53, Table 7-2). 21 "EMFAC2017 Web Database." (ARB, available at: https://arb.ca.gov/emfac/2017/. 22 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 13 Gros, Trip C.n,rotion 31,113 1.188 1,010 3,198 1,9:4 1,03: 1,956 (E+Q) R Tot:tl Primal'} Trip� :s:u 9:1 l,'80 :,
101 J,s:;: 91' :.7-4: (E-G-J-L-�l-c'-0-P)
Toe,! P•,;-By Dinrctd Linll. Trip R•ducrion (:,;:ooi (:6") (130) (497) (99) (lli'J (:14) (BTK However, review of the Project's CalEEMod output files demonstrates that the model for the mitigated land use plan with school only calculated 9,448.76 Weekday, 8,923.12 Saturday, and 8,923.12 Sunday vehicle trips, based on the trip rates inputted (see excerpt below) (Appendix H, pp. 474) . .................................. ,
en s
..
ow
... 1
se
........................ : .......... , ................... L ...... .' .................................. : .. 2 ...... :; Apartments Low Rise E 1,274.55 i 1,270.20 1270.20 E
""'"""""'"'"""""""""'""""'""
.
'""""'"""'"""'"'""""""""""""'""'"'""'I"""'"""" '"""'""""""'"""?""'""'""'""'"""""""""""""'""""""'""""""'P City Park : 491 .25 ! 491 .25 491 .25 :
..................................................................................................................... ), ....................................................... r, Elementary School : �00. D ! 0.00 0.00 :
......................

General Light Industry
....................... t .........

41.69 .......... !'""'"' 41.69
..................

41.69 ......... i
..................................................................................................................... ., ••••••••••••••••••••••••••••••••••••••••••••••••••••••• ,r. Regional Shopping Cen er E 465.DO i 464.40 464.40 E ······················································································································1·······················································•11 Retirement Community : 614.111() : 614.10 614.10 :
1•111111a111111a11II11a111111a111111 •• lltllaUIHl•t IUUaHUII •111111•111111• I IIIHI IIHl l•HHH•H 1111•111111a 1111)1a 1111 UalU UlalUUtall UUaU 1111a111111a111111a11111D Sin le Famil Housin l! 3.524.79 l 3,512.76 3512.76 l!
As you can see in the excerpt above, the Weekday, Saturday, and Sunday vehicle trips were underestimated by approximately 16,823, 17,349, and 17,349 trips, respectively. Furthermore, review of the Project's CalEEMod output files demonstrates that the model for the mitigated land use plan without school only calculated 9,585.78 Weekday, 9,554.31 Saturday, and 9,554.31 Sunday vehicle trips, based on the trip rates inputted (see excerpt below) (Appendix H, pp. 502-503). an se ay
Apartments Low Rise l! 2,667.28 l 2,658.62 2658.62 l!
.....................................................................................•................................ ,........................................................ ...

Apartments Low Rise i 1,33:9.8,0 ! 1,335.45 1335.45 i
.....................................................................................•................................ , ........•...........................•.............•..... ,, City Park : 516.41() : 515.62 515.62 :

General Light Industry � 41.69 i 41.69 41.69 §
...................................................................................................................... >·-...................................................... ,.. Regional Shopping Center : 488.40 ; 487.80 487.80 :
.....................................................................................•............................... , ........................................................• Retirement Community s 645.25 ! 640.80 640.80 s
...................................................................................................................... >··"""""""""""""""""'""""""""""""'""""'"" Sin le Famil Housin : 3,88:6.96 : 3,874.34 3874.34 :

As you can see in the excerpt above, based on available trip generation data, the Weekday, Saturday, and Sunday vehicle trips were underestimated by approximately 16,686, 16,718, and 16,718 trips, respectively. As such, the Project's CalEEMod models are inconsistent with the trip generation estimates 14 provided in the TIA. As a result, the models underestimate the Project's mobile-source operational emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Vehicle Fleet Mix
Review of the CalEEMod output files for the land use plan with school and the land use plan without school demonstrates that the fleet mix percentages values were manually altered, including reductions to the percentage of heavy-heavy duty trucks ("HHD") anticipated (Appendix H, pp. 405-408, 432-434, 459-462, 488-491). As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.23 According to the "User Entered Comments & Non-Default Data" table, the justification provided for these changes is: "from EMFAC for SD air basin 2035" (Appendix H, pp. 405, 432). However, this justification is insufficient, as EMFAC refers to an entire database, not a specific set of fleet mix percentages values.2
4 Thus, the RDEIR and associated appendices should have specified which input parameters were used to obtain the vehicle fleet mix percentage values inputted in the model. Without specific input parameters, we cannot verify the altered fleet mix, and the changes may be incorrect.

Furthermore, contradictorily, the RDEIR states:
"CalEEMod default emissions factors and vehicle fleet mix were conservatively used for the model inputs to estimate daily emissions from proposed vehicular sources" (emphasis added) (Appendix H, p. 4).

As you can see in the excerpt above, the RDEIR's GHG Analysis indicates that CalEEMod default values were utilized to estimate the Project's mobile-source operational emissions. Furthermore, the GHG Analysis states:
"Emission factors representing the vehicle mix and emissions for 2035 were used to estimate emissions associated with full buildout of the project" (Appendix H, p. 4).

However, this justification only relates to emission factors, not the Project's operational vehicle fleet mix. As a result, the RDEIR and associated appendices fail to justify any change to the Project's anticipated operational vehicle fleet mix. This presents an issue, as the fleet mix percentages are used by CalEEMod to calculate the Project's emissions associated with operational on-road vehicles.25 By including unsubstantiated changes to the Project's operational vehicle fleet mix, the model may underestimate the Project's mobile-source operational emission and should not be relied upon to determine Project significance.
2) Failure to Demonstrate Consistency with the Sustainable Santee Plan As discussed above, the RDEIR relies upon the Project's consistency with the Sustainable Santee Plan in order to conclude that the Project would result in a less than significant GHG impact (p. 4.7-31). 23 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 24 "EMFAC2017 Web Database." CARB, available at: https://arb.ca.gov/emfac/2017/. 25 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 15 However, review of the Sustainable Santee Plan reveals that the proposed Project is inconsistent with numerous checklist measures required by the plan, including but not limited to those listed below:

Sustainable Santee Plan26
Energy Efficiency
Land Use Sector-Residential
Measure 2.1: New residential construction meet or Here, the RDEIR states: "The proposed project exceed California Green Building Standards Tier 2 would comply with 2019 Title 24, Part 6, Standards Voluntary Measures, such as obtaining green and implement Mitigation Measure AIR-8, which building ratings including LEED, Build it Green, or requires the use of high-efficiency equipment and Energy Star Certified building certifications in fixtures that exceed 2016 California Green Building scoring development and explain the measures Standards Code and 2019 Title 24 standards by 14 implemented. percent. Mitigation Measure AIR-8 would apply to the entire residential portion of the proposed
project" p. 4.7-29, Table 4.7-12). However, while
the Project commits to exceeding the 2019 Title 24
Standards by 14%, the RDEIR fails to mention
whether or not the Project would obtain any green
building certifications, such as LEED or Build it
Green. As such, we cannot verify that this measure
would be fully implemented, monitored, and
enforced on the Project site. Furthermore, the
RDEIR fails to mention green building ratings
including LEED, Build it Green, and Energy Star
Certified. Thus, the RDEIR's consistency evaluation
should not be relied upon to determine Project
significance.

Land Use Sector-Commercial ,,
Measure 4.1: New commercial units meet or Here, the RDEIR states: "The proposed project exceed California Green Building Standards Tier 2 would comply with 2019 Title 24, Part 6, Standards Voluntary Measures such as obtain green building and implement Mitigation Measure AIR-8. ratings including: LEED, Build it Green, or Energy Implementation of this goal would result in the Star Certified buildings certifications in scoring proposed project increasing the energy efficiency development and explain the measures of commercial buildings by an additional 14 implemented. percent, consistent with the City's performance metric. Therefore, after mitigation, the proposed
project would be consistent with Goal 4" (p. 4.7-29,
Table 4.7-12). However, while the Project commits
26 "Sustainable Santee Plan: The City's Roadmap to Greenhouse Gas Reductions." City of Santee, December 2019, available at: https://www.cityofsanteeca.gov/home/showdocument?id=18422, pp. 195-199. 16 to exceeding the 2019 Title 24 Standards by 14%,
the RDEIR fails to mention whether or not the
Project would obtain any green building
certifications, such as LEED or Build it Green. As
such, we cannot verify that this measure would be
fully implemented, monitored, and enforced on
the Project site, and the RDEIR's consistency
evaluation should not be relied upon to determine
Project significance.
-
Advanced Goals Measures
Land Use Sector-Commercial
Measure 5.2: Project uses light-reflecting surfaces Here, while the RDEIR states that the Project would such as enhanced cool roofs on commercial "encourage the use of light-colored, semibuildings. reflective, or cool-roof technology for all roofing within the proposed project, including at least
60,000 square feet of commercial rooftops," the
RDEIR fails to require this measure (p. 4.7-29, Table

4.7-12}. As such, we cannot verify that this
measure would be implemented, monitored, and
enforced on the Project site, and the RDEIR's
consistency evaluation should not be relied upon
to determine Project significance.

Transportation
..

Land Use Sector-Residential and Commercial
Measure 7.1: Install electric vehicle chargers in all Here, the RDEIR states: "Mitigation Measure AIR-7 new residential and commercial developments. requires the proposed project to include electric vehicle chargers, consistent with the City's goal to
a. For new Single-Family Residential, install install 4,500 EVSE by 2035. The proposed project complete 40 Amp electrical service and would install a total of 1,572 electric vehicle one e-charger. chargers (e-chargers) as follows: the proposed b. For new Multifamily Residential, install e- project would install 1,203 240-volt Level 2 EVSE in chargers for 13 percent of total parking. each low density residential garage; a total of 354 c. c. For new Office Space, Regional Shopping EVSE within the parking areas of Medium Density Centers, and Movie Theaters, install e- Residential, Village Center, and Active Adult chargers for 5 percent of total parking residential uses; and 15 EVSE within the proposed spaces. project's commercial parking lots. Additionally, d. d. For new Industrial and other Land Uses Mitigation Measure GHG-6 would provide 100 employing 200 or more employees, install electric vehicles to project residents" (p. 4.7-30, e-charges for 5 percent of total parking Table 4.7-12}. However, the RDEIR fails to spaces. demonstrate that the Project would install
complete 40 Amp electrical service and one e17
charger for new single family residences; install echargers for 13 percent of total parking for new multifamily residences; install e-chargers for 5
percent of total parking spaces for office space,
regional shopping centers, and movie theatres; and
install e-charges for 5 percent of total parking
spaces for new industrial and other land uses
employing more than 200 employees, as is
required for this measure. As such, we cannot
verify that this measure would be implemented,
monitored, and enforced on the Project site, and
the RDEIR's consistency evaluation should not be
relied upon to determine Project significance.

Measure 8.1: Implement traffic flow improvement Here, the RDEIR states: "[t]he proposed Project program. would include roundabouts at key intersections" a. Install smart traffic signals at intersections
warranting a traffic signal, OR
b. Install roundabout.

Solid Waste 1
Land Use Sector-Residential and Commercial
Measure 9.1: Reduce waste at landfills.
and "Mitigation Measure TRA-16 requires
installation of Adaptive Traffic Signal Control (e.g.,
smart signals) along Mission Gorge Road between
Fanita Drive and Town Center Parkway to improve
traffic flow and reduce project transportation
impacts along that roadway" (p. 4.7-30 & 4.7-32,
Table 4.7-12 & Table 4.7-13). However, the RDEIR
fails to specify where the roundabouts would be
located and how this measure would be
implemented, monitored, and enforced on the
Project site. As such, the RDEIR's consistency
evaluation should not be relied upon to determine
Project significance.
.I'
Here, the RDEIR states: "Mitigation Measure GHG2 requires the applicant to institute recycling and composting services to divert at least 90 percent of
the proposed project's operational waste,
consistent with the City's performance metric. The
proposed project would also recycle or reuse at
least 70 percent of the construction waste, soil,
and debris by 2030 and 80 percent starting in 2030.

Therefore, after mitigation, the proposed project
would be consistent with Goal 9" (p. 4.7-32, Table

4.7-13). However, the RDEIR fails to demonstrate
18 Clean Energy
Land Use Sector-Residential and Commercial
Measure 10.1: Increase distributed energy
generation within City of Santee by implementing
the following applicable photovoltaic solar
systems:
a. Single-family residential to install at least
2kW per unit of PV solar systems, unless
the installation is infeasible due to poor
solar resources established in a solar
feasibility study prepared by a qualified
solar consultant submitted with an
application
b. Multifamily residential to install at least
lkW per unit of PV solar systems, unless
the installation is infeasible due to poor
solar resources established in a solar
feasibility study prepared by a qualified
solar consultant submitted with an
applicant's formal project submittal to City.
c. On commercial buildings, install at least 2
kW per square foot of building area (e.g.,
2,000 sq. ft.= 3 kW) unless the installation
is infeasible due to poor solar resources.
how this measure would be implemented,
monitored, and enforced on the Project site. As
such, the RDEIR's consistency evaluation should
not be relied upon to determine Project
significance.
!
Here, the RDEIR states: "The proposed project
would implement Mitigation Measure GHG-1 and
supply at least 12.147 megawatts for the preferred
land use plan with school or 12.083-megawatt
capacity for the land use plan without school by
buildout, consistent with the City's performance
metric. Therefore, after mitigation, the proposed
project would be consistent with Goal 1011 (p. 4.-32,
Table 4.7-13). However, the RDEIR fails to
demonstrate that at least 2kW of PV solar systems
would be installed per single family residential unit;
at least lkW of PV solar systems would be installed
per multifamily residential unit; and at least 2 kW
per square foot of building area (e.g., 2,000 sq. ft.=
3 kW) would be installed for commercial land uses,
as is required for the measure. As such, we cannot
verify that this measure would be implemented,
monitored, and enforced on the Project site, and
the RDEIR's consistency evaluation should not be
relied upon to determine Project significance.

As the above table indicates, the RDEIR fails to provide sufficient information and analysis to demonstrate the Project's consistency with numerous measures required by the Sustainable Santee Plan. Thus, we cannot verify that the Project would be consistent with the Sustainable Santee Plan. As a result, we recommend that an updated EIR be prepared to include further information and analysis demonstrating the Project's consistency.
3) Updated Analysis Indicates Significant CHG Impact
Applicable thresholds and modeling demonstrate that the proposed Project may result in a potentially significant GHG impact not previously identified or addressed by the RDEIR.

The CalEEMod output files, modeled by SWAPE utilizing Project-specific information as disclosed in the RDEIR, disclose the land use plan with school's mitigated emissions, which include approximately 19 129,240 MT C02e of total construction emissions (sum of 2021 through 2033 construction emissions for Construction Phase 1-2 and Construction Phase 3-4) and approximately 67,343 MT C02e/year of annual operational emissions (sum of area, energy, mobile, waste, and water-related emissions). When we compare the land use plan with school's amortized construction and operational GHG emissions to the threshold of 1.77 MT C02e/SP/year, we find that the land use plan with school's GHG emissions exceed the threshold (see table below).

SWAPE Annual Greenhouse Gas Emissions with School
Proposed
Project Phase Project {MT
C02e/year)
Construction (amortized over 30 years) 43,07.99
Area 46.18
Energy 13,351.49
Mobile 50,174.08
Waste 0.00
Water 3,771.49
Total 71,651.23
Service Population 8,424
Efficiency 8.51
Threshold 1.77
Exceed? Yes
Furthermore, the CalEEMod output files, modeled by SWAPE utilizing Project-specific information as disclosed in the RDEIR, disclose the land use plan without school's mitigated emissions, which include approximately 129,240 MT C02e of total construction emissions (sum of 2021 through 2033 construction emissions for Construction Phase 1-2 and Construction Phase 3-4) and approximately 68,536 MT C02e/year of annual operational emissions (sum of area, energy, mobile, waste, and waterrelated emissions). When we compare the land use plan with school's amortized construction and operational GHG emissions to the threshold of 1.77 MT C02e/SP/year, we find that the land use plan with school's GHG emissions exceed the threshold (see table below).

SWAPE Annual Greenhouse Gas Emissions without School
Proposed
Project Phase Project {MT
C02e/year)
Construction (amortized over 30 years) 4,307.99
Area 46.89
Energy 13,411.99
Mobile 51,311.70
Waste 0.00
Water 3,765.61
20 Total 72,844.17
Service Population 8,424
Efficiency 8.65
Threshold 1.77
Exceed? Yes
As the above tables demonstrate, when correct input parameters are used to model emissions associated with both the land use plan with school and the land use plan without school, we find a significant impact not previously assessed or identified in the RDEIR. As a result, an updated GHG analysis should be prepared in an EIR and additional mitigation should be incorporated into the Project, such as those listed below.

Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated The RDEIR conducts a health risk assessment ("HRA") for Project construction, and concludes that, after the implementation of MM AIR-3 and MM AIR-4, the maximum mitigated cancer risk posed to off-site sensitive receptors would be 2.84 in one million (see excerpt below) (Appendix C2, p. 19).

Table C: Project Construction Mitigated Cancer Risk (in one million) Receptor 3,d 0-2 2-16 16-30 ProJed Cons�ruction
No. Description Trimester Years Years Years hposure•
12 On-site- 0.22 Highest/Southwest Comer 5.40 6.56 1.00 9.96 22 On° site - z•• Highest 0.20 4.86 5.91 0.90 8.97
13 On-site -3"' Highest 0.19 4.64 5.64 0.86 8.56
23 On-site -4"' Highest 0.18 4.38 5.33 0.81 8.08
4 On-site -5"' Highest 0.18 4.27 5.19 0.79 7.87
72 On-site - Northwest Co mer 0.08 1.88 2.28 0.35 3.46
75 On-site - Northeast Gomer 0.05 1.17 1.42 0.22 2.16
11 On-site -Southeast Comer 0.05 1.31 1.60 0.24 vu
1 Off-site - Southwest 0.06 1.37 1.67 0.25 2.37
2 Off-site - Southeast 0.06 1.42 1.72 0.26 2.23
3 Off-site -Southeast 0.08 1.86 2.27 0.35 2.84
As a result, the RDEIR concludes that the Project's excess cancer risk would not exceed the SDAPCD threshold of 10 in one million, and the Project would have a less than significant health risk impact (p. 19). Regarding the Project's operational health risk impact, the RDEIR states:
"[T]he commercial component of the Fanita Ranch Project does not include specific uses or tenants but does allow the types of businesses, such as gasoline dispensing stations, that could emit TACs. However, location and operational detials of those facilities are currently unknown" (Appendix C2, p. 20).

As such, instead of conducting an HRA for the entire Project's operation, the RDEIR implements MMAIR-12, which states:
"The City of Santee shall require the applicant to avoid siting new on-site toxic air contaminant sources in close vicinity of residences and schools. Gasoline dispensing facilities with a throughput of less than 3.6 million gallons per year must have the gasoline dispensers at least 21 50 feet from the nearest residential land use, day care center, or school. In addition, gasoline dispensing facilities with a throughput of 3.6 million gallons per year, distribution centers, and dry cleaning operations are prohibited within the project" (Appendix C2, p. 20).

However, the RDEIR's HRA and less-than-significant impact conclusion is incorrect for four reasons.

First, the RDEIR's construction HRA is incorrect, as it relies upon exhaust PM10 estimates from an incorrect and unsubstantiated CalEEMod model, as discussed above (Appendix C2, p. 10). Thus, the HRA utilizes an underestimated DPM concentration to calculate the health risk associated with Project construction. As a result, the Project's construction HRA is underestimated and should not be relied upon to determine Project significance.

Second, the RDEIR's reliance on MM AIR-3, which requires the use of Tier 4 Final equipment during construction, is incorrect (Appendix C2, p. 18). As discussed above, the RDEIR failed to evaluate the feasibility of obtaining Tier
4 Final equipment. As the RDEIR fails to demonstrate that MM AIR-3 is feasible for the proposed Project, we cannot verify that the Project's health risk impact would be reduced to a less than significant level as claimed.

Third, the RDEIR failed to conduct a quantified operational HRA. By failing to prepare an operational HRA, the Addendum is inconsistent with recommendations set forth by the Office of Environmental Health and Hazard Assessment's ("OEHHA") most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments, as referenced by the RDEIR (Appendix C2, p. 10). Once construction of the Project is complete; the Project will operate for a long period of time. The RDEIR's Transportation Impact Analysis ("TIA"), provided as Appendix N to the RDEIR, indicates that the Project would generate 26,272 daily vehicle trips throughout operation, including pass-by and internal trip reductions, which will result in additional exhaust, thus continuing to expose nearby sensitive receptors to emissions (Appendix N, p. 53, Table 7-2). The OEHHA document recommends that exposure from projects lasting more than 6 months should be evaluated for the duration of the project, and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident ("MEIR").27 Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, we recommend that health risk impacts from Project operation also be evaluated, as a 30-year exposure duration vastly exceeds the 6-month requirement set forth by OEHHA. These recommendations reflect the most recent health risk policy, as referenced by the Addendum, and as such, we recommend that an updated assessment of health risk impacts posed to nearby sensitive receptors from Project operation be included in an updated EIR for the Project.

Fourth, review of the RDEIR demonstrates that, while the Project did conduct a construction HRA that evaluates the health risk impacts to nearby, existing receptors, the HRA fails to evaluate the cumulative 27 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 8-6, 8-15. 22 lifetime cancer risk to nearby, existing receptors as a result of Project construction and operation together. According to OEHHA guidance, as referenced by the RDEIR, "the excess cancer risk is calculated separately for each age grouping and then summed to yield cancer risk at the receptor location".28 However, the HRA conducted in the RDEIR failed to sum each age bin to evaluate the total cancer risk over the course of the Project's construction and operation. This is incorrect and thus, an updated analysis should quantify the Project's construction and operational health risks and then sum them to compare to the SDAPCD threshold of 10 in one million, as referenced by the RDEIR (Appendix C2, p. 17).

Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project's GHG emissions may result in potentially significant impacts.

In an effort to reduce the Project's emissions, we identified several mitigation measures that are applicable to the proposed Project. Feasible mitigation measures can be found in CAPCOA's Quantifying Greenhouse Gas Mitigation Measures.29 Therefore, to reduce the Project's emissions, consideration of the following measures should be made:

Measures - Energy
Building Energy Use
BE-2 Install Programmable Thermostat Timers
Range of Effectiveness: Best Management Practice - Influences building energy use for heating and cooling.

BE-3 Obtain Third-party HVAC Commissioning and Verification of Energy Savings (to be grouped with BE-1) Range of Effectiveness: Not applicable on its own. This measure enhances the effectiveness of BE-1.

BE-5 Install Energy Efficient Boilers
Range of Effectiveness: 1.2-18.4% of boiler GHG emissions.

Lighting
LE-1 Install Higher Efficacy Public Street and Area Lighting Range of Effectiveness: 16-40% of outdoor lighting.

LE-2 Limit Outdoor Lighting Requirements
Range of Effectiveness: Best Management Practice, but may be quantified.

LE-3 Replace Traffic Lights with LED Traffic Lights
Range of Effectiveness: 90% of emissions associated with existing traffic lights.

Alternative Energy Generation
AE-1 Establish Onsite Renewable or Carbon-Neutral Energy Systems- Generic 28 "Guidance Manual for preparation of Health Risk Assessments." OEHHA, February 2015, available at:
https:// oeh ha.ca .gov /media/down loads/crn r /2015gu idancema n ual. pdf p. 8-4 29 http://www. ca pcoa. org/wp-content/ u pl oa ds/2010/11/ CAPCOA-Qu a ntification-Report-9-14-F in a I. pdf 30 "Quantifying Greenhouse Gas Mitigation Measures." California Air Pollution Control Officers Association (CAPCOA), August 2010, available at: http://www.capcoa.org/wp content/uploads/2010/11/CAPCOAQu antification-Report-9-14-Fi na I. pdf, p. 23 Range of Effectiveness: 0-100% of GHG emissions associated with electricity use.

AE-3 Establish Onsite Renewable Energy System -Wind Power Range of Effectiveness: 0-100% of GHG emissions associated with electricity use.

AE-4 Utilize a Combined Heat and Power System
Range of Effectiveness: 0-46% of GHG emissions associated with electricity use.

AE-5 Establish Methane Recovery in Landfills
Range of Effectiveness: 73-77% reduction in GHG emissions from landfills without methane recovery.

AE-6 Establish Methane Recovery in Wastewater Treatment Plants Range of Effectiveness: 95-97% reduction in GHG emissions from wastewater treatment plants without recovery.

Measures - Transportation
I ,· ,, ,! ,j
land Use/location
LUT-1 Increase Density
Range of Effectiveness: 0.8-30% VMT reduction and therefore a 0.8-30% reduction in GHG emissions.

LUT-2 Increase Location Efficiency
Range of Effectiveness: 10% VMT reduction and therefore 10-65% reduction in GHG emissions.

LUT-3 Increase Diversity of Urban and Suburban Developments (Mixed Use) Range of Effectiveness: 9-30% VMT and therefore 9-30% reduction in GHG emissions.

LUT-4 Increase Destination Accessibility
Range of Effectiveness: 6.7-20% VMT reduction and therefore 6.7-20% reduction in GHG emissions.

LUT-5 Increase Transit Accessibility
Range of Effectiveness: 0.5-24.6% VMT reduction and therefore 0.5-24.6% reduction in GHG emissions.

LUT-6 Integrate Affordable and Below Market Rate Housing Range of Effectiveness: 0.04-1.20% VMT reduction and therefore 0.04-1.20% reduction in GHG emissions.

LUT-7 Orient Project Toward Non-Auto Corridor
Range of Effectiveness: Grouped strategy (see LUT-3).

LUT-8 Locate Project near Bike Path/Bike Lane
Range of Effectiveness: Grouped strategy (see LUT-4).

Neighborhood/Site Enhancements
SDT-1 Provide Pedestrian Network Improvements, such as:
• Compact, mixed-use communities
• Interconnected street network
• Narrower roadways and shorter block lengths
• Sidewalks
• Accessibility to transit and transit shelters
• Traffic calming measures and street trees
• Parks and public spaces
• Minimize pedestrian barriers
Range of Effectiveness: 0-2% VMT reduction and therefore 0-2% reduction in GHG emissions. 24 SDT-2 Provide Traffic Calming Measures, such as:
• Marked crosswalks
• Count-down signal timers
• Curb extensions
• Speed tables
• Raised crosswalks
• Raised intersections
• Median islands
• Tight corner radii
• Roundabouts or mini-circles
• On-street parking
• Planter strips with trees
• Chicanes/chokers
Range of Effectiveness: 0.25-1% VMT reduction and therefore 0.25-1% reduction in GHG emissions.

SDT-3 Implement a Neighborhood Electric Vehicle (NEV) Network.

Range of Effectiveness: 0.5-12.7% vehicle miles traveled (VMT) reduction since NEVs would result in a mode shift and therefore reduce the traditional vehicle VMT and GHG emissions. Range depends on the available NEV network and support facilities, NEV ownership levels, and the degree of shift from traditional.

SDT-4 Create Urban Non-Motorized Zones
Range of Effectiveness: Grouped strategy (see SDT-1).

Parking Policy/Pricing
PDT-1 Limit Parking Supply through:
• Elimination (or reduction) of minimum parking requirements • Creation of maximum parking requirements
• Provision of shared parking
Range of Effectiveness: 5-12.5% VMT reduction and therefore 5-12.5% reduction in GHG emissions.

PDT-2 Unbundle Parking Costs from Property Cost
Range of Effectiveness: 2.6-13% vehicle miles traveled (VMT) reduction and therefore 2.6-13% reduction in GHG emissions.

PDT-3 Implement Market Price Public Parking (On-Street) Range of Effectiveness: 2.8-5.5% VMT reduction and therefore 2.8-5.5% reduction in GHG emissions.

PDT-4 Require Residential Area Parking Permits
Range of Effectiveness: Grouped strategy (see PPT-1, PPT-2, and PPT-3).

Commute Trip Reduction Programs
TRT-1 Implement Commute Trip Reduction (CTR) Program - Voluntary • Carpooling encouragement
• Ride-matching assistance
• Preferential carpool parking
• Flexible work schedules for carpools
25 •
•
•
•
•
•
Half time transportation coordinator
Vanpool assistance
Bicycle end-trip facilities (parking, showers and lockers) New employee orientation of trip reduction and alternative mode options Event promotions and publications
Flexible work schedule for employees
Transit subsidies
Parking cash-out or priced parking
Shuttles
Emergency ride home
Range of Effectiveness: 1-6.2% VMT reduction and therefore 1-6.2% reduction in commute trip GHG emissions.

TRT-2 Implement Commute Trip Reduction (CTR) Program - Required Implementation/Monitoring •
•
Established performance standards (e.g. trip reduction requirements) Required implementation
Regular monitoring and reporting
Range of Effectiveness: 4.2-21% VMT reduction and therefore 4.2-21% reduction in commute trip GHG emissions.

TRT-3 Provide Ride-Sharing Programs
•
•
Designate a certain percentage of parking spaces for ride sharing vehicles Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles Providing a web site or messaging board for coordinating rides Permanent transportation management association membership and funding requirement .

Range of Effectiveness: 1-15% VMT reduction and therefore 1-15% reduction in commute trip GHG emissions.

TRT-4 Implement Subsidized or Discounted Transit Program Range of Effectiveness: 0.3-20% VMT reduction and therefore a 0.3-20% reduction in commute trip GHG emissions.

TRT-5 Provide Ent of Trip Facilities, including:
•
•
•
Showers
Secure bicycle lockers
Changing spaces
Range of Effectiveness: Grouped strategy (see TRT-1 through TRT-3).

TRT-6 Encourage Telecommuting and Alternative Work Schedules, such as:
• Staggered starting times
• Flexible schedules
• Compressed work weeks
Range of Effectiveness: 0.07-5.5% VMT reduction and therefore 0.07-5.5% reduction in commute trip GHG emissions.

TRT-7 Implement Commute Trip Reduction Marketing, such as:
• New employee orientation of trip reduction and alternative mode options Event promotions
Publications
Range of Effectiveness: 0.8-4% VMT reduction and therefore 0.8-4% reduction in commute trip GHG emissions. 26 TRT-8 Implement Preferential Parking Permit Program
Range of Effectiveness: Grouped strategy (see TRT-1 through TRT-3).

TRT-9 Implement Car-Sharing Program
Range of Effectiveness: 0.4-0.7% VMT reduction and therefore 0.4-0.7% reduction in GHG emissions.

TRT-10 Implement School Pool Program
Range of Effectiveness: 7.2-15.8% in school VMT reduction and therefore 7.2-15.8% reduction in school trip GHG emissions.

TRT-11 Provide Employer-Sponsored Vanpool/Shuttle
Range of Effectiveness: 0.3-13.4% VMT reduction and therefore 0.3-13.4% reduction in commute trip GHG emissions.

TRT-12 Implement Bike-Sharing Programs
Range of Effectiveness: Grouped strategy (see SDT-5 and LUT-9).

TRT-13 Implement School Bus Program
Range of Effectiveness: 38-63% School VMT reduction and therefore 38-63% reduction in school trip GHG emissions.

TRT-14 Price Workplace Parking, such as:
• Explicitly charging for parking for its employees;
•
Implementing above market rate pricing;
• Validating parking only for invited guests;
• Not providing employee parking and transportation allowances; and • Educating employees about available alternatives .

Range of Effectiveness: 0.1-19.7% VMT reduction and therefore 0.1-19.7% reduction in trip GHG emissions.

TRT-15 Implement Employee Parking 11Cash-Out11
Range of Effectiveness: 0.06-7.7% VMT reduction and therefore 0.6-7.7% reduction in commute trip GHG emissions.

Transit System Improvements
TST-1 Transit System Improvements, including:
• Grade-separated right-of-way, including bus only lanes (for buses, emergency vehicles, and sometimes taxis), and other Transit Priority measures. Some systems use guideways which automatically steer the bus on portions of the route.
• Frequent, high-capacity service
• High-quality vehicles that are easy to board, quiet, clean, and comfortable to ride . • Pre-paid fare collection to minimize boarding delays . • Integrated fare systems, allowing free or discounted transfers between routes and modes . • Convenient user information and marketing programs .
• High quality bus stations with Transit Oriented Development in nearby areas . • Modal integration, with BRT service coordinated with walking and cycling facilities, taxi services, intercity bus, rail transit, and other transportation services.

Range of Effectiveness: 0.02-3.2% VMT reduction and therefore 0.02-3% reduction in GHG emissions.

TST-2 Implement Transit Access Improvements, such as:
• Sidewalk/crosswalk safety enhancements
27 • Bus shelter improvements
Range of Effectiveness: Grouped strategy (see TST-3 and TST-4) TST-3 Expand Transit Network
Range of Effectiveness: 0.1-8.2% VMT reduction and therefore 0.1-8.2% reduction in GHG emissions.

TST-4 Increase Transit Service Frequency/Speed
Range of Effectiveness: 0.02-2.5% VMT reduction and therefore 0.02-2.5% reduction in GHG emissions.

TST-5 Provide Bike Parking Near Transit
Range of Effectiveness: Grouped strategy (see TST-3 and TST-4).

TST-6 Provide Local Shuttles
Range of Effectiveness: Grouped strategy (see TST-4 and TST-5).

Road Pricing/Management
RPT-1 Implement Area or Cordon Pricing
Range of Effectiveness: 7.9-22% VMT reduction and therefore 7.9-22% reduction in GHG emissions.

RTP-3 Required Project Contributions to Transportation Infrastructure Improvement Projects Range of Effectiveness: Grouped strategy (see RPT-2 and TST-1 through 7).

RTP-4 Install Park-and-Ride Lots
Range of Effectiveness: Grouped strategy (see RPT-1, TRT-11, TRT-3, and TST-1 through 6).

Vehicles
VT-1 Electrify Loading Docks and/or Require Idling-Reduction Systems Range of Effectiveness: 26-71% reduction in TRU idling GHG emissions.

VT-2 Utilize Alternative Fueled Vehicles, such as:
• Biodiesel (B20)
• Liquefied Natural Gas (LNG)
• Compressed Natural Gas (CNG)
Range of Effectiveness: Reduction in GHG emissions varies depending on vehicle type, year, and associated fuel economy.

VT-3 Utilize Electric or Hybrid Vehicles
Range of Effectiveness: 0.4-20.3% reduction in GHG emissions.

Measures - Water
Water Supply
WSW-1 Use Reclaimed Water
Range of Effectiveness: Up to 40% in Northern California and up to 81% in Southern California.

WSW-2 Use Gray Water
Range of Effectiveness: Up to 100% of outdoor water GHG emissions if outdoor water use is replaced completely with graywater.

WSW-3 Use Locally Sourced Water Supply
28 Range of Effectiveness: 0-60% for Northern and Central California, 11-75% for Southern California.

Water Use
WUW-5 Reduce Turf in Landscapes and Lawns
Range of Effectiveness: Varies and is equal to the percent commitment to turf reduction, assuming no other outdoor water use.

WUW-6 Plant Native or Drought-Resistant Trees and Vegetation Range of Effectiveness: Best Management Practice; may be quantified if substantial evidence is available.

Measures - Area Landscaping
. 'l ,_
landscaping Equipment
A-2 Implement Lawnmower Exchange Program
Range of Effectiveness: Best Management Practice, influences Area GHG emissions from landscape equipment.

Measures - Construction
Construction
C-1 Use Alternative Fuels for Construction Equipment
Range of Effectiveness: 0-22% reduction in GHG emissions.

C-2 Use Electric and Hybrid Construction Equipment
Range of Effectiveness: 2.5-80% of GHG emissions from equipment that is electric or hybrid if used 100% of the time.

C-3 Limit Construction Equipment Idling Beyond Regulation Requirements Range of Effectiveness: Varies with the amount of Project Idling occurring and the amount reduced.

C-4 Institute a Heavy-Duty Off-Road Vehicle Plan, including:
• Construction vehicle inventory tracking system;
• Requiring hour meters on equipment;
• Document the serial number, horsepower, manufacture age, fuel, etc. of all onsite equipment; and • Daily logging of the operating hours of the equipment .

Range of Effectiveness: Not applicable on its own. This measure ensures compliance with other mitigation measures.

C-5 Implement a Construction Vehicle Inventory Tracking System Range of Effectiveness: Not applicable on its own. This measure ensures compliance with other mitigation measures.

Measures - Miscellaneous
Miscellaneous
Misc-1 Establish a Carbon Sequestration Project, such as:
• Geologic sequestration or carbon capture and storage techniques, in which CO2 from point sources is captured and injected underground;
• Terrestrial sequestration in which ecosystems are established or preserved to serve as CO2 sinks; • Novel techniques involving advanced chemical or biological pathways; or • Technologies yet to be discovered .

Range of Effectiveness: Varies depending on Project Applicant and projects selected. The GHG emissions reduction is subtracted from the overall baseline project emissions inventory.

Misc-2 Establish Off-Site Mitigation
29 Range of Effectiveness: Varies depending on Project Applicant and projects selected. The GHG emissions reduction is subtracted from the overall baseline project emissions inventory.

Misc-3 Use Local and Sustainable Building Materials
Range of Effectiveness: Varies depending on Project Applicant and strategies selected. Best Management Practice.

Misc-4 Require best Management Practices in Agriculture and Animal Operations Misc-5 Require Environmentally Responsible Purchasing, such as:
• Purchasing products with sustainable packaging;
• Purchasing post-consumer recycled copier paper, paper towels, and stationary; • Purchasing and stocking communal kitchens with reusable dishes and utensils; • Choosing sustainable cleaning supplies;
• Leasing equipment from manufacturers who will recycle the components at their end of life; • Choosing ENERGY STAR appliances and Water Sense-certified water fixtures; • Choosing electronic appliances with built in sleep-mode timers; • Purchasing 'green power' (e.g. electricity generated from renewable or hydropower) from the utility; and
• Choosing locally-made and distributed products .

Range of Effectiveness: Varies depending on Project Applicant and strategies selected. Best Management Practice.

Misc-6 Implement an Innovative Strategy for GHG Mitigation Range of Effectiveness: Varies depending on Project Applicant and strategies selected. Best Management Practice.

Measures - General Plans
General Plans
GP-1 Fund Incentives for Energy Efficiency, such as:
• Retrofitting or purchasing new low-emissions equipment; • Purchasing electric or hybrid vehicles;
• Investing in renewable energy systems
Range of Effectiveness: Varies depending on Project Applicant and strategies selected. Best Management Practice.

GP-2 Establish a Local Farmer's Market
Range of Effectiveness: Varies depending on Project Applicant and strategies selected. Best Management Practice.

GP-3 Establish Community Gardens
Range of Effectiveness: Varies depending on Project Applicant and strategies selected. Best Management Practice.

Furthermore, in an effort to reduce the Project's emissions, we identified several mitigation measures that are applicable to the proposed Project from NEDC's Diesel Emission Controls in Construction Projects. 31 Therefore, to reduce the Project's emissions, consideration of the following measures should be made:
31 "Diesel Emission Controls in Construction Projects." Northeast Diesel Collaborative (NEDC), December 2010, available at: https ://www. e pa .gov/ sites/prod u ction/fi I es/2015-09 /documents/ nedc-m od el-contractsepcification. pdf. 30 Measures - Diesel Emission Control Technology
a. Diesel Onroad Vehicles
All diesel nonroad vehicles on site for more than 10 total days must have either (1) engines that meet EPA onroad emissions standards or (2) emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%.
b. Diesel Generators
All diesel generators on site for more than 10 total days must be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%. c. Emission control technology shall be operated, maintained, and serviced as recommended by the emission control technology manufacturer.
d. All diesel vehicles, construction equipment, and generators on site shall be fueled with ultra-low sulfur diesel fuel (ULSD) or a biodiesel blend33 approved by the original engine manufacturer with sulfur content of 15 ppm or less.

Measures - Additional Diesel Requirements
a. Construction shall not proceed until the contractor submits a certified list of all diesel vehicles, construction equipment, and generators to be used on site. The list shall include the following:
i. Contractor and subcontractor name and address, plus contact person responsible for the vehicles or equipment.
ii. Equipment type, equipment manufacturer, equipment serial number, engine manufacturer, engine model year, engine certification (Tier rating), horsepower, engine serial number, and expected fuel usage and hours of operation.
iii. For the emission control technology installed: technology type, serial number, make, model, manufacturer, EPA/CARB verification number/level, and installation date and hour-meter reading on installation date.
b. If the contractor subsequently needs to bring on site equipment not on the list, the contractor shall submit written notification within 24 hours that attests the equipment complies with all contract conditions and provide information.
c. The contractor shall establish generator sites and truck-staging zones for vehicles waiting to load or unload material on site. Such zones shall be located where diesel emissions have the least impact on abutters, the general public, and especially sensitive receptors such as hospitals, schools, daycare facilities, elderly housing, and convalescent facilities.

Reporting
a. For each onroad diesel vehicle, nonroad construction equipment, or generator, the contractor shall submit to the developer's representative a report prior to bringing said equipment on site that 32 "Diesel Emission Controls in Construction Projects." Northeast Diesel Collaborative (NEDC), December 2010, available at: https ://www. e pa .gov/sites/prod u cti on/fi I es/2015-09 /documents/ n ed c-m od el-contra ctse pcification. pdf. 33 Biodiesel blends are only to be used in conjunction with the technologies which have been verified for use with biodiesel blends and are subject to the following requirements:
http://www. a rb. ca .gov/ d iese 1/ve rd ev /reg/bi od iese I comp Ii an ce. pdf. 31 includes:
i. Equipment type, equipment manufacturer, equipment serial number, engine manufacturer, engine model year, engine certification (Tier rating), horsepower, and engine serial number. ii. The type of emission control technology installed, serial number, make, model, manufacturer, and EPA/CARB verification number/level.
iii. The Certification Statement signed and printed on the contractor's letterhead. b. The contractor shall submit to the developer's representative a monthly report that, for each onroad diesel vehicle, nonroad construction equipment, or generator onsite, includes:
i. Hour-meter readings on arrival on-site, the first and last day of every month, and on off-site date. ii. Any problems with the equipment or emission controls. iii. Certified copies of fuel deliveries for the time period that identify:

1. Source of supply

2. Quantity of fuel

3. Quality of fuel, including sulfur content (percent by weight) Finally, in an effort to reduce the Project's emissions, we identified several mitigation measures that are applicable to the proposed Project from the Sacramento Metropolitan Air Quality Management District's ("SMAQMD") Basic Construction Emission Control Practices (Best Management Practices} and Enhanced Exhaust Control Practices.34' 35 Therefore, to reduce the Project's emissions, consideration of the following measures should be made:

The following Basic Construction Emissions Control Practices are considered feasible for controlling fugitive dust from a construction site. The practices also serve as best management practices {BMPs}, allowing the use of the non-zero particulate matter significance thresholds. Lead agencies should add these emission control practices as Conditions of Approval {COA} or include in a Mitigation Monitoring and Reporting Program (MMRP}.

Use wet power vacuum street sweepers to remove any visible trackout mud or dirt onto adjacent public roads at least once a day. Use of dry power sweeping is prohibited.

Limit vehicle speeds on unpaved roads to 15 miles per hour (mph).

All roadways, driveways, sidewalks, parking lots to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used.
34 "Basic Construction Emission Control Practices (Best Management Practices)." Sacramento Metropolitan Air Quality Management District (SMAQMD), July 2019, available at:
https ://www. e pa .gov/sites/prod u cti on/fi les/2 015-09 /documents/ n ed c-m ode I-co ntract-sepcifi cation. pdf. 35 "Enhanced Exhaust Control Practices." Sacramento Metropolitan Air Quality Management District (SMAQMD)October 2013, available at:
http://www.a i rq u a I ity. org/La n d Use T ra nspo rtati on/Documents/ Ch3 En ha need Exha ustCo ntro IF I NALl0-2013. pdf. 36 "Basic Construction Emission Control Practices (Best Management Practices)." Sacramento Metropolitan Air Quality Management District (SMAQMD), July 2019, available at:
h ttps ://www.epa.gov/sites/p rod u cti o n/fi I es/2015-09 /documents/ n ed c-m ode 1-contract-sepcificatio n. pdf. 32 The following practices describe exhaust emission control from diesel powered fleets working at a construction site. California regulations limit idling from both on-road and off road diesel-powered equipment. The California Air Resources Board (CARB) enforces idling limitations and compliance with diesel fleet regulations.

Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes [California Code of Regulations, Title 13, sections 2449(d)(3) and 2485]. Provide clear signage that posts this requirement for workers at the entrances to the site.

Provide current certificate(s) of compliance for CARB's In-Use Off-Road Diesel-Fueled Fleets Regulation [California Code of Regulations, Title 13, sections 2449 and 2449.1].

1. The project representative shall submit to the lead agency and District a comprehensive inventory of all off-road construction equipment, equal to or greater than 50 horsepower, that will be used an aggregate of 40 or more hours during any portion of the construction project. • The inventory shall include the horsepower rating, engine model year, and projected hours of use for each piece of equipment.
• The project representative shall provide the anticipated construction timeline including start date, and name and phone number of the project manager and on-site foreman. • This information shall be submitted at least 4 business days prior to the use of subject heavyduty off-road equipment. • The District's Equipment List Form can be used to submit this information. • The inventory shall be updated and submitted monthly throughout the duration of the project, except that an inventory shall not be required for any 30-day period in which no construction activity occurs.

2. The project representative shall provide a plan for approval by the lead agency and District demonstrating that the heavy-duty off-road vehicles (SO horsepower or more) to be used in the construction project, including owned, leased, and subcontractor vehicles, will achieve a project wide fleet-average 20% NOX reduction and 45% particulate reduction compared to the most recent California Air Resources Board (ARB) fleet average.
• This plan shall be submitted in conjunction with the equipment inventory. • Acceptable options for reducing emissions may include use of late model engines, lowemission diesel products, alternative fuels, engine retrofit technology, after-treatment products, and/or other options as they become available. • The District's Construction Mitigation Calculator can be used to identify an equipment fleet that achieves this reduction.

3. The project representative shall ensure that emissions from all off-road diesel powered equipment used on the project site do not exceed 40% opacity for more than three minutes in any one hour. • Any equipment found to exceed 40 percent opacity (or Ringelmann 2.0) shall be repaired 37 "Enhanced Exhaust Control Practices." Sacramento Metropolitan Air Quality Management District (SMAQMD)October 2013, available at:
http://www. a i rq u a lity. org/La n d Use Tran sportati on/Documents/Ch 3 En ha need Exhaust Co ntro IF I NALl0-2013. pdf. 33 immediately.
• Non-compliant equipment will be documented and a summary provided to the lead agency and District monthly.
• A visual survey of all in-operation equipment shall be made at least weekly. • A monthly summary of the visual survey results shall be submitted throughout the duration of the project, except that the monthly summary shall not be required for any 30-day period in which no construction activity occurs. The monthly summary shall include the quantity and type of vehicles surveyed as well as the dates of each survey.

4. The District and/or other officials may conduct periodic site inspections to determine compliance.

Nothing in this mitigation shall supersede other District, state or federal rules or regulations.

These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation. An updated EIR should be prepared to include all feasible mitigation measures, as well as include an updated air quality and GHG analysis to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The updated EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project's significant emissions are reduced to the maximum extent possible.

SWAPE has received limited information regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
/ft,{ //,uz(/v·t-<.__.----
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.
34 City Response to Center for
Biological Diversity

HomeFed Fanita Rancho, LLC
August 20, 2020
Ms. Marlene Best
City Manager
City of Santee
10601 Magnolia Avenue
Santee, CA 92071
Dear Ms. Best,
This letter is to inform the City of Santee of a proposed change to the Fanita Ranch project. As the project applicant, we will delete the extension of Magnolia Avenue from the project and will direct those resources towards the funding of improvements to SR-52, which will relieve existing and future congestion in a timelier manner.

We fully understand the implications of modifying the project at this time, with a City Council hearing noticed for next week, and that this change will necessitate a delay of the City Council's consideration of the project. We ask that you accept this letter as a formal request for a hearing continuance.

As you know, the current Fanita Ranch proposal includes as a project feature, the off-site improvement of Magnolia Avenue ("Magnolia Extension"). The Magnolia Extension is not necessary for the development of Fanita Ranch. As the Draft EIR illustrates, it is not necessary to mitigate any project impacts to traffic circulation, fire safety/emergency evacuation, or any other potential environmental impacts associated with the project.

Rather, we included the Magnolia Extension as a component of the project to provide an additional community benefit, just like many others. The Magnolia Extension is part of a Circulation Element roadway in Santee's existing, approved General Plan. The City has anticipated future implementation of this roadway, but without funding in the past, it was unclear if and when this road would be implemented.

However, through our public outreach and interaction with Santee residents, it is clear that congestion relief on SR-52 is unquestionably the top priority for this community. Moreover, upon recently learning that including the extension in our project could potentially pose a conflict with a council member, this change is in everyone's best interest. 1903 Wright Place, Suite 220 - Carlsbad, CA 92008
ATTACHMENT 9
The existing project already guarantees roughly $10,000,000 to the SR-52 effort from the applicant. Importantly, no homes may be occupied within the project until the SR 52 improvements to relieve congestion are complete.

The feedback we've received over the past year at community meetings and webinars, as well as calls and emails, has led us to the conclusion that the project resources proposed for the Magnolia Extension will better serve Santee residents by providing additional funding to the SR52 improvement effort. This will help the City provide the required "local match" funding that will expedite regional, state and federal funding sources to make the SR-52 improvement a reality sooner rather than later.

This approach will increase Home Fed's obligation to SR-52 from roughly $10 million to roughly $15 million. That is the essence of the modification we propose to the Fanita project.

Needless to say, the COVID pandemic has dramatically changed the world in which we live, and put extreme fiscal pressures on government at all levels, federal, state and local. By providing the additional funding for SR-52, the city may, if it so chooses, use funds otherwise earmarked for the SR-52 local match towards other city priorities.

In addition, this will allow all members of the City Council to participate in the decision on Fanita, not excluding anyone because of the proximity of the council members residence to the Magnolia Extension--not even excluding the councilman who wrote an initiative to stop the project even before considering all the project materials and facts. We believe a project of this scope and importance should be considered by fil! the elected representatives of each City Council District, who reflect the interests of all city residents.

Thank you and your staff for all the hard work to date on the Fanita Ranch project. We will contact you shortly about the tasks necessary to move forward with the project as revised.

Very Truly Yours,
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JetVo'�o�nor
Vice President
1903 Wright Place, Suite 220 - Carlsbad, CA 92008
RESOLUTION 093-2020
1 RESOLUTION NO. 093-2020 OF THE CITY COUNCIL FOR THE CITY OF SANTEE CERTIFYING THE REVISED ENVIRONMENTAL IMPACT REPORT (SCH # 2005061118) FOR THE FANITA RANCH PROJECT; ADOPTING FINDINGS OF FACT

AND A STATEMENT OF OVERRIDING CONSIDERATIONS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT; ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM; AND APPROVING THE PROJECT WHEREAS, the Fanita Ranch Project (“Project”) proposes a community consisting of approximately 2,949 housing units under a preferred land use plan with school, or 3,008 units under a land use plan without school, up to 80,000 square feet of commercial uses, parks, open space, and agricultural uses; and
WHEREAS, the Project consists of approximately 2,638 acres of land in the northern portion of the City of Santee (“City”); and
WHEREAS, the Project site has been subject to environmental review and land use planning for the past 40 years; and
WHEREAS, development of the Project site would be clustered into three villages in order to designate approximately 63 percent of the site as Habitat Preserve; and WHEREAS, the villages would be arranged around a centralized Farm to support farming and wellness as the theme for Fanita Ranch; and WHEREAS, a Special Use area separated from the rest of the development would be located in the southwestern corner of the site, allowing for a limited range of uses; and WHEREAS, the Project would provide a coordinated system of parks and nonmotorized use trails that would connect to the three villages, regional trails and open space; and
WHEREAS, the Project would improve and construct new segments of two Santee General Plan Mobility Element Roads, namely Fanita Parkway and Cuyamaca Street; and
WHEREAS, the Project applicant is seeking a General Plan Amendment, Specific Plan, Zone Amendment or Reclassification, Vesting Tentative Map, Development Review Permit, Conditional Use Permits, and a Development Agreement to implement the Project; and
WHEREAS, pursuant to Public Resources Code section 21067, State CEQA Guidelines section 15367, and the City's Local CEQA Guidelines, the City is the lead agency for the Project; and
RESOLUTION 093-2020
2 WHEREAS, pursuant to CEQA and the State CEQA Guidelines the City determined that a Revised Environmental Impact Report (“EIR”) should be prepared in order to analyze all potential adverse environmental impacts of the proposed Project; and

WHEREAS, in accordance with State CEQA Guidelines section 15082, on November 10, 2018, the City sent to the Office of Planning and Research and each responsible and trustee agency a Notice of Preparation (“NOP”) stating that a Revised Environmental Impact Report (State Clearinghouse # 2005061118) would be prepared; and
WHEREAS, in the NOP, the City solicited comments from various public agencies, other entities, and members of the public; and
WHEREAS, on November 29, 2018, the City held a public scoping meeting to further solicit comments on the scope of the EIR; and
WHEREAS, a Draft Revised EIR was prepared incorporating comments received in response to the NOP; and
WHEREAS, the Draft Revised EIR determined that mitigation measures were required to mitigate some impacts to a less than significant level; and WHEREAS, the Draft Revised EIR further concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts; and
WHEREAS, on or about May 29, 2020 the City initiated a 45-day public review and comment period for the Draft Revised EIR ending on July 13, 2020 at 5:00 p.m.; and WHEREAS, during the public review and comment period, copies of the Draft Revised EIR and technical appendices were available for review and inspection at City Hall and on the City’s website; and
WHEREAS, pursuant to State CEQA Guidelines section 15086, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others during the 45-day public review and comment period; and WHEREAS, during the review and comment period, the City received six comments from federal and state agencies, four comments from local or regional agencies, five comments from tribal entities, twelve comments from non-government organizations, and 189 comments from individuals; and
WHEREAS, the City has prepared a Final Revised EIR, consisting of the written comments received during the review and comment period on the EIR; written responses RESOLUTION 093-2020
3 to those comments as well as thematic responses; an errata showing revisions to the Draft Revised EIR (First Errata) and technical appendices in response to comments; and an errata to the Final Revised EIR (Second Errata) documenting the removal of the Magnolia Avenue extension from the Project in response to the applicant’s August 20, 2020 request to the City. The Second Errata explains that any reference to the previously proposed Magnolia Avenue extension as a project feature contained in the Draft or Final Revised EIR or appendices has been deleted from the Final Revised EIR. For purposes of this Resolution, the “EIR” shall refer to the Draft Revised EIR, as revised by the Final Revised EIR, together with the other sections of the Final Revised EIR, including both errata documents; and
WHEREAS, after the close of the 45-day public review and comment period, the City continued to receive numerous, additional late comments. These late comments have been addressed in the Staff Report for the Project and do not raise any significant environmental issues under State CEQA Guidelines section 15088 beyond what has already been addressed in the Final Revised EIR; and
WHEREAS, pursuant to Public Resources Code section 21092.5, the City provided copies of its responses to timely commenting public agencies at least ten days prior to the City Council’s consideration of the Final Revised EIR; and WHEREAS, on September 23, 2020, the City Council held a public hearing on the Project, at which all persons wishing to testify were heard; and WHEREAS, the environmental impacts identified in the EIR that the City finds are of no impact or constitute a less than significant impact and do not require mitigation are described in Section II of the CEQA Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the environmental impacts identified in the EIR as potentially significant but which the City finds can be mitigated to a level of less than significant through the incorporation of feasible Mitigation Measures identified in the EIR and set forth herein, are described in Section III of the CEQA Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the City finds that even with the incorporation of all feasible mitigation measures, the environmental impacts that are identified in the EIR that are significant and unavoidable are set forth in Section IV of the CEQA Findings of Fact, attached hereto and incorporated herein as Exhibit A; and
WHEREAS, the cumulative impacts of the Project identified in the EIR and set forth herein, are described in Section V of the CEQA Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the significant and irreversible environmental changes that would result from the Project, but which would be largely mitigated, and which are identified in RESOLUTION 093-2020
4 the EIR and set forth herein, are described in Section VI of the CEQA Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the existence of any growth-inducing impacts resulting from the Project identified in the EIR and set forth herein, are described in Section VII of the CEQA Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, alternatives to the Project that might eliminate or reduce significant environmental impacts are described in Section VIII of the CEQA Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, because the EIR identified significant and unavoidable impacts, the City Council explains its reasoning for recommending the adoption of the Project despite those impacts in the Statement of Overriding Considerations, as set forth in Section IX of the CEQA Findings of Fact, attached hereto and incorporated herein as Exhibit A; and WHEREAS, the Mitigation Monitoring and Reporting Program setting forth the mitigation measures to which the City shall bind itself in connection with adopting the Project is attached hereto as Exhibit B; and
WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision on the Project; and
WHEREAS, prior to taking action, the City Council has heard, been presented with, reviewed and considered all of the information and data in the administrative record, including the EIR, and all oral and written evidence presented to it during all meetings and hearings; and
WHEREAS, the EIR reflects the independent judgment of the City Council and is deemed adequate for purposes of making decisions on the merits of the Project; and WHEREAS, the City has not received any comments or additional information that constitute substantial new information requiring recirculation of the EIR or any portion thereof under Public Resources Code section 21092.1 and State CEQA Guidelines section 15088.5; and
WHEREAS, all the requirements of CEQA, the State CEQA Guidelines, and the City’s Local CEQA Guidelines have been satisfied by the City in the EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have occurred.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santee does hereby resolve as follows:

RESOLUTION 093-2020
5 SECTION 1: RECITALS
The recitals above are true and correct and are incorporated into this Resolution by reference as findings of fact.

SECTION 2: CEQA COMPLIANCE
As the decision-making body for the City, and in the City’s roll as lead agency under the California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.) and the State CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.), the City Council has reviewed and considered the information relating to the Project contained within the EIR and all supporting documentation, together with all oral and written comments received during the public review process, and all other related documents, which are available at City Hall and which are incorporated by reference herein. The City Council finds that the EIR reflects the independent judgment and analysis of the City. The City Council further finds that the EIR contains a complete and accurate reporting of environmental impacts associated with the Project, and was prepared in compliance with CEQA, the State CEQA Guidelines, and the City’s Local CEQA Guidelines. The City Council further finds and declares that the City has not received any evidence of new significant impacts, as defined by State CEQA Guidelines, section 15088.5, after circulation of the EIR which would require recirculation. No substantial changes to the Project have occurred that would require a supplemental or subsequent EIR.

SECTION 3: FINDINGS OF FACT
In accordance with State CEQA Guidelines, sections 15091 and 15093, the City Council hereby adopts the Environmental Findings of Fact attached hereto as Exhibit A and incorporated herein by this reference as if fully set forth herein.

SECTION 4: CERTIFICATION OF EIR
In accordance with State CEQA Guidelines, sections 15090, the City Council hereby certifies that:

A. The EIR is an accurate and objective statement that has been completed in compliance with CEQA and the State CEQA Guidelines.

B. The City Council has been presented with and has reviewed and considered the information contained in the EIR prior to approving the Project.

C. The EIR reflects the City Council’s independent judgment and analysis.

SECTION 5: MITIGATION MONITORING AND REPORTING PROGRAM
RESOLUTION 093-2020
6 Pursuant to Public Resources Code section 21081.6, the City Council hereby adopts the Mitigation Monitoring and Reporting Program (“MMRP”) attached hereto as Exhibit B and incorporated herein by this reference. The City Council finds that the MMRP is designed to ensure that, during the implementation of the Project, the City and any other responsible parties implement the components of the Project and comply with the mitigation measures identified in the MMRP. To the extent there is any conflict between the MMRP, the EIR, or the Findings of Fact, the terms and provisions of the MMRP shall control.

SECTION 6: APPROVAL OF THE PROJECT
Based upon the entire record before the City Council and the findings set forth herein, the City Council of the City of Santee approves the proposed Project.

SECTION 7: RECORD OF PROCEEDINGS
The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at City Hall, 10601 N. Magnolia Avenue, Santee, CA 92071. The custodian of the record of proceedings is the Department of Development Services.

SECTION 8: NOTICE OF DETERMINATION
The City Council hereby directs staff to prepare and file a Notice of Determination with the County Clerk of the County of San Diego within five working days of the execution of this Resolution and approval of the Project and with the Office of Planning and Research.

ADOPTED by the City Council of the City of Santee, California, at a Regular Meeting thereof held this 23rd day of September, 2020 by the following roll call vote to wit:

AYES:

NOES:

ABSENT:

APPROVED:

JOHN W. MINTO, MAYOR
ATTEST:

RESOLUTION 093-2020
7 ANNETTE ORTIZ, CMC, CITY CLERK
Attachments: Exhibit A
Exhibit B
RESOLUTION 093-2020
8 EXHIBIT A

FINDINGS OF FACT
SECTION I: INTRODUCTION
Public Resources Code section 21002 states that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” Section 21002 further states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” Pursuant to section 21081 of the Public Resources Code, a public agency may only approve or carry out a project for which an EIR has been completed that identifies any significant environmental effects if the agency makes one or more of the following written finding(s) for each of those significant effects accompanied by a brief explanation of the rationale for each finding:

1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment.

2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency.

3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.

As indicated above, section 21002 requires an agency to “avoid or substantially lessen” significant adverse environmental impacts. Thus, mitigation measures that “substantially lessen” significant environmental impacts, even if not completely avoided, satisfy section 21002’s mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 [“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level”]; Las Virgenes Homeowners Fed., Inc. v. County of Los Angeles (1986) 177 Cal. App. 3d 300, 309 [“[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”].)
While CEQA requires that lead agencies adopt feasible mitigation measures or alternatives to substantially lessen or avoid significant environmental impacts, an agency need not adopt infeasible mitigation measures or alternatives. (Pub. Resources Code, § 21002.1(c) [if “economic, social, or other conditions make it infeasible to mitigate one or RESOLUTION 093-2020
9 more significant effects on the environment of a project, the project may nonetheless be carried out or approved at the discretion of a public agency”]; see also State CEQA Guidelines, § 15126.6(a) [an “EIR is not required to consider alternatives which are infeasible”].) CEQA defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.” (Pub. Resources Code, § 21061.1.) The State CEQA Guidelines add “legal” considerations as another indicia of feasibility. (State CEQA Guidelines, § 15364.) Project objectives also inform the determination of “feasibility.” (Jones v. U.C. Regents (2010) 183 Cal. App. 4th 818, 828-829.) “‘[F]easibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) “Broader considerations of policy thus come into play when the decision making body is considering actual feasibility[.]” (Cal. Native Plant Soc’y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000 (“Native Plant”); see also Pub.

Resources Code, § 21081(a)(3) [“economic, legal, social, technological, or other considerations” may justify rejecting mitigation and alternatives as infeasible] (emphasis added).)
Environmental impacts that are less than significant do not require the imposition of mitigation measures. (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347.)
The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576.) In addition, perfection in a project or a project’s environmental alternatives is not required; rather, the requirement is that sufficient information be produced “to permit a reasonable choice of alternatives so far as environmental aspects are concerned.” Outside agencies (including courts) are not to “impose unreasonable extremes or to interject [themselves] within the area of discretion as to the choice of the action to be taken.” (Residents Ad Hoc Stadium Com. v. Board of Trustees (1979) 89 Cal.App.3d 274, 287.)
SECTION II: FINDINGS REGARDING ENVIRONMENTAL IMPACTS NOT

REQUIRING MITIGATION
The City Council hereby finds that the following potential environmental impacts of the Project are less than significant and therefore do not require the imposition of Mitigation Measures.

A. AESTHETICS
RESOLUTION 093-2020
10 1. Scenic Vistas
Threshold: Would the Project have a substantial adverse effect on a scenic vista?
Finding: Less than significant. (EIR, § 4.1.5.1.)
Explanation: The Santee General Plan Community Enhancement Element describes numerous topographic features in the City and the surrounding vicinity as providing distinctive views and vistas from developed portions of the City. Although the Santee General Plan does not designate specific scenic vistas in the City, the major ridgeline and hillside systems provided by undeveloped areas of the northern portion of the City, including the project site, present a large portion of the views and vistas in the City. Jurisdictions outside of the City surrounding the project site, such as the County’s Lakeside Community Plan, do not designate scenic vistas in the viewshed of the project site.

To show the changes in key views and describe the visibility of the proposed project from surrounding areas and potential scenic vistas, visual simulations were prepared using photographs of the project site and computer-generated, three-dimensional project modeling (Visual Impact Group 2020).

Fifteen key vantage points were analyzed and the proposed project’s design would retain most of the major ridgelines and landform features on the project site visible from public viewpoints, and the surrounding topography would be retained. This would allow for the continued screening of views into much of the proposed project from throughout the City and adjacent public view areas.

Additionally, the proposed project would comply with the design recommendations set forth by the City through the development review process, which ensures development projects adhere to the City’s design principles. Further, there are no designated scenic vistas on or around the project site. Therefore, development of the proposed project would not obstruct or detract from a designated scenic vista. Impacts would be less than significant.

2. Scenic Resources
Threshold: Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, or historic buildings within a state scenic highway?
Finding: Less than significant. (EIR, § 4.1.5.2.)
Explanation: SR-52 is a state designated scenic highway which runs in an east– RESOLUTION 093-2020
11 west direction approximately 1.8 mile south of the southern project site boundary. The approximately 3.5-mile segment from Santo Road east to Mast Boulevard within the City of San Diego was officially designated as a state scenic highway in February 2016 (Caltrans 2017). Due to its distance and intervening topography, future project development would not be seen from this location. To demonstrate this, three locations were studied along this designated segment as part of the visual simulation effort for the proposed project. As part of that effort, all three locations were determined to have no view of the project site. Consequently, the proposed project would not alter views from within the rights-of-way of a designated or eligible state scenic highway. Therefore, the proposed project would not have a significant impact associated with views from scenic highways.

3. Visual Character
Threshold: In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public view of the site and its surroundings?
Finding: Less than significant. (EIR, § 4.1.5.3.)
Explanation: Visual Character. Fifteen key vantage points (KVPs) were analyzed depicting various existing and proposed condition views surrounding the project site and the off-site improvement areas. The proposed project would alter the existing aesthetic characteristics of the project site from a variety of vantage points within the City and adjacent areas. As demonstrated by the representative KVPs, changes in the project site’s aesthetic appearance would be visible from public vantage points located adjacent to the project site on the south, west, and east; recreational areas such as Santee Lakes Recreation Preserve and Stowe Trail; and major roadways such as SR-125, Fanita Parkway, and Cuyamaca Street.

As illustrated with the KVPs, some existing residences and user groups would be affected by the proposed landform alteration and site development. The KVP that displays the largest potential change in visual character is KVP-15, which shows a view looking south onto the project site from the Stowe Trail. This KVP shows the proposed Active Adult neighborhood and, due to close proximity to the existing trail, reveals considerable views of the development. However, the proposed landscaping and revegetated slopes would screen much of this development and allow it to blend in with the surrounding existing environment. In addition, the proposed project proposes to grade this area in accordance with Hillside Development Guidelines (Policy 1.3 of the Conservation Element of the Santee General Plan RESOLUTION 093-2020
12 [City of Santee 2003]), which require contour grading and clustering of development to minimize the grading footprint. The resulting revegetated slopes would blend in with the native landscape and further act as wildfire buffers to the community.

Due to uneven topography and the far distances from the proposed village development area to the nearest off-site receptors, it is difficult to distinguish the proposed development along most ridgelines. In addition, the proposed project’s design would retain most of the major ridgelines and landform features on the project site’s periphery, which would allow for the continued screening of views into much of the proposed project from throughout the City and adjacent areas. The changes in views due to the extension of Fanita Parkway, and the off-site improvement to Cuyamaca Street have been anticipated as part of the Santee General Plan Circulation Element roadway improvements. These improvements would be enhanced through the use of natural vegetation, landscaping, and revegetated manufactured slopes. Therefore, the proposed project would have a less than significant impact on the visual character or quality of the area.

Landform Alteration. Sensitive landforms are natural landforms that are unique or contribute to the character of a site. The Santee General Plan Conservation Element (City of Santee 2003) identifies two main topographic landforms that exist in the City, one being the Peninsular Range, which traverses much of the project site. Policies within the Conservation Element call for significant natural landforms to be maintained during development whenever possible. To protect and wisely manage hillsides and topographic resources, the City lays out specific hillside development guidelines.

Construction of the proposed project would involve extensive excavation and grading into the native terrain. Earthwork would involve approximately 27 million cubic yards of cut and fill materials, which would be balanced on site (Figure 3-16, Conceptual Cut and Fill Plan, in Chapter 3, Project Description). Construction would include cuts up to 165 feet and fills up to 142 feet. The site would be graded into development pads using a maximum 2:1 slope ratio for fill slopes and a maximum 1.5:1 for cut slopes, which is a requirement of the Santee Municipal Code, Section 11.40.320, and to closely mimic the interval of the natural contours. The Special Use area has been previously graded and no significant grading or introduction of water into the soil is proposed.

While the proposed project would generally preserve the existing contours of the landforms where feasible for development, the proposed project includes considerable grading into steeply sloped RESOLUTION 093-2020
13 areas. Some of the largest differences from the existing grade would occur with the development of a Neighborhood Park and multi-family residences in the central area of Orchard Village and Low Density Residential in southern and central areas of Vineyard Village. The prominent hilltop in Fanita Commons would be preserved within the planned Community Park. These large cut and fill slopes, as identified on the Vesting Tentative Map, that are visible from the public rights-of-way would utilize landform grading techniques to recreate and mimic the flow of natural contours and drainages within the natural surroundings. Where development is proposed on hillsides, grading would be efficient to minimize the grading footprint.

Special contour grading techniques would be utilized at edges and transitions in landform. In addition, the proposed extensions of Fanita Parkway and Cuyamaca Street into the village development area would be designed to preserve natural hillsides and rock outcroppings and follow the existing slopes and landforms to the extent possible.

Manufactured slopes along the edges of the development footprint, primarily visible along the northern village development area of Vineyard Village and at the proposed extension of Cuyamaca Street, would be revegetated with natural vegetation to restore the native habitat and blend with the existing environment, further limiting the visibility of the landform alteration of these areas. These slopes, some of which are highly visible from public rights-of-way, are identified in the Fanita Ranch Specific Plan as “public interest” slopes. During construction, these slopes would be temporarily devoid of vegetation; however, they would be revegetated and landscaped in compliance with the Santee Municipal Code, Chapter

12.26, Landscape and Irrigation Regulations, and the Guidelines for Implementation of the City of Santee Water Efficient Landscape Ordinance (2017). Therefore, by complying with the policies in the Santee General Plan and the requirements of the Santee Municipal Code, as well as adhering to the guidelines set forth in the Fanita Ranch Specific Plan, the proposed project would have a less than significant impact associated with landform alteration.

4. Lighting and Glare
Threshold: Would the proposed project create a new source of substantial light or glare that would adversely affect day or nighttime views? Finding: Less than significant. (EIR, § 4.1.5.4.)
Explanation: Implementation of the proposed project would result in the development of new structures that would have the potential to increase sources of light or glare. The proposed new development RESOLUTION 093-2020
14 would take place in currently undeveloped areas, and potential new sources of light would include exterior building illumination, sports field lighting, Special Use area security lighting, residential lighting, parking lots, new landscaped areas, and new roadway lighting. New sources of glare could result from reflective building surfaces or the headlights of vehicular traffic.

During the day, lighting has limited potential to impact views.

Potential impacts from glare would primarily occur from the sun reflecting off reflective building surfaces. Daytime views that are subject to a substantial amount of new glare may be significantly impacted. However, the proposed project would not include the implementation of large, uninterrupted expanses of glass or any other highly reflective material. The Special Use area would include space for approximately 18.4 acres of photovoltaic solar panels atop an RV/boat storage area, which could result in potential glare impacts to surrounding residents. However, photovoltaic solar panels are designed to absorb light, not reflect it, and would be coated with anti-reflective materials to maximize light absorption. In addition, solar panels face upward resulting in a small likelihood of directly affecting nearby residents on the ground. Therefore, the proposed project would not result in substantial glare that would adversely affect daytime views in the area.

Sensitive views of the night sky could be impacted from new light and glare in a previously undeveloped area. The proposed project would include 2,949 residences with a school, or 3,008 residences without a school, commercial uses, parks, open space, agriculture uses, and a network of streets with off-site roadway improvements. The increase in light and glare from the implementation of the proposed project would have a potentially significant impact to views of the night sky. The proposed project would be replacing a natural backdrop with a large residential development with exterior building illumination, sports field lighting, residential lighting, parking lots, new landscaped areas, and new roadway lighting.

To minimize the impacts of lighting and glare as a result of new development, the proposed project has prepared a Conceptual Lighting Plan as part of the Fanita Ranch Specific Plan. The Conceptual Lighting Plan provides general lighting design guidance for streets, pathways, common open space, recreation areas, buildings, special accent lighting, and sign illumination. One of the primary goals of the Conceptual Lighting Plan is to reduce or eliminate light pollution by utilizing low glare and full cutoff light fixtures, lower wattage luminaires, and lighting controls to create a “Dark Sky” friendly community. This would be achieved by designing lighting according to use; prohibiting certain types of light sources; RESOLUTION 093-2020
15 using appropriate shielding and direction of lighting sources; and enforcing lighting curfews for certain uses. Outdoor lighting would be designed and placed to efficiently direct light downward, particularly lighting for streets and parking areas. All outdoor lighting would be shielded to confine light within the site and prevent glare onto adjacent properties, the Habitat Preserve, riparian areas, and streets.

The Conceptual Lighting Plan for the proposed project states specific requirements for lighting within or adjacent to the Habitat Preserve and other environmentally sensitive areas. These requirements would prohibit lighting in or adjacent to conserved habitat, except where essential for roadway use, facility use, safety, or security purposes; use of low-pressure sodium illumination sources or other similar technology; would not use low-voltage outdoor or trail lighting, spotlights or bug lights; and would shield light sources adjacent to conserved habitat so that the lighting is focused downward.

Proposed Streets “V” and “W” would traverse the Habitat Preserve to connect Fanita Commons and Orchard Village with Vineyard Village. These streets would be designed to include wildlife crossings and use retroreflective pavement markers and touch-activated lighted bollards, instead of conventional lighting, to allow for the safe crossing of automobiles and wildlife while minimizing excessive light pollution on adjacent uses.

In addition, the anticipated development of the proposed project would be required to comply with the lighting guidelines of the Santee General Plan and the City Zoning Ordinance (Title 13 of the Santee Municipal Code) to assure that the proposed project would not include nuisance lighting. Therefore, by complying with the City Zoning Ordinance, guidelines in the Santee General Plan, and adhering to the requirements set forth in the Conceptual Lighting Plan designed for the proposed project, the proposed project’s potential to create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area would be less than significant.

B. AGRICULTURE AND FOREST RESOURCES

1. Farmland Conversion
Threshold: Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide significance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
Finding: No impact. (EIR, § 5.1.1.)
RESOLUTION 093-2020
16 Explanation: Pursuant to the California Department of Conservation Farmland Mapping and Monitoring Program, the project site is designated as Grazing Land. Grazing Land is defined as “land on which the existing vegetation is suited to the grazing of livestock” (DOC 2020).

California Public Resources Code, Section 21060.1, defines agricultural land as “prime farmland, farmland of statewide importance, or unique farmland.” Soils on the project site have been mapped by the U.S. Department of Agriculture (2020) and consist predominantly of portions of three soil series: Redding, Diablo, and Linne. The Redding and Diablo soils are the most common on site.

The Linne soil is generally limited to smaller areas throughout the project site. Redding soil is composed of gravelly loamy soils that have a gravelly clay subsoil and a hardpan, while Diablo and Linne soils consist chiefly of deep clay loams derived from soft, calcareous sandstones and shale. The above soils do not meet the criteria for prime farmland or soils of statewide importance outlined in the U.S.

Department of Agriculture’s land inventory and monitoring program for San Diego area (2020). The project site does not support prime farmland, unique farmland, or farmland of statewide importance.

Therefore, the proposed project would not impact classified farmland, either directly or indirectly, or result in the conversion of farmland to non-agricultural use. As such, no impact would occur to prime farmland, unique farmland, or farmland of statewide importance.

2. Agricultural Zoning
Threshold: Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
Finding: No impact. (EIR, § 5.1.1.)
Explanation: As shown on the City’s Zoning District Map (2017), no lands zoned for agricultural use are on the project site. The project site is zoned as Planned Development (PD). Further, the project site is not in the vicinity of any lands zoned for agricultural use. No lands affected by the proposed project are currently under a Williamson Act contract.

Therefore, the proposed project would have no impact on a Williamson Act contract property or conflict with existing zoning for agricultural use.

3. Forest Land
Threshold: Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section RESOLUTION 093-2020
17 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)?
Threshold: Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
Threshold: Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of farmland, to non-agricultural use or conversion of forest land to nonforest use? Finding: No impact. (EIR, § 5.1.1.)
Explanation: The project site does not support prime farmland, unique farmland, or farmland of statewide importance and would not involve other changes in the existing environment, which would result in conversion of farmland to non-agricultural use. In addition, the City has no designated forest land or timberland within its boundaries.

The project site is not zoned for timberland production and is not in proximity to any lands zoned as Forest Land. The land area affected by the proposed project does not support forest land or timberland resources or operations. Therefore, no impact would occur from project implementation with regard to conflict with existing zoning for, or cause rezoning of, forest land or timberland, and the proposed project would not result in the potential loss or conversion of forest land to non-forest use.

C. AIR QUALITY

1. Other Adverse Emissions
Threshold: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? Finding: Less than significant. (EIR, § 4.2.5.4.)
Explanation: Heavy-duty equipment on the project site during construction would emit odors, primarily from equipment exhaust. However, the construction activity would cease to occur after individual construction is completed in a given area. Generally, construction would be separate from existing receptors by hundreds of feet due to the distance of the nearest off-site residences to the village development areas. Additionally, emissions of SOx, the pollutant most associated with odors, would be minimal. Therefore, impacts during construction would be less than significant.

Following construction, operation of the proposed agricultural areas (specifically the Farm) could release localized odors. However, RESOLUTION 093-2020
18 localized odors would generally be confined to the Agriculture Overlay zone on the project site and would dissipate quickly beyond the limits of the Farm based on typical agricultural operations. An extensive animal husbandry operation is not proposed and would not be accommodated within the Farm; therefore, the potential to generate odors would be low. The remaining proposed commercial and residential uses are not typical sources of nuisance odors.

Although not an impact under CEQA, as an impact of the
environment on the proposed project, it is noted that operation of the proposed project would require implementation of Conditional Use Permit measures at the Padre Dam Municipal Water District (PDMWD) Ray Stoyer Water Recycling Facility (WRF) located on Fanita Parkway west of the project site. The existing Conditional Use Permit for the PDMWD Ray Stoyer WRF contains measures that require implementation once the proposed project is constructed.

These measures include the use of an odor scrubber to limit hydrogen sulfide, the replacement of the existing primary clarifier system with a chemical scrubbing system, the covering of all zones of the biological nutrient removal basins, the installation of additional chemical scrubbers, and the installation of an additional SO2 neutralization system at the dechlorination building (Helix 2015).

Therefore, objectionable odors affecting a substantial number of people would not occur because of the proposed project. This impact would be less than significant.

D. BIOLOGICAL RESOURCES

1. Local Policies and Ordinances
Threshold: Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Finding: Less than significant. (EIR, § 4.3.5.5.)
Explanation: The City of Santee’s Urban Forestry Ordinance contains tree-related policies, regulations, and generally accepted standards for planting, trimming, and removing trees on public property and public rights-ofway (Santee Municipal Code, Section 8.06 [City of Santee 2020]).

The ordinance gives the City control of all trees, shrubs, and other plantings in any street, park, public right-of-way, landscape maintenance district or easement, or other City-owned property. City review of development plans for the City-owned and maintained property would ensure that the proposed landscaping and maintenance requirements conform to the Urban Forestry
RESOLUTION 093-2020
19 Ordinance. Therefore, the proposed project would comply with the Urban Forestry Ordinance, and impacts would be less than significant.

In the Conservation Element of the Santee General Plan, biological resources are discussed and specific objectives and policies are presented. The proposed project does not conflict with any objectives or policies as presented in the Conservation Element of the Santee General Plan. Impacts would be less than significant.

2. Habitat Conservation Plans
Threshold: Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan (NCCP), or other approved local, regional, or state habitat conservation plan? Finding: Less than significant. (EIR, § 4.3.5.6.)
Explanation: The City is actively preparing its Draft MSCP Subarea Plan. The Draft Santee MSCP Subarea Plan would implement the MSCP Subregional Plan and is intended to result in issuance to the City of federal and state authorizations (permits) for the take of certain listed threatened or endangered species. These authorizations would be granted to the City by USFWS and CDFW pursuant to Section 10(a)(1)(B) of the Endangered Species Act and Section 2835 of the California Natural Community Conservation Planning Act, respectively. The City, in turn, may then extend the take authorizations to public and private projects within its jurisdiction, as long as those biological resources are adequately conserved by the Santee MSCP Subarea Plan and the projects are consistent with and covered by the provisions of the Santee MSCP Subarea Plan.

The proposed project design is consistent with the Draft Santee MSCP Subarea Plan through specific adherence to conditions of coverage and mitigation/conveyance requirements for hardline Covered Projects as defined in the Draft Santee MSCP Subarea Plan (City of Santee 2018). The proposed project would not compromise continued implementation of the MSCP in the County or other cities because their Subarea Plans do not rely on the City of Santee for coverage of any species. Furthermore, the current project footprint has been reduced from the previous development hardline footprint identified in the approved 1998 MSCP Plan (City of San Diego 1998).

A large development bubble in the southern portion site from the 1998 project design was removed, increasing the size of the current Habitat Preserve by more than 200 acres. Development of the proposed project would contribute 1,650.4 acres to the targeted 171,917 acres within the MHPA for conservation (City of San Diego RESOLUTION 093-2020
20 1998). Therefore, implementation of the current project design would be consistent with the Draft Santee MSCP Subarea Plan and would not compromise future implementation of the MSCP Subarea Plan within the City of Santee because the current project meets all requirements and provides a greater level of conservation than required for the Santee MSCP Subarea Plan pursuant to the MSCP Plan.

The proposed project comprises the Fanita Ranch Subunit of the Draft Santee MSCP Subarea Plan. The Santee General Plan, including its Conservation Element, and the NCCP Enrollment Agreement executed by the City require that any development in the City comply with the Draft MSCP Subarea Plan. This requirement applies to the proposed project and all other development that would impact biological resources in the City.

Therefore, the proposed project’s consistency with the MSCP Subarea Plan would be ensured by the City, and impacts related to consistency with habitat conservation plans (HCPs) would be less than significant.

E. CULTURAL RESOURCES

1. Historical Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: Less than significant. (EIR, § 4.4.5.1.)
Explanation: The Cultural Resources Phase I Survey Report evaluated one potential historic resource, the Stowe Trail, which runs through the very western edge of the area of potential effect (APE) and connects the City of Santee with the City of Poway. Atkins was unable to locate any documentation specifying the precise length or boundaries of the Stowe Trail. However, historical U.S. Geological Survey maps suggest it is quite short, extending approximately 1 mile north of Stowe to intersect with other trails. The dirt road was of local importance to Stowe, a small ranching community in northern Sycamore Canyon (north of the project site), in the latter half of the nineteenth century. The dirt road had likely fallen out of use by 1942.

Although this dirt road was locally important for several decades, no historic artifacts were observed during the pedestrian survey. It is likely that modern activity, including road maintenance, entirely replaced the original road surface and has disturbed or obscured any subsurface historic or prehistoric cultural materials. For these RESOLUTION 093-2020
21 reasons, this section of the dirt road is unlikely to contain cultural deposits and was recommended not eligible to the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR), or any local designation because it lacks the integrity necessary to convey its historic significance. Therefore, the proposed project’s impact to this site would be less than significant.

No other historic resources were observed on site or identified through records searches or archival research. Therefore, the proposed project would not cause a substantial adverse change in the significance of a historic resource pursuant to Section 15064.5 of the CEQA Guidelines. Impacts are less than significant.

F. ENERGY

1. Wasteful Use of Energy
Threshold: Would the Project result in a potentially significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Finding: Less than significant. (EIR, § 4.5.5.1.)
Explanation: Construction. Construction of the proposed project would result in temporary energy consumption and one-time, non-recoverable energy costs associated with construction of structures, utilities, and roadways. Energy consumption as a result of construction of the proposed project would primarily consist of the consumption of fossil fuels as a result of use of off-road construction equipment, movement of soil, and use of on-road vehicles for worker commuting and vendors.

As shown in EIR Tables 4.5-5 and 4.5-6 of the EIR, peak total daily energy consumption from on- and off-road sources would be approximately 1,855 MMBtu per day and would occur during Phase

1. The transportation fuel consumption in California is approximately

2.9 billion MMBtu per year, or approximately 7.8 million MMBtu per day. The proposed project would result in an increase in temporary indirect energy consumption compared to energy consumption without project construction. However, this level of energy consumption would be negligible at the regional level (approximately

0.03 percent of statewide transportation fuel consumption) and would be a one-time use during project construction. Construction of the proposed project would not include unusual construction practices that would result in wasteful or inefficient consumption of energy compared to typical construction. Therefore, construction of the proposed project would not cause a significant temporary energy RESOLUTION 093-2020
22 impact during construction. This impact would be less than significant.

Operation:

Electricity. The proposed project’s estimated electricity consumption and renewable energy generation were calculated for project operation. EIR Table 4.5-7 provides estimated energy consumption with and without implementation of the mitigation measures required to reduce air quality and GHG emissions in Sections 4.2 and 4.7, respectively. Specifically, Mitigation Measure AIR-8 would reduce energy use, and Mitigation Measure GHG-1 requires generation of renewable energy on the project site. The annual electricity consumption of the proposed project with Mitigation Measures AIR7, GHG-4, and GHG-6 would be higher than without mitigation measures due to the electricity consumption by electric vehicles (EVs) and all-electric residences. However, mitigation would include on-site renewable electricity generation (Mitigation Measure GHG-1) that would offset the higher electricity consumption of the proposed project.

The U.S. Census Bureau reported that, in 2017, the total population in the County was 3,325,468 (U.S. Census Bureau 2020). The proposed project is anticipated to generate a service population of approximately 8,424 people under the preferred land use plan with school, or 8,345 people under the land use plan without school, which is equal to approximately 0.3 percent of the County’s total population. The proposed project would be home to approximately

0.3 percent of the County’s population but would consume approximately 0.15 percent of the County’s total electricity consumption without any mitigation and 0.06 percent of the County’s total electricity consumption when on-site renewable generation is taken into account. Therefore, before mitigation, the proposed project’s electricity consumption per person would be efficient compared to its proportion of the County’s population and would not result in significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources. The implementation of the air quality and GHG mitigation measures further improves the proposed project’s energy efficiency by decreasing its proportion of energy consumption in the County.

Additionally, with implementation of Mitigation Measure GHG-1, the proposed project would generate renewable energy on site. By buildout, the proposed project would generate approximately 20,472,039 kilowatt-hours (kWh) and 20,378,877 kWh of electricity per year from distributed photovoltaic solar electric generation on site, under the preferred land use plan with school and land use plan RESOLUTION 093-2020
23 without school, respectively, which is equal to approximately 63 percent of the total electricity demand. The on-site generation of renewable energy would reduce the project’s percent of County 2017 energy consumption to 0.06 percent. Therefore, the proposed project’s operational electricity impacts would be less than significant.

Natural Gas. Natural gas consumption was estimated for the preferred land use plan with school and the land use plan without school and with and without implementation of the mitigation measures required to reduce air quality and GHG emissions.

Specifically, Mitigation Measure GHG-4 requires all-electric residences, which would substantially reduce natural gas consumption. These mitigation measures are not required to reduce energy consumption but would have the added benefit of reducing natural gas consumption. EIR Table 4.5-8 of the EIR provides estimated natural gas use at project buildout with and without mitigation measures required for air quality and GHG impacts.

At full buildout, without mitigation, the proposed project would result in an annual natural gas consumption of approximately 60,889 MMBtu and 62,329 MMBtu under the preferred land use plan with school and the land use plan without school, respectively, which is approximately 0.13 percent of the County’s total natural gas consumption of 48,000,000 MMBtu in 2017. Because the population of the proposed project would be approximately 0.3 percent of the County’s total population, and its natural gas consumption would be

0.13 percent, the proposed project’s natural gas consumption would be efficient compared to its population. This impact would be less than significant prior to implementation of mitigation measures for air quality and GHG emissions impacts. However, with implementation of all-electric residences (Mitigation Measure GHG-4), natural gas use on the project site would be further reduced to approximately

0.04 percent of the County’s total consumption under the preferred land use plan with school and 0.03 percent for the land use plan without school. Therefore, the proposed project would not result in a significant environmental impact due to the wasteful, inefficient, or unnecessary consumption of natural gas. This impact would be less than significant.

Petroleum. EIR Table 4.5-9 of the EIR shows the annual petroleum demand at full buildout of the proposed project under the preferred land use plan with school and the land use plan without school and with and without the transportation demand management mitigation measure (Mitigation Measure AIR-6). The mitigation measure is not required to reduce energy use but would have the added benefit of RESOLUTION 093-2020
24 reducing fuel consumption. The petroleum consumption estimate at the state level is available for comparison to the proposed project’s petroleum consumption estimate. The proposed project would consume approximately 0.01 percent of the state’s total petroleum consumption. The U.S. Census Bureau reported that, in 2018, the total population in California was 39,557,045 (U.S. Census Bureau 2020). The proposed project is anticipated to generate a service population of approximately 8,424 people under the preferred land use plan with school, or 8,345 people under the land use plan without school, which is equal to approximately 0.02 percent of the state’s total population. Therefore, the proposed project’s petroleum consumption would be efficient compared to its proportion of the state population and would not result in a significant environmental impact due to the wasteful, inefficient, or unnecessary consumption of energy resources. Impacts related to petroleum consumption would be less than significant.

2. Energy Efficiency Plans
Threshold: Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Finding: Less than significant. (EIR, § 4.5.5.2.)
Explanation: Energy use on the project site during construction would be temporary, and energy use associated with operation of the proposed project would be relatively small in comparison to the state’s and County’s available energy sources. It would also be efficient compared to the proposed project’s estimated proportion of the state’s and County’s population. In addition, on-site renewable energy generation (Mitigation Measure GHG-1) combined with allelectric residences (Mitigation Measure GHG-4) would significantly reduce the energy usage associated with operation of the proposed project. Because the proposed project’s per capita energy consumption would be less than the state or County level for the same resource, the proposed project would not conflict with California’s energy conservation plans as described in the California Energy Commission’s (CEC) 2019 Integrated Energy Policy Report (IEPR). Therefore, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. This impact would be less than significant.

G. GEOLOGY AND SOILS

1. Fault Rupture, Seismic Groundshaking, and Seismic-Related Ground Failure RESOLUTION 093-2020
25 Threshold: Would the Project 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; strong seismic ground shaking; seismic-related ground failure including liquefaction; or landslides?
Finding: Less than significant. (EIR, § 4.6.5.1.)
Explanation: Fault Rupture. The geotechnical investigations prepared for the proposed project indicated that no known active, potentially active, or inactive faults are on the project site or in off-site improvement areas. In addition, the proposed project is not on the Alquist-Priolo Earthquake Fault Zoning Map. The nearest known active faults are the Newport-Inglewood Fault and Rose Canyon Fault Zone, both located approximately 15 miles west of the project site. As a result, ground surface rupture is not likely to occur due to an earthquake or seismic event. Due to the distance of these faults from the project site, the proposed project is not anticipated to be at risk from ground surface rupture at these faults. In addition, all new structures associated with the proposed project would be constructed in compliance with the 2019 CBC or most current code at the time of construction. Therefore, because no active faults are located on or near the project site and project construction would comply with the CBC, implementation of the proposed project would result in a less than significant impact associated with the rupture of a known earthquake fault.

Ground Shaking. The project site is located in a seismically active area that has the potential to experience strong ground shaking.

Ground shaking has the potential to dislodge objects from walls, ceilings, and shelves and to damage and destroy buildings and other structures. People in the area would be exposed to these hazards.

The proposed project would minimize hazards associated with damage or destruction to buildings and other structures through compliance with the CBC, which includes specific structural seismic safety provisions. Given the proposed project’s compliance with the CBC, impacts associated with ground shaking would be less than significant.

Liquefaction. Soil liquefaction typically occurs when loose, saturated, and relatively cohesionless soil deposits found below the water table lose strength during strong seismic ground motions. Seismically induced soil liquefaction is a phenomenon in which loose to medium dense, saturated granular materials undergo matrix rearrangement, develop high pore water pressure, and lose shear strength due to RESOLUTION 093-2020
26 cyclic ground vibrations induced by earthquakes. Due to the relatively high density and grain-size distribution characteristics of the fill and formational materials at the project site, and the absence of a permanent water table in the proposed development area, the risk of seismically induced soil liquefaction occurring at the project site is very low. In addition, due to the dense formational material encountered, lack of significant deposits of saturated soils that could be susceptible to liquefaction, and compliance with the CBC, liquefaction occurrence at the off-site improvement areas is also low.

Therefore, impacts related to liquefaction would be less than significant.

Landslides. The stability and potential impacts of ancient landslides located on the project site and off-site improvement areas were evaluated in the geotechnical investigations prepared for the proposed project. The geotechnical investigations found that landslide instability due to seismic ground shaking is not anticipated and that there are no known ancient landslides within the Friars Formation in the County that have reactivated due to natural causes.

Therefore, the potential for seismically induced landslides occurring on the project site is low. Impacts would be less than significant.

2. Septic Tanks
Threshold: Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? Finding: No impact. (EIR, § 4.6.5.5.)
Explanation: The proposed project proposes connections to existing sewer lines within the City. No septic systems or other alternative wastewater disposal systems are proposed. Therefore, no impact would occur.

H. HAZARDS AND HAZARDOUS MATERIALS

1. Hazardous Materials
Threshold: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Finding: Less than significant. (EIR, § 4.8.5.1.)
Explanation: Construction. Project construction activities could result in the transport, use, and disposal of hazardous materials such as fuels, grease, and lubricants for construction equipment and vehicle use, asphalt during roadway construction activities, and toxic solvents, RESOLUTION 093-2020
27 pesticides, and herbicides during site clearing and landscaping activities. These materials would be used and stored in designated construction staging areas within the boundaries of the project site and in staging areas for off-site improvements. Activities associated with the temporary aggregate plant would include crushing rock and producing roadway subbase and other aggregate materials for use on the project site using electricity to power the plant. If electricity is not available, a diesel generator would be used to power the aggregate plant. Project construction activities would comply with all applicable local standards set forth by the City, as well as state and federal health and safety requirements that are intended to minimize hazardous materials risk to the public, such as the RCRA, CERCLA, SARA, Hazardous Materials Transportation Act, CCR Title 22 and Title 27, Cal/OSHA requirements, the Hazardous Waste Control Act, the California Accidental Release Protection (CalARP) Program, and the California Health and Safety Code. The construction contractor would be required to implement such regulations relative to the transport, handling, and disposal of any hazardous materials, including the use of standard construction controls and safety procedures to avoid a significant hazard to the public or environment.

Standard construction practices would be observed such that any materials released are appropriately contained and remediated as required by local and state laws.

Operation: The types of uses proposed by the proposed project include residential units, Village Center buildings, potential school, agricultural uses, recreational and trails, sewer/water connections, and roadway improvements typical of residential community development. Without development of the school site, the potential sources of hazardous materials typically associated with schools would not contribute to the proposed project’s potential impacts related to hazardous wastes.

Residential, Village Center, and Parks and Recreational Uses:

Operation of the proposed project would involve the use of potentially hazardous materials typical of residential, commercial, agricultural, recreational, and civic uses including cleaning fluids, detergents, solvents, adhesives, sealers, paints, fuels/lubricants, and fertilizers or pesticides for landscaping. The proposed land uses would result in an increase in hazardous chemical waste generation at the site compared to the current baseline condition. However, these materials would be transported, contained, stored, used, and disposed of in accordance with manufacturers’ instructions, applicable standards, and federal, state, and local regulations.

Compliance with applicable state and local regulations would serve RESOLUTION 093-2020
28 to protect against a significant and irreversible environmental change that could result from the routine use of these hazardous materials.

Agricultural Uses: Implementation of the proposed project would include agricultural uses associated with the Farm and within the Agriculture Overlay area. This includes terraced vegetable fields, pasture lands, limited housing for employees, raised gardens, and pastures/facilities for farm animals. These uses are anticipated to involve the use of pesticides, fertilizers, and other hazardous materials. However, any use of fertilizers or pesticides as part of agricultural operations are required to comply with CalEPA’s enforcement of pesticide laws and regulations in California.

Additionally, animal raising would generate animal waste which could result in vectors, such as flies, and could be considered a hazard itself if not handled and disposed of correctly. However, standard housekeeping practices and best management practices are adequate for addressing the hazards of animal waste. Therefore, compliance with existing federal and state regulations and using standard housekeeping practices and best management practices would ensure that the routine transport, use, and dispose of hazardous materials related to agricultural uses would result in a less than significant impact.

School Use: The School Overlay reserves a school site for a potential K–8 public school or other educational uses on the project site. If acquired by the Santee School District, the site would be able to accommodate up to 700 students, including existing Santee students and new students on the project site. Schools throughout the state generate hazardous waste as a normal part of the operation and maintenance of each school. Typical wastes generated by the routine operation and maintenance of K–12 schools include the following: Electronic equipment (e.g., computer monitors), batteries, and copier or printer toners from school daily operation and administration; chemical and biological hazardous wastes from chemistry and science labs; used oil, antifreeze, solvents, degreasers, and auto batteries from auto repair shops and classrooms or compressors; pesticides, cleaning solvents, detergents, and oil-based or latex paint wastes from school maintenance and housekeeping or janitorial functions.

In California, on-site and off-site storage of hazardous waste is a regulated activity that requires authorization under the Department of Toxic Substances Control (DTSC) five-tiered program for hazardous waste treatment or storage. School uses are required to comply with DTSC requirements for on-site and off-site collection and storage of hazardous wastes. This requires obtaining permits to RESOLUTION 093-2020
29 manage and transport hazardous waste products. Therefore, compliance with state requirements and permitting under the DTSC would ensure that the routine transport, use, and dispose of hazardous materials associated with the potential school would result in a less than significant impact.

2. Hazards Near Schools
Threshold: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school? Finding: Less than significant. (EIR, § 4.8.5.3.)
Explanation: Sycamore Canyon Elementary School, is located on Settle Road, approximately 500 feet from the proposed Special Use area along the southwestern boundary of the project site in the Carlton Hills neighborhood. Approximately 350 students are currently enrolled in the elementary school. The Special Use area falls within the notification area for Gillespie Field and has a height restriction, thus limiting its development potential. It is also on landslide deposits, which further limits its development potential. Therefore, the Special Use area would allow for a limited range of uses, such as a solar farm, recreational vehicle and boat storage, aboveground agriculture without irrigation, and other similar uses. The types of hazardous materials that would be potentially emitted from the site could include gasoline, diesel fuel, oils, and grease from the recreational vehicle and boat storage and pesticides from the aboveground agriculture.

However, due to the limited nature of development proposed, the Special Use area is not anticipated to emit or handle hazardous materials in quantities large enough to affect the nearby school. As such, the permitted uses for the Special Use area would not result in activities that emit hazardous emissions or handle hazardous materials, substances, or waste in quantities that would affect persons at Sycamore Canyon Elementary School.

In addition, existing residential uses and intervening topography provide a buffer from any hazardous materials that could be potentially emitted from the Special Use area. The applicant is required to include a minimum 50-foot buffer adjacent to the existing homes to the south and southwest and a minimum 100-foot buffer to the west to preserve neighbor privacy. This would also provide an additional buffer between the existing and permitted land uses. In the event that agricultural uses are implemented in the Special Use area, the potential for pesticides to become airborne during application exists. However, they would be handled and disposed of in accordance with all federal, state, and local laws regulating the RESOLUTION 093-2020
30 management and use of hazardous materials such that an impact would not occur.

CEQA Guidelines, Section 15186(b), stipulates that before certifying an EIR for a project located within 0.25 mile of a school that involves the construction of a facility that might emit hazardous air emissions or handle an extremely hazardous substance, the lead agency is required to consult with and provide written notification to the school district no less than 30 days prior to the certification of the EIR.

Sycamore Canyon Elementary School is located within 0.25 mile of the proposed Special Use area. However, as discussed previously, the Special Use area is not anticipated to emit hazardous air emissions or handle an extremely hazardous substance or a mixture containing extremely hazardous substances in a quantity equal to or greater than the state threshold quantity specified in the California Health and Safety Code. Therefore, it is not anticipated that the proposed project would trigger the requirements of CEQA Guidelines, Section 15186(b), and consultation with and notification to the Santee School District would not be required.

The preferred land use plan with school includes a 15-acre school site with a School Overlay to allow for the development of a future school by the Santee School District. Land uses in the vicinity of the school would include residential, commercial, agricultural, recreational, and civic uses, which would require the routine transport, use, and disposal of hazardous materials. However, these materials would be contained, stored, and used on site in accordance with manufacturers’ instructions, applicable standards, and federal, state, and local regulations. While hazardous materials and waste would be handled within 0.25 mile of a proposed school associated with the proposed project, these materials would not exist in quantities large enough to pose a health risk to users of the nearby school. Additionally, these types of land uses do not typically constitute incompatible land uses near a school.

The PDMWD Ray Stoyer WRF is approximately 0.25 mile southwest of the 15-acre school site proposed in Fanita Commons under the preferred land use plan with school. The WRF handles hazardous materials, including chlorine and sulfur dioxide gas. The RMP for the WRF lays out a comprehensive plan for the protection of public health and addresses potential chlorine and sulfur dioxide spills at this facility. Pursuant to CEQA Guidelines, Section 15186(c)(2), notification is required in writing by the Santee School District to consult with the San Diego Air Pollution Control District over the siting of the new school near a facility known to handle hazardous materials. The PDMWD Ray Stoyer WRF is within 0.25 mile of the proposed school site. This is a formal notification requirement that RESOLUTION 093-2020
31 would be completed in accordance with Section 25502 of the California Health and Safety Code and would be necessary for the Santee School District to make a finding to approve the site.

The DTSC school siting requirements would not allow for development of a school adjacent to incompatible land uses or those that would release hazardous materials. In accordance with the California Education Code and California Code, Sections 17210.1 through 17213.2, as with all proposed school sites that would receive state funding for acquisition or construction, the Santee School District would be required to comply with CEQA for its acquisition of the proposed project’s school site. The proposed school site has been reviewed in the Phase I ESA prepared for the proposed project.

As concluded in the Phase I ESA, the project site is not a former waste disposal site and has not been identified by DTSC as a hazardous waste release site, and there are no pipelines carrying hazardous waste that traverse the project site. Therefore, there is no evidence of existing on-site RECs in connection with the proposed school site. Under the land use plan without school, no impact would occur.

The proposed project would comply with federal and state regulations pertaining to hazardous waste, such as proper handling, disposal practices, and cleanup procedures, to ensure that risks associated with hazardous emissions or materials to existing or proposed schools within one-quarter mile of the project site would not result in a significant impact. Impacts would be less that significant.

3. Waste Sites
Threshold: Would the Project 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?
Finding: Less than significant. (EIR, § 4.8.5.4.)
Explanation: As part of the Phase I ESA, a hazardous materials record search was conducted for the project site and surrounding properties from federal, state, and local databases. According to the government hazardous materials databases searched, no reported hazardous materials sites are located within the boundaries of the project site.

Pursuant to Government Code, Section 65962.5, there is one facility located within one-quarter mile of the project site that was listed three times on LUST database. This facility is the 7-Eleven located at a facility at 9750 Cuyamaca Street. According to the findings in the RESOLUTION 093-2020
32 Phase I ESA, all three LUST listings identified for the facility relate to a release of gasoline on three separate occurrences (March 1986, May 1991, and June 1994). Regulatory closure was granted in each case.

The Phase I ESA determined that based on distance from the project site, downstream position, and closed regulatory status, the facility located at 9750 Cuyamaca Street is unlikely to have caused a REC at the project site. Therefore, the proposed project would not result in a significant hazard to the public or the environment due to the presence of hazardous materials sites identified pursuant to Government Code, Section 65962.5, as it relates to annual updates to the Cortese List. Impacts would be less than significant.

4. Airport Safety
Threshold: 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 for people residing or working in the project area?
Finding: Less than significant. (EIR, § 4.8.5.5.)
Explanation: The project site is located in the vicinity of two airports: MCAS Miramar (private federal) and Gillespie Field (public). The project site is east of MCAS Miramar. The portions of the project site proposed for development fall outside of any Overflight Zones and are not subject to overflight-related disclosure or notification requirements.

According to the MCAS Miramar ALUCP, the entire project site is located within the Federal Aviation Regulations Part 77 Outer Boundary, which establishes standards and Federal Aviation Administration notification requirements for potential hazards to use of navigable airspace. A small northerly portion of the project site falls within Review Area 2 of the AIA, which requires ALUC review for any proposed objects with a height greater than 35 feet above ground level. However, this portion of the project site would be dedicated as Habitat Preserve and would not be developed. The easterly portions of the project site are within a High Terrain zone but are not within Review Area 2; therefore, they do not require ALUC review. The remainder of the project site is located outside of the AIA. Thus, the proposed project would not be subject to any land use restrictions from MCAS Miramar.

The project site is also located north of Gillespie Field. Southerly portions of the project site are located within the Federal Aviation Administration Height Notification Boundary and are proposed as Habitat Preserve and Special Use area. Within this boundary, the RESOLUTION 093-2020
33 Federal Aviation Administration shall be notified of any proposed construction or alteration having a height greater than an imaginary surface extending 100 feet outward and 1 foot upward (slope of 100 to 1) from the runway elevation. The Special Use area also falls within the Gillespie Field Review Area 2, which requires limitations on the height of structures. Review Area 2 also requires overflight notification documents for residential uses; however, residential uses would not be permitted within the Special Use area, except for a caretaker unit. If a caretaker unit is proposed, the applicant is required to provide notification and compliance in accordance with the Gillespie Field Review Area 2 requirements. Therefore, implementation of the proposed project would not result in a significant impact regarding airspace safety hazards or conflicts with the land use plans for MCAS Miramar or Gillespie Field.

5. Emergency Plans
Threshold: Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Finding: Less than significant. (EIR, § 4.8.5.6.)
Explanation: The proposed project would have a significant impact if it were to interfere with the City’s adopted Emergency Operations Plan (2010).

The City’s Emergency Operations Plan addresses the planned response to extraordinary emergency situations associated with natural and human-caused disasters. In addition, the Unified San Diego County Emergency Services Organization and County Operational Area Emergency Operations Plan – Evacuation Annex was formed in the 1960s to assist the cities and the County in developing emergency plans by providing strategies, procedures, recommendations, and organizational structures that can be used to implement a coordinated evacuation effort in the County Operational Area (County of San Diego 2018). Additionally, the proposed project has developed new project-specific evacuation and emergency responses plans, including the Fire Protection Plan, Construction Fire Prevention Plan, and Wildland Fire Evacuation Plan. According to Santee Fire Department, the proposed project would not interfere with current evacuation and emergency plans.

The proposed project’s interior street network and the existing regional street system that it connects with would provide multidirectional primary and secondary emergency evacuation routes consistent with, or exceeding, most communities in this area.

Furthermore, the only proposed through routes on the project site would loop between Fanita Parkway and Cuyamaca Street on site RESOLUTION 093-2020
34 and would not affect emergency response and evacuation plans elsewhere in Santee. Consistent with County Operational Area Emergency Operations Plan – Evacuation Annex (County of San Diego 2018), major ground transportation corridors in the area would be used as primary evacuation routes during an evacuation effort.

The primary roadways that would be used for evacuation from the project site are Fanita Parkway and Cuyamaca Street. The available evacuation routes (Fanita Parkway and Cuyamaca Street) would meet the 2019 California Fire Code, Appendix D, and the Santee Municipal Code and Ordinance 570 requirement for multiple access points and, therefore, are considered adequate for emergency purposes. These streets provide access to major traffic corridors, including directly or indirectly to State Route (SR-) 52 to the south, SR-67 to the east, Interstate (I-) 8 to the south, I-125 to the south, and I-15 to the west.

During an emergency evacuation from the project site, the primary and secondary roadways may serve as egress for those leaving the project site and as ingress for responding emergency vehicles.

Because the roadways are designed to meet or exceed the City’s Fire Code requirements, including unobstructed travel lane widths consistent with the Fanita Ranch Specific Plan standards, unobstructed travel lanes, adequate parking, 28-foot inside radius, grade maximums, signals at intersections, and extremely wide roadside fuel modification zones, potential conflicts that could reduce the roadway efficiency are minimized, allowing for smooth evacuations. Additionally, the streets would provide residents the option to evacuate from at least two points in two different directions from each neighborhood.

The project site’s primary evacuation routes would be accessed through a series of internal neighborhood roadways, which connect with the primary ingress/egress streets that intersect off-site primary and major evacuation routes. Based on the existing street network, the community would evacuate to the north (once off site), south, east, and west depending on the nature of the emergency.

Depending on the nature of the emergency requiring evacuation, it is anticipated that the majority of the community traffic would exit the proposed project via Cuyamaca Street. This is the most direct route for the project site. Fanita Parkway may be used by the western portion of the project site, depending on the time available for evacuation and the need for additional movement via the southerly route. In a typical evacuation that allows several hours or more time (as experienced for most areas during the 2003, 2007, 2014, 2016, and 2017 wildfires), all traffic may be directed to the south and out Cuyamaca Street. If less time is available, fire and law enforcement RESOLUTION 093-2020
35 officials may direct some neighborhoods to temporarily shelter in their residences.

The decision on whether to evacuate or shelter-in-place is carefully considered with the timing and nature of the incident. Sheltering-inplace is the preferred method of protection for people who are not directly impacted or in the direct path of a hazard. This would reduce congestion and transportation demand on the major transportation routes for those who have been directed to evacuate by law enforcement or fire personnel. The proposed project would incorporate ignition-resistant construction and wide fuel modification zones and provide defensibility throughout. Therefore, responding fire and law enforcement personnel would be able to direct project residents to temporarily refuge in their homes in the rare situation where that alternative is determined to be safer than evacuating. The proposed project would not impair the implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Therefore, impacts are considered less than significant impact.

I. HYDROLOGY AND WATER QUALITY

1. Water Quality Standards
Threshold: Would the Project violate any water quality standards or waste discharge requirements?
Finding: Less than significant. (EIR, § 4.9.5.1.)
Explanation: Construction and operation activities associated with the proposed project could result in an increase in potential discharge of pollutants to receiving waters, including waters designated as impaired for certain conditions of concerns. Hydromodification could increase stormwater runoff and intensify erosion and the transport of sediments and other pollutants. Development of vacant land would introduce new types of pollutants in stormwater runoff.

Construction: During construction, the proposed project has the potential to produce pollutants such as sediment, nutrients, heavy metals, organic compounds, trash and debris, oxygen-demanding substances, oil and grease, bacteria and viruses, and
pesticides/herbicides. Additionally, waste materials such as wash water, paints, wood, paper, concrete, food containers, and sanitary wastes may be discharged from the project site during construction.

These pollutants could impact water quality if they were washed off site by stormwater or non-stormwater or are blown or tracked off site to areas susceptible to wash off by stormwater or non-stormwater.

RESOLUTION 093-2020
36 Pollutants are likely to drain into Sycamore Canyon Creek. Sycamore Canyon Creek drains into the San Diego River, which then drains into the Pacific Ocean. Therefore, these water bodies are identified as the receiving waters of the proposed project. Impairments for these water bodies include dissolved oxygen, benthic community effects, cadmium, indicator bacteria, nitrogen, dissolved oxygen, phosphorus, total dissolved solids, and toxicity for the San Diego River. Under these impairments, the receiving water cannot assimilate or accommodate additional loading of pollutants, and any increases in pollutants would contribute to the impairment.

The proposed project would be subject to compliance with Construction General Permit requirements and with Chapter 9.06 of the Santee Municipal Code, which prohibits non-stormwater discharges and eliminates illicit discharges and illicit connections to the stormwater conveyance system, reduces the discharge of pollutants from the stormwater conveyance system to the maximum extent practicable in order to achieve applicable water quality objectives for surface waters in the County, and achieves compliance with TMDL regulations (City of Santee 2020).

Prior to project grading or construction, the Construction General Permit requires preparation of a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP would include a series of specific BMPs to be implemented during construction in order to address erosion, accidental spills, and the quality of stormwater runoff. The SWPPP applies only to the time period in which construction activity is taking place, and is no longer operative once the soil on the project site has been stabilized and a Notice of Termination is completed. BMPs that must be implemented as part of a SWPPP can be grouped into two major categories: (1) erosion and sediment control BMPs and (2) non-stormwater management and materials management BMPs.

As part of project compliance with the General Construction Permit, a Notice of Intent would be prepared and submitted to the San Diego RWQCB providing notification and intent to comply with the General Permit. The Construction General Permit also requires that construction sites be inspected before and after storm events and every 24 hours during extended storm events. The purpose of the inspections is to identify maintenance requirements for BMPs and to determine the effectiveness of BMPs that are being implemented.

Operation: Operation of the proposed project land uses would have the potential to generate pollutants that could degrade the surface water quality of downstream receiving waters. Pollutant sources from operation of the proposed project would include landscaping, rooftops, parking and driveways, roadways, agricultural uses, RESOLUTION 093-2020
37 general use areas, and trash storage areas. Pollutants from operation of the proposed project would include sediment, nutrients, heavy metals, organic compounds, trash and debris, oxygendemanding substances, oil and grease, bacteria and viruses, and pesticides. In addition, project implementation would require routine operation and maintenance activities, thereby increasing instances of accidental spills and non-stormwater discharges to storm drains, and non-stormwater connections (e.g., sewer connections) that could result in the potential discharge of pollutants to storm drainage systems and associated receiving waters.

Consistent with the City’s Stormwater Management Ordinance, the proposed project is considered a priority development project and is required to identify and incorporate measures for hydromodification management to ensure that stormwater runoff rates and durations do not exceed pre-development conditions or result in adverse erosion or sedimentation effects. All priority development projects are required to implement structural BMPs for stormwater pollutant control. Additionally, projects subject to hydromodification management requirements must implement structural BMPs for flow control. Structural BMPs, such as biofiltration (basins and proprietary modular units) and combined pollutant control and hydromodification control measures, have been incorporated into the proposed project design.

Runoff from natural and sloped areas containing no impervious areas would be collected in separate storm drains and discharged through riprap energy dissipaters to avoid comingling of drainage and to allow any course sediment generated in the areas to pass through. The proposed project would extend and make
improvements to Fanita Parkway and would include features in accordance with Green Streets design elements, including rock garden swales and tree wells, to address water quality. Street improvements would reset roadway widths, medians, utilities, and storm drain conveyance systems. The proposed storm drain system would be constructed to collect and convey on-site runoff as well offsite run-on from developed areas east of Fanita Parkway that confluences with the Fanita Parkway flows. However, instead of discharging into an open channel along the western side of Fanita Parkway as it currently does, confluence flows would be conveyed within a storm drain pipe within Fanita Parkway to an existing drainage. Cuyamaca Street would also be extended and improved to provide access to the project site. Similar to Fanita Parkway, this street would also include Green Street design elements, such as rock gardens and tree wells.

RESOLUTION 093-2020
38 Through changes in topography and land cover on the project site, the proposed project has the potential to result in impacts to sedimentary transport to downstream channel areas, known as Potential Critical Coarse Sediment Yield Areas (PCCSYA), by altering the sediment producing areas on the project site. The alteration of PCCSYAs has the potential to negatively impact characteristics of sediment supply and delivery which can lead to water quality degradation of downstream receiving waters. To avoid impacts to PCCSYAs produced on the project site and resulting downstream water quality impacts, the discharges of the sediment producing areas would be diverted to adjust the sediment production as close as possible to the original conditions. As a result, the proposed project would not encroach into more than 5 percent of the proposed project’s potential PCCSYAs areas off site and would have no net encroachment into on-site areas. In addition, the discharges of the project site would be adjusted by designing BMPs such that the erosion from the discharged flows is as close as possible to the pre-development conditions. The proposed project would avoid significant impacts to both on- and off-site PCCSYAs and water quality through redirecting sediment producing discharges, adherence to BMPs, and the protection of the remaining natural areas. Therefore, alteration of the drainage area on the project site would have less than significant impacts to PCCSYAs and would not result in the loss of sedimentary transport or decreased water quality to downstream channel areas.

The Stormwater Quality Management Plan identifies a number of site design BMPs to ensure that water quality is maintained during project operation. BMPs have been incorporated into the project design to minimize impacts from project-generated operational pollutant sources, which include sediment, nutrients, heavy metals, organic compounds, trash and debris, oxygen-demanding substances, oil and grease, bacteria and viruses, and pesticides.

Preparation of and compliance with the SWPPP, implementation of BMPs identified in the Stormwater Quality Management Plan, and compliance with existing federal, state, and local regulations as discussed previously would protect water quality and ensure project compliance with applicable water quality standards. The proposed project would not violate any water quality standards or WDRs.

Additionally, the implementation of these BMPs would help treat runoff and decrease the amount of pollution entering receiving waters. Therefore, impacts would be less than significant.

2. Groundwater Supplies
RESOLUTION 093-2020
39 Threshold: Would the Project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
Finding: Less than significant. (EIR, § 4.9.5.2.)
Explanation: The City does not rely on groundwater sources for its water supply.

No groundwater would be used for project construction or operation activities. Therefore, the proposed project would not adversely affect or deplete groundwater supplies due to water demand generated by the proposed development.

Development of the proposed project would result in new impervious surfaces that may lead to a decrease in the amount of water recharged into the groundwater system within the project boundaries. To minimize potential effects on groundwater recharge, the proposed project would be designed to include pervious, landscaped areas, allowing groundwater recharge to continue to occur. Runoff from developed areas would drain into proposed onsite basin system designed to slow peak flow and discharge to rates equal to or less than existing conditions. Hydromodification management would occur through storage of stormwater within the basins, with outlets that regulate the flow rate and duration of stormwater released. Source control and low-impact development measures would be implemented to incorporate pervious surfaces and maximize the amount of open space, landscaping, and vegetated swales to slow and absorb runoff, allowing for groundwater recharge.

Further, the proposed project would include a total of approximately 2,022.6 acres of undeveloped area including 256 acres of Open Space, 1,650.4 acres of Habitat Preserve, and 116.2 acres of Agriculture and Parks (Community, Neighborhood, and Mini). As such, groundwater recharge in these areas would continue after project implementation.

The proposed project is not anticipated to substantially deplete groundwater supplies or interfere substantially with groundwater recharge. No groundwater would be used for project construction or operation, and the proposed project would be designed to minimize potential effects to groundwater recharge through consolidation of impervious surfaces and the retaining of approximately 2,022.6 acres as Open Space, Habitat Preserve, and Agriculture and Parks.

Impacts would be less than significant.

3. Erosion or Siltation
RESOLUTION 093-2020
40 Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or impede or redirect flood flows?
Finding: Less than significant. (EIR, § 4.9.5.3.)
Explanation: Construction. Land-disturbing construction activities associated with implementation of the proposed project, such as vegetation clearing, grading, and excavation of project sites, and construction of new building foundations, streets, driveways, and trenches for utilities, could result in localized alteration of drainage patterns and temporarily increase erosion and sedimentation in the construction area.

Temporary ponding or flooding could also result from construction activities from temporary alterations of the drainage system (reducing its capacity of carrying runoff). Alterations may temporarily result in increased erosion and siltation if flows were substantially increased or routed to facilities or channels without capacity to carry the additional flow.

Construction phase activities implemented under the proposed project would be required to comply with the SWRCB General Construction Stormwater Permit, which requires preparation of a SWPPP. The SWPPP would include a series of specific BMPs to be implemented during construction to address erosion, accidental spills, and the quality of stormwater runoff, which have been developed in part to reduce the potential adverse effects associated with construction activities. In addition, construction phase activities implemented under the proposed project would be required to comply with Chapter 9.06 of the Santee Municipal Code, which mandates the implementation of a pollution control plan for each phase of construction and season of the year (City of Santee 2020).

The pollution control plan would incorporate BMPs in accordance with the California Stormwater Quality Association’s Construction BMP Handbook (2015).

Therefore, with the adherence to regulatory requirements, which include the implementation of erosion and sediment control BMPs, any short-term impacts resulting from alterations of drainage and hydrology during construction would be less than significant.

RESOLUTION 093-2020
41 Operation. The proposed project would result in hydromodification from development of impervious surfaces in an area that is currently undeveloped. Hydromodification could increase stormwater runoff and intensify erosion and the transport of sediments and other pollutants. Changes to delivery of coarse sediment and transport of coarse sediment result in increased transport capacity and the potential for adverse channel erosion (City of Santee 2016).

Additionally, impervious surfaces do not allow percolation of the water down into the soil. Water is instead forced directly into storm drain systems or streams, where increases in erosion and siltation could result, as well as increased flood risks. These alterations could also result in exceeding the existing capacity of stormwater facilities if substantial drainage is rerouted or stormwater flow or velocities are substantially increased. To avoid these types of impacts, the proposed project includes a drainage network designed to control and filter stormwater runoff in conformance with RWQCB and City’s requirements, which call for retention first, then biofiltration. The proposed stormwater system would include the use of biofilters, onsite storage of stormwater in basins with outlets that regulate the flow rate and duration of stormwater released, and the use of both retention and detention basins to slow and sequester runoff.

The pre- and post-development conditions for the proposed project were evaluated to determine if the proposed biofiltration facilities are sized adequately to meet the current HMP requirements of the RWQCB. Hydromodification management would occur through storage of stormwater in proposed on-site basins, with outlets to regulate the flow rate and duration of stormwater released. Runoff would be collected in storm drain inlets from street surfaces and routed toward multi-purpose basins and treated for stormwater quality, flow control for hydromodification, and flood attenuation to maintain existing peak-flow rates during a 100-year storm event.

As indicated in the Master Drainage Study, the pre-development project 100-year flows are 3,312 cubic feet per second. Through project design, stormwater runoff upon project completion would result in 2,729 cubic feet per second 100-year flows. Thus, project design would help to reduce flows by approximately 583 cubic feet per second versus existing conditions.

The proposed project would construct a total of 19 stormwater basins and 3 vaults. Of the 19 stormwater basins, the proposed project would construct 15 on-site stormwater basins (BF-1-1 through BF-1- 6, BF-1-17, HMP-17, HMP-18, and BF-1-RV1 through BF-1-RV6).

Biofiltration basins BF-1-1 through BF-1-6, BF-1-17, and BF-1-RV1 through BF-1-RV6 would serve as combined water quality, hydromodification, and detention basins. Basins HMP-17 and HMP- RESOLUTION 093-2020
42 18 would serve as hydromodification and detention basins. In addition, the proposed project would construct four off-site stormwater basins (BF-1-10A, BF-1-10B, HMP-11, and HMP-12) and three vaults (HMP-13, HMP-15, and HMP-16). BF-1-10B would serve as a water quality, hydromodification, and detention basin.

Basins HMP-11 and HMP-12 and vaults HMP-13, HMP-15, and HMP-16 would serve as hydromodification and detention facilities. In addition, an interim basin would be constructed adjacent to and directly east of Cuyamaca Street on property currently identified as APN-378-220-05. The interim basin would be removed at such time that Magnolia Avenue would be extended.

The system would collect stormwater through a series of swales, catch basins, and culverts that direct stormwater to
detention/biofiltration basins. Runoff from the residential portions of the site would generally be collected by inlets and conveyed toward one of the proposed detention basins. Flows would outlet the basins and discharge into downstream conveyance channels consisting of storm drain pipes, constructed channels, or natural drainage ways.

The proposed basins would also serve as detention for flow-control hydromodification and peak-flow attenuation. Peak-flow attenuation would be required not only due to the increase in imperviousness associated with the development but also because the site design proposes to divert acreage from areas that currently drain easterly and southerly to drain westerly toward Sycamore Canyon Creek.

Other areas along the roadway corridors of Fanita Parkway and Cuyamaca Street would include storage facilities such as underground vaults and aboveground basins to address local peakflow attenuation. Each detention facility would be equipped with a riser designed to accomplish the various functions. Orifices placed along the height of the rise would regulate the lower flow rates to address flow-control hydromodification. The cross-sectional area of the riser would aid in regulating the higher flows to reduce flows below existing conditions. The basins would also include a second riser installed for redundancy and as an emergency outlet should the primary riser clog. Design of this secondary riser would be performed during final engineering. Depending on the accessibility of the riser structures, it may be necessary to equip some of them with a grate over the top opening as a safety measure. The biofiltration basins proposed for the site would be lined; therefore, no infiltration is assumed in the biofiltration basins.

The storm drain system and layout would be designed to address peak flows and to integrate water quality features needed to comply with the City’s BMP Design Manual requirements for water quality and hydromodification. As designed, the proposed project would RESOLUTION 093-2020
43 allow biofiltration, evapotranspiration, and filtering of stormwater to remove microscopic organisms, suspended solids, organic material, nitrogen, and phosphorous. The results show that development of the proposed project would not increase peak flows for any point of discharge. Therefore, the proposed project would not compromise the capacity of downstream drainage facilities, and effects due to erosion, sedimentation, and flooding are anticipated to be minimal.

The proposed project has been designed in compliance with the San Diego RWQCB and the City’s requirements. Post-development flow rates would be reduced to below pre-development flow rates with implementation of bioretention and hydromodification basins.

Construction runoff would be contained in compliance with the State of California Construction Permit. Post-construction runoff would be cleaned through bioretention basins and modular wetlands in compliance with the San Diego RWQCB Order R9-2013-0001.

Portions of Fanita Parkway and Cuyamaca Street have been designed as a Green Street per the requirements of the San Diego RWQCB.

All site runoff would receive water quality treatment prior to discharging off site. To prevent erosive velocities at pipe outlet locations, energy dissipating measures would be included as part of project design. These measures would be designed during final engineering and would include but not be limited to riprap and concrete energy dissipating headwalls. Landform grading has been incorporated into the proposed project to mimic existing conditions where the proposed grading ties into or daylights with the existing terrain. It is intended that the stormwater running off manufactured slopes would sheet flow and follow existing drainage patterns.

Implementation of hydromodification measures would reduce postproject flows to below pre-project conditions. As shown, the basins proposed for the proposed project would help to reduce flows by approximately 583 cubic feet per second compared to existing conditions. Thus, post-project flows would be released into Sycamore Canyon Creek at a lower rate than existing natural flows.

Runoff from the adjacent hillsides and natural off-site areas would be collected in a series of brow ditches and conveyed to culverts located within the proposed street improvements. Runoff generated by the hardscape improvements would be intercepted via curb and gutter, draining to an internal storm drain system that would convey these flows to Modular Wetland Biofiltration BMP’s prior to draining to HMP detention facilities. Once treated and detained, these flows are then discharged to their respective discharge location. Proposed structural BMPs would be maintained by the homeowners
association in perpetuity.

RESOLUTION 093-2020
44 Additionally, Green Streets principles and infrastructure are proposed for meeting water quality requirements for portions of Fanita Parkway and Cuyamaca Street in the areas outside of the villages where the roadways are proposed to be improved. The Green Streets approach integrates strategies into roadway design that help protect, restore, and mimic the natural water cycle such that runoff is encouraged to be percolated or stored in a more natural manner, with the use of features such as rock garden swales and tree wells, which are designed to capture runoff from hardened surfaces, slow water down, spread it out, and allow it to sink into the soil during storms. Methods like this would help to trap silt and pollutants to reduce siltation and erosion. The use of Green Street principles would reduce the proposed project’s potential to increase peak flows. Therefore, compared to existing conditions, the potential for erosion to occur downstream of the project site would be reduced with implementation of the proposed project. Existing flow velocities would be lessened with implementation of the proposed project since post-development flows would be reduced. As such, the proposed project would not compromise the capacity of downstream drainage facilities, and effects due to erosion and sedimentation are anticipated to be minimal. Therefore, erosion and siltation is not expected downstream of the project site.

Further, the project design includes improvements to allow connection to the City’s existing stormwater infrastructure system.

Proposed improvements would ensure that stormwater flows are properly maintained and treated on site so that runoff volumes or velocities do not exceed that which currently occur under existing conditions. The proposed project would be subject to National Pollution Discharge Elimination System (NPDES) requirements and other local, state, and federal regulations pertaining to maintaining water quality and minimizing potential adverse effects on downstream water bodies. Because stormwater runoff from the site would be less with the proposed project, it would not create or contribute runoff that would exceed the capacity of existing or planned stormwater drainage systems, and the proposed project would not generate additional sources of polluted runoff.

Lastly, the project site is in Federal Emergency Management Agency Flood Zone X, which is outside of the 100- and 500-year flood hazard areas. The proposed project would be designed to reduce peak-flow rates such that downstream locations would be below existing flow rates. The proposed project would not impede or redirect flood flows because redirected areas would be reduced by attenuation facilities such that post-development flows would not exceed pre-project flows. Therefore, the proposed project would not substantially alter the existing drainage pattern of the site or area, including through the RESOLUTION 093-2020
45 alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would substantially increase the rate or amount of surface runoff in a way that would impede or redirect flood flows or result in substantial erosion or siltation on or off site or flooding on or off site. The proposed project would not create or contribute runoff that would exceed the capacity of existing or planned stormwater drainage systems, and the proposed project would not generate additional sources of polluted runoff. As such, impacts would be less than significant.

4. Flood Hazard
Threshold: In flood hazard, tsunami, or seiche zones, would the Project risk release of pollutants due to project inundation?
Finding: No impact. (EIR, § 4.9.5.4.)
Explanation: The project site is not subject to inundation by tsunami or seiche. The project site is located approximately 16 miles from the Pacific Ocean negating the potential for the site to be subject to a tsunami event. A seiche is a wave on the surface of a lake or landlocked bay that is caused by atmospheric or seismic disturbances. The nearest lake to the project site is San Vincente Reservoir located approximately 2 miles from the northeastern portion of the project site. This portion of the project site is located at approximately 1,000 feet above mean sea level and the area between the reservoir and the project site is a valley. This topographical variation would make it difficult for the project site to be inundated by the reservoir. Further, the project site is located in Federal Emergency Management Agency Flood Zone X, which is outside of the 100- and 500-year flood hazard areas.

Therefore, implementation of the proposed project would not release pollutants due to inundation caused by a flood hazard, tsunami, or seiche.

5. Water Quality Control Plan
Threshold: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Finding: Less than significant. (EIR, § 4.9.5.5.)
Explanation: The project site is located within the San Diego River Hydraulic Unit (HU) of the San Diego region as defined by the San Diego RWQCB and is further located within the Santee Hydrologic Subarea. The project site currently drains west to Sycamore Canyon Creek and east to unnamed tributaries and storm drain conveyance systems that eventually discharge to San Diego River, both of which are on the CWA Section 303(d) list for dissolved oxygen. Once developed, RESOLUTION 093-2020
46 on-site hydromodification would divert acreages from areas that drained easterly to now drain west toward Sycamore Canyon Creek.

As identified in the Basin Plan, the designated beneficial uses for Sycamore Canyon Creek include: agricultural supply (AGR), industrial services supply (IND), contact water recreation (REC1), non-contact water recreation (REC2), warm freshwater habitat (WARM), and wildlife habitat (WILD), and rare, threatened, or endangered species (RARE). Sycamore Canyon Creek is a tributary to the San Diego River, which is on the CWA Section 303(d) list for benthic community effects, cadmium, indicator bacteria, nitrogen, dissolved oxygen, phosphorus, total dissolved solids, and toxicity.

Construction and operation activities associated with the proposed project could result in an increase in potential discharge of pollutants to receiving waters, including waters designated as impaired.

Additionally, hydromodification could increase stormwater runoff and intensify erosion and the transport of sediment and other pollutants.

Land use changes may also introduce new types of pollutants in stormwater runoff. There is no sustainable groundwater
management plan prepared for the project site.

Construction. Construction activities associated with the proposed project would involve various types of equipment such as bulldozers, scrapers, backhoes, and other earthmoving equipment; dump trucks; cranes; trucks; concrete mixers; and generators. Pollutants associated with these construction activities that could result in water quality impacts include soils, debris, other materials generated during demolition and clearing, fuels and other fluids associated with the equipment used for construction, paints, other hazardous materials, concrete slurries, and asphalt materials. The proposed project would be required to comply with General Construction Stormwater Permit requirements, including the development and implementation of a SWPPP. The SWPPP must identify BMPs that the discharger would use to protect stormwater runoff from pollutants and the placement of those BMPs. Therefore, with the
implementation of policies and regulatory requirements, which include the implementation of construction-period BMPs to address potential discharges of pollutants to stormwater, any short-term water quality impacts during construction of the proposed project would be minimized and would not cause a conflict with or obstruct implementation of the Basin Plan. Therefore, impacts would be less than significant.

Operation. Implementation of the proposed project would result in land use changes that would have the potential to generate pollutants that could degrade the surface water quality of downstream receiving waters. Pollution sources for the proposed project would include landscaping, rooftops, parking, and trash RESOLUTION 093-2020
47 storage areas. In addition, implementation of the proposed project would also result in routine operation and maintenance activities, increasing opportunities for accidental spills and non-stormwater discharges to storm drains and non-stormwater connections (e.g., sewer connections) that could result in the potential discharge of pollutants to receiving waters.

However, the proposed project requires the implementation of construction and operation BMPs, which include low-impact development site design and source control BMPs, to reduce runoff or pollutants at the source. Therefore, with implementation of appropriate BMPs, compliance with Chapter 9.06 of the Santee Municipal Code, and applicable state requirements, project impacts would be minimized and would not conflict with or obstruct implementation of the Basin Plan. Impacts would be less than significant.

J. LAND USE AND PLANNING

1. Established Communities
Threshold: Would the Project physically divide an established community? Finding: Less than significant. (EIR, § 4.10.5.1.)
Explanation: The proposed project does not contain any components that could result in dividing an established community. The project site is an undeveloped area located in the City’s boundary. Areas directly north are currently undeveloped, though they are designated as Rural Lands (RL-40) (one residential unit per 40 acres) and Open Space (Conservation) by the San Diego County General Plan and zoned Agriculture (A70) and Specific Plan (S80). Beyond that, north of the project site and west of SR-67 lies the 2,272-acre Goodan Ranch/Sycamore Canyon County Preserve. Areas northeast include undeveloped hillsides and Slaughterhouse Canyon, where active mining operations take place. East of the project site is an unincorporated rural residential subdivision known as Eucalyptus Hills. Existing detached single-family residences in the Carlton Hills neighborhood are south of the project site. The Santee Lakes Recreation Preserve is southwest of the project site and MCAS northwest of the project site.

Proposed roadways would connect, rather than separate, the project site from established communities in the vicinity. A proposed extension of Fanita Parkway and Cuyamaca Street would connect the project site to the existing residential development to the south.

RESOLUTION 093-2020
48 Additionally, people have historically taken informal access through the proposed project for active and passive recreation.

Implementation of the proposed project would formalize permanent public access trails, trailheads, and staging areas. The proposed project proposes more than 35 miles of multimodal public trails allowing access for pedestrians and bicyclists throughout the site and providing connections to the City center and regional trails. Thus, the proposed trail system would provide enhanced connectivity to existing trails in and near the project site. The proposed project would not result in the physical division of an established community.

Impacts would be less than significant.

2. Conflicts With Plans
Threshold: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Finding: Less than significant. (EIR, § 4.10.5.2.)
Explanation: The review of local land use plans, including the ALUCPs for MCAS Miramar and Gillespie Field, SANDAG’s Regional Plan, the Santee General Plan, and the City’s Zoning Ordinance, has indicated that the proposed project would be generally consistent with the implementation of these plans.

San Diego County Airport Land Use Compatibility Plans: The project site is located in the vicinity of two airports: MCAS Miramar and Gillespie Field. The project site abuts the easterly property line of the MCAS Miramar. The entire project site is within the Federal Aviation Regulations, Part 77, Outer Boundary, which establishes standards and Federal Aviation Administration notification requirements for potential hazards to use of navigable airspace. The easterly portions of the project site are in a High Terrain zone, which is an area of land in the vicinity of an airport where the ground is above a surface regulated by Federal Aviation Regulations, Part 77. However, only a small northerly portion of the site falls in Review Area 2 of the AIA.

The portion of the site in Review Area 2 would be dedicated as Habitat Preserve and would not be developed, and the remainder of the project site is outside of any AIA. Therefore, the proposed project would not be subject to any land use or development restrictions. In addition, the areas proposed for development fall outside of any Overflight Zones and are not subject to overflight-related disclosure or notification requirements (SDCRAA 2011).

The project site is north of Gillespie Field. Southerly portions of the site are within the Federal Aviation Administration Height Notification RESOLUTION 093-2020
49 Boundary. The proposed Habitat Preserve and Special Use area are within this notification boundary. Within this boundary, the Federal Aviation Administration is required to be notified of any proposed construction or alteration having a height greater than an imaginary surface extending 100 feet outward and 1 foot upward (slope of 100 to 1) from the runway elevation. The Special Use area also falls in the Review Area 2, which requires limitations on the height of structures. Review Area 2 also requires overflight notification documents for residential uses; however, residential uses are not permitted in the Special Use area, except for one caretaker unit. If a caretaker unit is proposed, notification in accordance with the Review Area 2 requirements would be made. The development standards for the Special Use area consider the site’s relationship to Gillespie Field and adjacency to off-site neighbors. Height in the Special Use area would be limited to conform to the Gillespie Field ALUCP. Buffers would be required adjacent to existing residences off site to preserve privacy (SDCRAA 2010). Therefore, the proposed project would be consistent with the ALUCPs for MCAS Miramar and Gillespie Field.

San Diego Forward: The Regional Plan: In accordance with SB 375, the Regional Plan includes five building blocks that are accompanied by strategies to move the San Diego region toward sustainability and to reduce greenhouse gas emissions. The building blocks and strategies aim to reduce greenhouse gas emissions through a land use pattern that accommodates the region’s future employment and housing needs and protects sensitive habitats, cultural resources, and resource areas.

The proposed project proposes Village Center, Medium Density Residential, Low Density Residential, and Active Adult land use designations that would allow for a diversified mix of housing types.

Additionally, the proposed development would be clustered into three villages to preserve approximately 63 percent of the site as Habitat Preserve to maintain core habitat identified in the Final MSCP Plan, preserve known wildlife corridors, and maintain a contiguous and connected open space system, which would help implement the first building block. By clustering compact, walkable, sustainable, low-impact development in strategic locations that minimize ecological impacts, development of the proposed project would allow for the restoration of sensitive habitat areas and management of the Habitat Preserve. Implementation of the proposed project would include the establishment of a formal management entity and a management plan to monitor and protect biodiversity. Open space corridors between the villages would preserve connectivity and allow for continued wildlife movement through the site. Wildlife crossings at roadways would be designed RESOLUTION 093-2020
50 to support the safe and efficient movement of wildlife. In addition, existing drainages between the villages would allow for revegetation and restoration of these important features, which provide habitat and connectivity for wildlife.

The proposed project’s mobility plan focuses on reducing the number and length of vehicle trips and providing alternatives to fossil fuelpowered vehicle use, which would help implement the second building block. This would be achieved through organizing land uses to locate services and goods close to residences and optimizing circulation systems to create direct, efficient, safe, and comfortable routes for a variety of transportation modes. The proposed project land uses are designed to meet the daily needs of the project residents to minimize trips outside the project site. Emphasis is placed on encouraging a transportation network that generate fewer emissions, such as walking, biking, electric vehicles, transit, and ridesharing. A Transportation Demand Management (TDM) Plan has been prepared to support alternative modes, manage shared facilities to optimize transportation modes, implement and support appropriate advanced technologies, and reduce greenhouse gas emissions. The TDM Plan considers community programs to support and encourage ridesharing, alternative modes, and other strategies to reduce single-occupancy vehicle use, which would help implement the third and fourth building blocks. Implementation of the TDM Plan would be required by Mitigation Measure AIR-6.

The proposed project includes a Complete Streets system that supports various modes of transportation and offers alternatives to single-occupancy vehicle travel. Streets on the project site are designed as a system of Complete Streets that safely accommodate and support multiple user types, including motorists, pedestrians, bicycles, and transit riders in an effort to manage the transportation system. The Fanita Ranch Specific Plan establishes the street designs within the boundaries of the project site. Street improvements associated with development on the project site include the extension of existing streets and the construction of a new internal systems of public and private streets. The proposed project establishes a network of streets of varying design capacities tailored to meet the unique concepts of the three villages.

Additionally, the proposed project street designs address safety, aesthetics, and functionality, as well as site constraints.

The proposed project would offer sustainable transportation features that would reduce the number of vehicle trips, reduce emissions, and improve the overall mobility of people in the community, all of which would help implement the fifth building block (innovative pricing policies) of the Regional Plan. One proposed mobility feature is a RESOLUTION 093-2020
51 bicycle circulation network throughout the community through a combination of on-street bike lanes and off-street multi-purpose trails. Bicycle trails would be designed for both recreation and to provide direct access between the villages. Another project feature is a project layout that promotes walkability and wellness. The proposed project would provide direct connections to multiple destinations that shorten the routes and allow walking to be an efficient and viable method of travel. The project proposes two pedestrian bridges that would provide direct connections across the two drainages in Fanita Commons to shorten the walking distance.

The bridge that would traverse the northerly drainage would provide convenient access between the Active Adult neighborhood and the Community Park. The bridge that would traverse the southerly drainage would connect Orchard Village to the school, Community Park, and Fanita Commons. Additionally, every street on the project site would include a sidewalk or multi-purpose trail to accommodate pedestrian travel. Trails along the northerly and southerly drainages would also offer pedestrian connections between the school, the Farm, and the Active Adult neighborhood with minimal interruptions from vehicular traffic. The proposed project would include a pedestrian and bicycle mobility system consisting of sidewalks, trails, and bikeways throughout the proposed project, providing linkages between neighborhoods to other key land uses.

The proposed project supports the Regional Plan by proposing a land use pattern and TDM strategies that would accommodate the region’s future employment and housing needs and protect sensitive habitats, cultural resources, and resource areas. Therefore, the proposed project would be consistent with the strategies and objectives of the Regional Plan.

Multiple Species Conservation Program: The proposed land use plan would be consistent with the Fanita Ranch Subunit of the City’s Draft MSCP Subarea Plan. The proposed project would adhere to or exceed conditions of coverage and mitigation/conveyance requirements for covered projects as defined in the City’s Draft MSCP Subarea Plan (City of Santee 2018). The Santee General Plan, including its Conservation Element and the Natural Communities Conservation Plan Enrollment Agreement executed by the City, requires that any development in the City comply with the City’s Draft MSCP Subarea Plan.

Santee General Plan: The Santee General Plan provides the framework for the City’s long range planning vision. One of the proposed discretionary actions is an amendment to the Santee General Plan to change the land use designation for the project site from Planned Development (PD) to Specific Plan (SP). The Fanita RESOLUTION 093-2020
52 Ranch Specific Plan would be adopted by ordinance by the City. The Fanita Ranch Specific Plan would support the City’s need for diverse housing types and high-quality amenities while preserving sensitive habitat areas. The Fanita Ranch Specific Plan is designed to ensure fiscally sound development by balancing appropriate land uses and providing flexibility in the plan to respond to changing market conditions through the provision of diverse housing types and sizes supported by adequate services and infrastructure. The Fanita Ranch Specific Plan also provides permitting procedures and development standards, design guidelines, street standards, financing mechanisms, maintenance entities, and phasing to ensure proper implementation, operation, and maintenance of the community over time. As such, the purpose of the Fanita Ranch Specific Plan is to implement the Santee General Plan.

Since the Santee General Plan’s adoption in 2003, the economy and market demands have changed. As a result, the current
development proposal for the project site better addresses the needs of the community, future residents, and tenants. Included as part of the General Plan amendment, the applicant proposes to amend the 16 Guiding Principles for Fanita Ranch to better adhere to the current project design. The existing 16 Guiding Principles for Fanita Ranch would be replaced by the proposed 13 Guiding Principles identified in EIR Table 4.10-1. These amendments are required to ensure that the proposed project is in compliance with the Santee General Plan.

As shown in EIR Table 4.10-1, the project is consistent with the proposed 13 Guiding Principles. As identified in EIR Table 4.10-2, the proposed project would be consistent with all the applicable goals, objectives, and policies of the Santee General Plan.

City of Santee Zoning Ordinance: To facilitate the type of development consistent with the Zoning Ordinance, the proposed project includes a zone change from Planned Development (PD) to Specific Plan (SP), which would amend the Santee Zoning District Map and Zoning Ordinance as part of the proposed project to designate the property as Specific Plan (SP) and allow zoning to be administered through the Fanita Ranch Specific Plan. The Fanita Ranch Specific Plan provides a unique set of development standards that allow for creative housing types and use configurations not currently addressed in the City’s existing Zoning Ordinance. The proposed project would include detailed zoning standards and design guidelines intended to facilitate the creation of new and innovative housing types and configurations, walkability, and housing attainability by creating greater efficiency and addressing the diverse range of incomes, lifestyles, special needs, and household types in Santee and the greater San Diego County region.

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53 Therefore, the proposed project would be consistent with the City’s Zoning Ordinance upon project approval.

K. MINERAL RESOURCES

1. Regional and Statewide Mineral Resources
Threshold: Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Finding: Less than significant. (EIR, § 4.11.5.1.)
Explanation: Construction of the proposed project has the potential to impact the mineral resources of both known and unknown significance in MRZ2 and MRZ-3 on the project site. The proposed project would have the potential to impact MRZ-2 lands in the northeastern and central portions of the proposed project where the Vineyard and Orchard Villages would be developed. The development of Fanita Commons, the Farm, and surrounding roadways would have the potential to impact MRZ-3 lands. The MRZ-2 lands in the southern portion of the project site and the majority of the MRZ-3 lands throughout the rest of the project site would remain undeveloped in the proposed Habitat Preserve. Although there is the potential of mineral recovery from the MRZ-2 and MRZ-3 areas on the project site, in accordance with the Santee General Plan Conservation Element, economic, land use compatibility, and environmental protection factors must be considered when deciding on the appropriateness of mining in a particular area. Furthermore, the Santee General Plan designates the project site for Planned Development, not mineral resources extraction.

The majority of the project site is underlain with two major rock types, granitic rock and Stadium Conglomerate, with alluvial deposits made up of sand, gravel, and silt overlaying these basement rocks. These rock formations are commonly mined elsewhere in the County and the State of California for use as aggregate and are considered valuable to the region and the state. The proposed project would reuse on-site rock materials, such as large boulders, rock cobble, decomposed granite, and processed rock. There are large quantities of rock cobble existing on site. Rock cobble would be collected and used in the construction of water quality and landscape features. It is also anticipated that a relocatable, temporary aggregate plant would be permitted and set up on site during construction. The temporary aggregate plant would crush rock and produce roadway subbase and other aggregate materials for use on site. In addition to rock materials, there are large deposits of decomposed granite on site, RESOLUTION 093-2020
54 which would be reused for trails and other landscape related purposes.

The processing and use of the on-site aggregate would reduce the need for mining and trucking aggregate materials from off-site sources for the infrastructure needs of the proposed project. The onsite aggregate plant would be capable of producing the materials required for roads, drain rock and backfill materials for wet and dry utilities, cobbles to line drainage channels and road medians, and a variety of landscaping materials for on-site and off-site road improvements. Construction of the proposed project would require on-site processing of approximately 937,500 tons of raw aggregate obtained from the project site. This equates to approximately 300,000 cubic yards of manufactured aggregate to be used for the building materials for the proposed project. Areas of high-grade Stadium Conglomerate or granite would be selected as the cut operation is ongoing and would be moved to the aggregate plant as aggregate is needed. The on-site aggregate plant would be permitted by the City as a part of the overall project entitlement process. Rock-crushing activities would comply with the City’s noise standards and regional air quality standards. The on-site aggregate plant would not be designed to produce materials for asphalt or ready-made concrete. These materials would be brought in from local off-site sources. The use of the on-site aggregate plant would terminate at project buildout.

In consideration of the Santee General Plan Conservation Element’s Objective 5.0 and Policy 5.1, the project site’s proximity to the Goodan Ranch/Sycamore Canyon County Preserve and the Santee Lakes Recreation Preserve would likely preclude the proposed project from eligibility for mineral extraction due to the potential habitat and water quality impacts to those preserve areas. Use of the on-site aggregate plant would allow for the mineral resources existing on the project site to be used as part of the proposed project and would not contribute to other environmental impacts from transporting aggregate from off-site locations. Transitioning the onsite aggregate production areas to the proposed project uses would comply with the Santee General Plan Conservation Element’s Objective 6.0 and Policy 6.1, which prioritize the reclamation of mined lands for the use of recreational, wildlife habitat, and residential uses. In addition, consistent with the Santee General Plan Conservation Element’s Objective 10.0, over 60 percent of the project site would remain in open space, and the mineral resources like aggregate and sediment in the open space would not be lost to the region. Therefore, the proposed project would result in a less RESOLUTION 093-2020
55 than significant impact associated with the loss of mineral resources that would be of value to the region and the state.

2. Locally-Important Mineral Resource
Threshold: Would the Project result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Finding: Less than significant. (EIR, § 4.11.5.2.)
Explanation: The Santee General Plan Conservation Element designates the project site as MRZ-2 and MRZ-3 lands containing mineral resources of known and unknown importance. However, the proposed project would satisfy the Santee General Plan Conservation Element’s Objectives 5.0, 6.0, and 10.0 and Policies 5.1 and 6.1 regarding consideration of environmental disturbance from mineral resources extraction; reclamation of mined lands for recreational, habitat, and residential uses; and the preservation of mineral resources. In addition, the Santee General Plan designates the project site as Planned Development, not mineral resource extraction, and does not consider the project site a potential significant local source of mineral resources. Therefore, the proposed project would result in a less than significant impact associated with the loss of availability of a locally important mineral resource recovery site.

L. NOISE

1. Airport Noise
Threshold: 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?
Finding: Less than significant. (EIR, § 4.12.5.3.)
Explanation: MCAS Miramar is located adjacent to the west/northwestern boundary of the project site. The runways are located approximately 6 miles west of the project site. Additionally, Gillespie Field is located approximately 1.75 miles south of the project site. The project site is currently subject to periodic, audible overflights, particularly from MCAS Miramar. However, the proposed project site is not located within the 60 dBA CNEL noise contour of either airport (SDCRAA 2010, 2011). Additionally, the proposed project does not include any components that would increase air traffic or require changes to RESOLUTION 093-2020
56 existing air traffic patterns. As such, overflights are anticipated to continue to be audible at the project site; however, the proposed project is not anticipated to increase exposure to excessive noise levels from airport operation. Therefore, impacts would be less than significant.

M. POPULATION AND HOUSING

1. Population Growth
Threshold: Would the Project 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 road or other infrastructure)?
Finding: Less than significant. (EIR, § 4.13.5.1.)
Explanation: Direct Impacts
Preferred Land Use Plan with School: The proposed project would result in the construction of 2,949 residential units under the preferred land use plan with school. Of the 2,949 residential units, 445 are proposed to be designated as Active Adult units. The proposed project residential population is based on a population generation factor of 2.9 persons per household and 1.6 persons per Active Adult unit. Based on this population factor, the proposed project is expected to result in a population increase of approximately 7,974 residents (2.9 x 2,703 residential units) + (1.6 x 445 Active Adult units). It is unknown whether the proposed project would generate residents from in the City or result in resident migration from other areas. Presumably, the additional residents generated by the proposed project would be a combination of current residents in the City and residents who migrate from other areas. The analysis conservatively assumes the proposed project would increase the City’s population by 7,974 residents.

SANDAG’s population projections for the City are based on the adopted Santee General Plan. The current designation of the project site as Planned Development (PD) in the Santee General Plan Land Use Element and the identification of the site to provide 1,395 units in the Santee General Plan Housing Element demonstrate that the site has been planned for residential growth by the City. Using the

2.9 persons per household multiplier, a development project of 1,395 units could result in a population increase of approximately 4,045 residents. The difference between the planned and proposed land uses, when translated to persons per household, is approximately 3,929 persons. However, the project site has been subject to land RESOLUTION 093-2020
57 use planning for the past 40 years, indicating that this site was planned for development even before it was part of the City. In 1980, the project site was designated in the County General Plan for development of approximately 14,000 residential units. When the City adopted its first General Plan (1984), the project site was designated for a maximum of 8,100 residential units. The number of residential units proposed on the project site has continued to vary over the years, with many proposals greater than the 2,949 residential units currently proposed, indicating that the project site has been intended for population growth by the City and the County for many decades. In addition, the proposed project would include a General Plan Amendment to change the designation of the project site from Planned Development (PD) to Specific Plan (SP) and to increase the number of residential units on the site up to 2,949 with a school, which would be consistent with the Santee General Plan Housing Element, as amended (City of Santee 2013).

Further, the production of housing in California has not returned to the level required to meet the projected housing demand and would need to be approximately 100,000 additional residential units annually to meet this demand (HCD 2018). In the County, SANDAG projected that housing production at the regional level will not be able to keep pace with population growth in the coming years. Because new development in the County are constrained to the north by Camp Pendleton, to the west by the Pacific Ocean, and to the south by Mexico, the proposed project would be beneficial to County residents because it would contribute to the overall County housing stock. Construction of the proposed project is anticipated to begin in 2021 with a buildout of approximately 10 to 15 years. Thus, based on a conservative estimate and averaged over 10 years, the 7,974- person population increase would equate to approximately 797 new residents per year, which would be consistent with the City’s historical population increases. In the context of the housing shortage currently experienced by the state and the San Diego region, the provision of new housing on the project site would be considered growth accommodating and would represent a regional benefit.

In addition, the RHNA has identified housing needs based on income level for the City. The Santee General Plan Housing Element lists the project site as the only source for above moderate income residential units. Other sites are identified to meet RHNA requirements for the other income levels. The proposed project would satisfy the RHNA requirements for above moderate residential units and provide additional residential units to meet the anticipated future deficiencies in the City.

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58 Further, the widening of State Route 52 from Cuyamaca Street to State Route 67 has contributed to the loss of housing in the City. This project resulted in the loss of approximately 199 residential units as of 2006, which the proposed project would replace (Poucel 2006).

Therefore, the preferred land use plan with school would not result in direct impacts to unplanned population growth, and impacts would be less than significant.

The Planned Development (PD) land use designation in the Santee General Plan allows for a variety of mixed-use development types, including commercial uses. The proposed project proposes to change this land use designation to Specific Plan (SP). Similar to the Planned Development (PD) land use designation, the Specific Plan (SP) land use designation would allow for innovative and high-quality development and would not limit the extent or mix of development to occur, which would allow more flexibility to provide a variety of land uses. The non-residential components of the proposed project, including commercial uses (retail, service, and office) in the Village Centers, the Farm, and the proposed school, would result in the creation of approximately 450 jobs (411 full-time and 39 part-time positions), which would not induce substantial population growth given the size of the labor pool anticipated on the project site and in the existing City and nearby communities. Approximately 250 jobs would be associated with the proposed on-site school. The proposed project is not anticipated to cause significant numbers of people to relocate to the area solely to be close to the project site for employment purposes. This proposed non-residential development is allowed by the Specific Plan (SP) land use designation and would not contribute to unplanned population growth.

Land Use Plan Without School: The underlying land use for the onsite designated school location is Medium Density Residential. If the school site is not acquired for school use by the Santee School District within 2 years of filing the final map containing the school site, then the Medium Density Residential land use may be implemented on the school site for development of an additional 59 residential units, for a total project development potential of 3,008 residential units. Using the same population generation factors of 2.9 persons per household (U.S. Census Bureau 2020) and 1.6 persons per Active Adult unit, the land use plan without school would provide housing for approximately 8,145 residents, which would be an increase of 171 persons compared to the preferred land use plan with school.

As discussed previously, SANDAG’s population projections for the City are based on the adopted Santee General Plan land uses for the project site, which would allow 1,395 residential units that could RESOLUTION 093-2020
59 result in a population increase of approximately 4,045 residents (assuming 2.9 persons per household). The difference between the planned and proposed land uses, when translated to persons per household, is approximately 4,100 persons. As stated previously, the project site has been slated for development for the past 40 years with designated residential development ranging from 1,395 to 14,000 residential units. In addition, the state and the County recognize a prominent housing deficit, and the provision of new housing on the project site would be considered growth
accommodating and would represent a regional benefit. The proposed project proposes a General Plan Amendment to increase the units on the site up to 3,008 without a school, which would be consistent with the Santee General Plan Housing Element, as amended (City of Santee 2013).

Additionally, the land use plan without school would be a phased development with a construction start date of 2021 and a buildout of approximately 10 to 15 years. Therefore, based on a conservative estimate and averaged over 10 years, the 8,145-person increase would equate to approximately 815 new residents per year. The land use plan without school would be consistent with the historical numeric population increases that have occurred in the City.

Therefore, under the land use plan without school, the proposed project would not induce unplanned population growth, and impacts would be less than significant.

The proposed Specific Plan (SP) land use designation would replace the Planned Development (PD) land use designation on the project site, which would allow for a variety of mixed-use development, including commercial uses. The non-residential components of the land use plan without school would include commercial uses (retail, service, and office) in the Village Centers and the Farm. These uses are estimated to create approximately 200 jobs (161 full-time and 39 part-time staff positions), which would not induce substantial population growth given the size of the labor pool anticipated on the project site and in the existing City and nearby communities. Nonresidential development is allowed by the Specific Plan (SP) land use designation and would not contribute to unplanned population growth.

Indirect Impacts
Preferred Land Use Plan With School and Land Use Plan Without School: Population growth can be induced indirectly with the provision of streets or other infrastructure. Substantial new infrastructure would be built to serve the project site including the extension of and improvements to Fanita Parkway and Cuyamaca RESOLUTION 093-2020
60 Street. These street extensions are included in the Santee General Plan Mobility Element and would facilitate residential development contemplated in the Santee General Plan Land Use Element. The proposed project would also extend water and sewer utilities to the project site. The infrastructure improvements would allow for the development of the proposed project, the resulting growth of which is described previously. However, the extension of infrastructure would not allow for additional development on the project site or beyond, since the undeveloped open space on the project site would be dedicated in perpetuity as Habitat Preserve and much of the undeveloped land surrounding the project site is owned by the federal government, County and Padre Dam Municipal Water District and is not planned for future growth. Instead, the proposed infrastructure would accommodate growth already planned for in the area. Therefore, the proposed project would not indirectly induce substantial population growth. The proposed project’s indirect impacts would be less than significant.

2. Displacement of Housing
Threshold: Would the Project displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere; and displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?
Finding: No impact. (EIR, §4.13.5.2.)
Explanation: The project site is currently undeveloped, and there are no existing housing units on the project site. As such, the proposed project would have no impacts related to the displacement of substantial numbers of existing housing units or people. Therefore, this significance criterion listed previously would not apply to the proposed project, and no additional analysis related to this criterion is required. There would be no impacts related to this issue area.

N. PUBLIC SERVICES

1. Fire Protection
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection?
RESOLUTION 093-2020
61 Finding: Less than significant. EIR, § 4.14.5.1.)
Explanation: Under the preferred land use plan with school, the proposed project would develop 2,949 new residential units, which would generate approximately 7,974 residents. Under the land use plan without school, the proposed project would develop 3,008 residential units, which would generate approximately 8,145 residents. Using the City’s current per capita call generation factor of 100 calls per 1,000 persons, the project site is projected to add approximately 950 calls per year to the SFD’s existing call load. Under the land use plan without school, the additional population would increase the annual calculated call volume to 889 calls per year.

Due to increased demand and larger service area, response times to emergencies may exceed established response time goals. The primary standard used in the City to determine adequate levels of service is response time. The Santee General Plan (City of Santee 2003) states the goal is to provide an average maximum initial response time of no more than 6 minutes for fire, rescue and emergency medical services with an average maximum response time of no more than 10 minutes for supporting paramedic transport units 90 percent of the time. Secondary to response time is the number of personnel necessary to perform critical tasks required to safely mitigate emergencies.

According to the Fire Service Letter prepared for the proposed project, fire stations and personnel within the City are currently operating at capacity. To accommodate the increased demand and larger service area, the proposed project designates a 1.5-acre site for a new fire station and requires firefighting apparatus and trained firefighters in Fanita Commons to serve the project site and ensure adequate response times. The new station specifications regarding size, staffing, and layout would be determined through the approved Development Agreement between the applicant and the City.

The SFD has indicated it can and would serve the project site with the addition of an adequately staffed and equipped fire station. The station design would comply with City building and design standards, including City Ordinance No. 457, Article 86, Amended – Fire Protection Plan Wildland-Urban Interface Areas, in accordance with the approved Development Agreement. Either a permanent or a temporary fire station must be constructed prior to the occupancy of any residential units in the proposed project. The proposed project would provide a fully constructed and staffed permanent fire station.

In addition, a temporary fire station site equipped with apparatus and personnel may be provided on site until a permanent fire station is complete. The temporary fire station must be in an area that would RESOLUTION 093-2020
62 meet a response time maximum of no more than 6 minutes to all areas of the proposed project. The temporary fire station would be fully equipped and staffed 24 hours per day, 7 days per week. The final location for the temporary fire station would be specified in the approved Development Agreement and must be approved by the Santee Fire Chief. The applicant may choose to provide a permanent fire station in lieu of a temporary station. The Santee Fire Chief confirmed the addition of the new fire station, equipment, and staff on the project site would adequately serve the project site while maintaining current response standards. Travel time from the new permanent station to the most remote (distant) lot on the project site is calculated at 3 minutes and 26 seconds. This would allow just under 2 minutes for dispatch and turnout and would meet the Santee General Plan response time goal of no more than 6 minutes.

Fire flow pressure would be required to be a minimum of 2,500 gallons per minute for 3 hours of fire flow for single-family and multifamily residential and 3,500 gallons per minute for 4 hours of fire flow for commercial areas with fire hydrants spaced on average every 300 feet. New construction in the City requires the installation of fire sprinklers, which would further reduce the potential for fire loss on the project site. To address fire and life safety issues on new development, the City’s Fire Marshal reviews proposed residential, commercial, and industrial projects through the City’s Development Review process to ensure that adequate fire hydrant locations, water flow pressures, access for emergency vehicles, and other requirements are met, which would also reduce the need for fire protection services (City of Santee 2003).

The on-site fire station would be constructed to serve the increased development and population associated with the proposed project and would be a project component located within the boundaries of the project site. Because the proposed project would provide an onsite fire station to serve the anticipated increase in development and population, it would not require construction or expansion of additional new fire protection facilities off site. Therefore, impacts associated with the need for new or expanded fire facilities in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection would not result in a new significant impact.

2. Police Protection
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause RESOLUTION 093-2020
63 significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection?
Finding: Less than significant. (EIR, § 4.14.5.2.)
Explanation: The proposed project would generate additional population under either the preferred land use plan with school or the land use plan without school. The increase in population would increase the demand for law enforcement services, with a consequent increase in the response times to emergency and non-emergency calls. The SDCSD provided a will-serve letter that includes service ratio and response time information for law enforcement services provided to the City by the County. The ratio of officers to population in the City is approximately 2.5 full-time deputies per 1,000 residential unit, which is higher than the SDCSD goal1 of providing 1 patrol position per 10,000 residents. Based on this ratio, the addition of the proposed project would equate to a need for approximately 7.4 new officers to serve the proposed project at full buildout under the preferred land use plan with school or 7.5 officers under the land use plan without school.

The proposed project would be constructed in four phases, and the addition of approximately 7,974 residents under the preferred land use plan with school, or 8,145 residents under the land use plan without school, would be spread out over approximately 10 to 15 years until full buildout, enabling the City to contract with the SDCSD for appropriate increases in the level of service, including personnel, equipment, shifts, and person-hours committed to the City as a whole.

The Village Center land use designation in Fanita Commons allows for the development of a law enforcement satellite office for future expansion of police protection services, if deemed necessary, to accommodate these additional officers. Overall staffing would be a contractual commitment in which both the City and SDCSD would enter into and agree on personnel required for the proposed project.

As stated in the SDCSD will-serve letter for the proposed project, the provision of additional officers would not require the need for new or expanded police facilities on the project site to maintain acceptable service ratios, response times, or other performance objectives for police protection. The additional officers could be in the SDCSD’s existing facilities. Therefore, the proposed project would not result in new significant impacts associated with the provision of new or

1 The SDCSD staffing goals and facility plans are based on population instead of residential units.

RESOLUTION 093-2020
64 physically altered government facilities.

3. Schools
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of 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 schools?
Finding: Less than significant. (EIR, § 4.14.5.3.)
Explanation: According to the Santee School District (SSD), the development of 2,949 residential units under the preferred land use plan with school would generate approximately 635 K–8 students. Though SSD identifies that it has capacity to house some new students in existing schools within the district, in order to accommodate the total influx of new students, a new school facility would need to be constructed.

The proposed project reserves a school site for a potential K–8 public school or other educational uses on the project site boundaries. If acquired by the SSD, the site can accommodate up to 700 students, including existing City students and new students on the project site, plus required staff. Under this land use plan, the proposed project would provide an on-site K–8 school to serve the proposed project’s anticipated increase in population, and would not require construction or expansion of additional K–8 school facilities off site.

Additionally, according to the Grossmont Union High School District (GUHSD), the project site is within the West Hills High School attendance area, and if necessary, the GUHSD may consider a boundary adjustment to allow students living on the project site to attend Santana High School. According to the GUHSD, both of these school facilities have adequate capacity to serve students from the project site and the GUHSD does not anticipate the need to modify or expand the schools to accommodate the additional students from the proposed project. Therefore, impacts associated with the need for new or expanded school facilities in order to maintain acceptable service ratios, response times, or other performance objectives for public schools would be less than significant.

Should the SSD not acquire the on-site school site, the proposed project would allow development of an additional 59 residential units on the school site. Based on the generation rates provided by the SSD, the land use plan without school is anticipated to generate 647 students, which is only 12 more students than the SSD’s calculation of 635 students under the preferred land use plan with school.

RESOLUTION 093-2020
65 According to the SSD, the district does not have sufficient classroom space to accommodate the additional students generated by this land use plan. However, given the 10–15 year project buildout, a new or expanded school would not be needed for several years after onsite residential units begin to be occupied. The SSD uses a centralized, open enrollment system, whereby students are assigned to schools based on available space. Therefore, an interim solution for school placement of new students generated by the proposed project would be to assign them to any of the SSD’s current nine schools, depending on space availability. SSD makes every attempt to assign students to their school of residence, when requested.

However, given available space, it is not always possible to assign students to the facility closest to their residence. An additional option may include the construction of new classrooms on existing school campuses to accommodate the increase in students. If the long-term solution is an expanded or new school, the SSD would be required to comply with CEQA under separate review.

According to the GUHSD, both of the high schools that would serve the project site (West Hills High School and Santana High School) have adequate capacity to serve students from the proposed project, including the additional students generated by the development of 59 residential units in the area sited for the school. The GUHSD does not anticipate the need to modify or expand schools to accommodate additional students from the proposed project.

The applicant would be required to pay development impact fees for the proposed project’s residential and commercial development in the amount required at the time of building permit issuance. Both school districts have established school impact mitigation fees to address the facility impacts created by residential and commercial development. The districts use these fees to pay for facility expansion and upgrades needed to serve new students. These fees would be collected during the plan check process. Payment of mandatory school impact fees in accordance with SB 50 would mitigate potential impacts to school facilities from the proposed project. Impacts would be less than significant.

4. Other Public Facilities - Libraries
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of 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 libraries?
RESOLUTION 093-2020
66 Finding: Less than significant. (EIR, § 4.14.5.4.)
Explanation: The Santee branch library, which is run by the Serra Cooperative Library System in conjunction with the County of San Diego, is considered to be in a space deficit. The City’s Capital Improvement Program (CIP) Five-Year Budget (Fiscal Years 2020 through 2024) includes a project to develop a new library facility (City of Santee n.d.). The CIP project would build a new, 20,000 square foot library facility to replace the undersized space currently rented by the County of San Diego. Though a specific location is not identified at this time, as part of the CIP approval process, the City would conduct environmental review compliant with CEQA and identify mitigation measures to reduce significant impacts, as applicable. The library CIP project is currently unfunded by the City and is anticipated to occur in Fiscal Year 2023–2024. It is anticipated that the New Library Building Fund created by the Friends of Santee Library would provide some funding for the new library.

The construction of the proposed project would incrementally increase the existing library space deficit. The proposed project includes a Village Center land use designation that would allow for a mix of uses including civic uses. While a library is not precluded, a designated library site has not been identified on the project site. If a library is built on the project site in the Village Center area, the library construction and operation would be no more impactful than the other proposed commercial or public uses proposed within this land use designation.

Though the proposed project would be required to pay development impact fees (Chapter 12.30 of the Santee Municipal Code), which fund the construction of public facilities that are reasonably related to the impacts of the new development, the fees associated with Chapter 12.30 do not go toward funding the construction of libraries.

The location of a new library on site or an expanded library off site has not been identified; however, the provision of new facilities off site would be subject to separate environmental review. Therefore, the proposed project would not result in significant impacts associated with the provision of new or physically altered government facilities. Impacts would be less than significant.

O. RECREATION

1. Increased Use
Threshold: 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? RESOLUTION 093-2020
67 Finding: Less than significant. (EIR, § 4.15.5.1.)
Explanation: Parks. The proposed project would develop 2,949 residential units (under the preferred land use plan with school) or 3,008 residential units (under the land use plan without school). Implementation of the proposed project would result in an increase of approximately 7,974 persons (under the preferred land use plan with school) or 8,145 persons (under the land use plan without school) on the project site and in the City, which, as of 2019, has a current population of 58,408, bringing the estimated population in the City to 66,382 (under the preferred land use plan with school) or 66,553 (under the land use plan without school).

The City’s objective of providing 10 acres of parkland for every 1,000 residents would be satisfied through compliance with the Santee Municipal Code, Chapter 12.40, requirement to provide 5 acres of parkland per 1,000 residents of parkland dedication and the provision of “other recreation and open space areas” equal to 5 acres per 1,000 persons. The increase in population from implementation of the proposed project would require approximately 79 acres of additional parkland under the preferred land use plan with school or approximately 81 acres under the land use plan without school.

Including the proposed project’s population increase, the City would require approximately 663 acres of developed parkland Citywide under the preferred land use plan with school or approximately 665 acres under the land use plan without school to meet the Santee General Plan policy.

To meet the City’s minimum standard while adhering to the Santee Municipal Code, Chapter 12.40, the proposed project would provide new recreational amenities, including 78 acres of public and private parkland for active and passive recreation and 4.5 acres (approximately 4.8 miles) of trail land consisting of the perimeter trail and Stowe Trail connection for a total of 82.5 acres. This parkland could be accessed by the public at large and project residents. Per the public park credit provisions set forth in the Santee Municipal Code, Chapter 12.40.110, Credit for Public Parks, developed parkland dedicated to and maintained by the City would receive up to 100 percent park credit. Developed parkland maintained by a homeowners association and trail systems would receive up to 50 percent credit per the private park credit provisions in Santee Municipal Code, Chapter 12.40.100, Credit for Private Parks.

Applying these credits, approximately 52.4 acres of the total 82.5 acres of public and private parkland and trail land would be available for parkland dedication credit, which would satisfy the Santee Municipal Code parkland dedication requirement of 5 acres of parkland per 1,000 residents based on 740.5 square feet per single- RESOLUTION 093-2020
68 family unit and 675.2 square feet per multi-family unit. The proposed project would be required to provide 47.6 acres of dedicated parks and trails based on the Santee Municipal Code requirement stated above. With the provision of 52.4 acres of dedicated parks and trails, the proposed project would result in a surplus of 4.8 acres. Under the land use plan without school, the developed parkland and recreational facility dedication requirement would increase by 0.9 acre due to the addition of 59 Medium Density Residential units. This would result in a total parkland dedication requirement of 48.5 acres and would result in a surplus of 3.9 acres under the land use plan without school.

Of the 82.5 acres of parkland and trails, the largest proposed park would be the Community Park (31.2 acres) in Fanita Commons. This park would be the primary location for active and organized recreational activities on the project site. Eight Neighborhood Parks totaling 30.4 acres would be provided in key locations to define neighborhoods and provide community-gathering spaces. Thirty-one Mini-Parks totaling 16.4 acres would be designed to enhance open space areas such as vistas and riparian corridors, break up development patterns, and provide visual relief. The 1.6-acre Village Green would be a special Mini-Park that, together with the Village Center and the Farm, would establish a centralized landmark and event space for the entire community. The proposed perimeter trail and Stowe Trail connection would total approximately 4.5 acres (approximately 4.8 miles). Applying the applicable 50 percent or 100 percent park credit to these acreages, these parks and trails would provide 52.4 acres of credited parkland dedicated to the City for public use.

Furthermore, to comply with the specific ratio outlined in Santee Municipal Code, Section 12.40.070 (740.5 square feet per singlefamily unit and 675.2 square feet per multi-family unit), approximately

47.6 acres of other recreation and open space areas would be needed to meet the Santee General Plan Recreation Element Objective 1.0. To meet that requirement, the proposed project would provide 49 additional acres of parks, trails, and other recreation and open space areas, resulting in a surplus of 1.4 acres. The 49 acres includes the 4.8 acres of surplus public and private parks and trails described previously, the 27.3-acre Farm, 10.9 acres of Open Space areas with an Agriculture Overlay, and 6 acres of multi-purpose trails.

In addition, playgrounds and other recreational facilities would be provided at the reserved school site under the preferred land use plan with school should the Santee School District acquire the site and construct a school. When taken together, the 52.4 acres of dedicated parks and trails, the 49 additional acres of other recreation RESOLUTION 093-2020
69 and open space areas, and the miscellaneous playground and recreational facilities would support a broad range of active and passive recreational opportunities to serve the City’s population and proposed residents and would satisfy Objective 1.0 of the Santee General Plan Recreation Element.

The proposed project would be designed so that every residence would be within a short walking distance of a park or trail. Active sports-oriented parks, playgrounds, gardens, and seating areas with views that provide meditative space would be spread throughout the community to allow residents opportunities for outdoor recreation.

Play structures in the parks would be of non-combustible or other materials approved by the Santee Fire Department. Park designs would be consistent with the Fire Protection Plan prepared for the proposed project. In addition, an AgMeander would use the proposed trail, path, and sidewalk system and provide numerous interpretive stations and exhibits.

Under existing conditions, the City has approximately 823 acres of public parkland, or approximately 12 acres of parkland for every 1,000 residents, which exceeds Objective 1.0 in the Santee General Plan Recreation Element. Implementation of the proposed project would increase the parkland inventory for the City to approximately 13 acres of parkland for every 1,000 residents under either the preferred land use plan with school or the land use plan without school. The proposed project would add public parkland acreage to an already surplus City inventory, which would increase access to public recreational facilities for the entire community. In total, the proposed project would provide more than the minimum acreage required by the Santee General Plan Recreation Element for the proposed project’s population increase.

Trails. Trails proposed throughout the project site would provide connectivity between the villages, existing City development, and regional trails. The proposed project would provide over 35 miles of trails (23 acres), including the perimeter trail and Stowe Trail connection (approximately 4.8 miles combined), that were used to calculate compliance with the Santee Municipal Code. While not all trails would meet access requirements (particularly the existing primitive trails in the Habitat Preserve), the proposed project would comply with the Americans with Disabilities Act accessibility requirements to the extent practicable. The proposed project’s local trails would connect with the nearby existing regional trails north to Goodan Ranch/Sycamore Canyon County Preserve and south to Mission Trails Regional Park. Trail locations throughout the project site would be coordinated to minimize conflicts with sensitive habitat areas by using existing trails and dirt roads and providing signage, RESOLUTION 093-2020
70 well-defined trail markers, fencing, and community education to protect habitat areas.

The Santee General Plan Recreation Element and Objective 9.0, Policies 9.1 through 9.5, of the Trails Element discuss recreational trails in the City’s 2018 Draft Multiple Species Conservation Program Subarea Plan. As considered in the Recreation and Trails Elements, certain trails in the proposed Habitat Preserve would offer recreational benefits and may be included in the overall park and open space calculations for the proposed project.

The proposed project would provide sufficient acreage of parks, trails, and recreational facilities to satisfy the parkland dedication requirements and comply with the Santee General Plan Recreational Element Objectives 1.0 and 2.0 to provide adequate recreational facilities including trails.

The proposed project would provide a variety of new, on-site recreational amenities to occupants of the project site, thereby offsetting the need to go off site to use recreational facilities. While project residents may use existing Neighborhood and Regional Parks or other recreational facilities, they would also be expected to use the on-site recreational amenities due to convenience and variety. Therefore, substantial physical deterioration of the existing recreational facilities would not be expected to occur or be accelerated. Impacts would be less than significant.

P. TRANSPORTATION / TRAFFIC

1. Design Hazards
Threshold: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Finding: Less than significant. (EIR, § 4.16.5.3.)
Explanation: Implementation of the proposed project would establish a network of streets of varying design capacities tailored to meet the needs of the three proposed villages. The Fanita Ranch Specific Plan has developed its own street design criteria intended to address safety, aesthetics, and functionality, as well as site constraints. The streets would be designed to meet or exceed Santee Fire Department (SFD) requirements. The project would design a system of complete streets that supports multiple user types, including motorists, pedestrians, bicyclists, and transit riders. On-site streets would generally be two lanes and would include a variety of design elements, including roundabouts, split streets, landscaped medians, and parkways.

RESOLUTION 093-2020
71 A Traffic Calming Plan would be implemented throughout the proposed project in an effort to reduce traffic-related hazards by lowering vehicle speeds on neighboring streets without restricting access. The overall goals of the Traffic Calming Plan would be to improve the quality of life for residents, reduce impacts of motor vehicles on local and collector streets, create safe and attractive streets, and create a friendly environment for pedestrians and bicyclists. Several traffic calming measures would be implemented throughout the project site to assist in meeting these goals.

To relieve potentially dangerous intersections, a series of roundabouts would be incorporated throughout the proposed project to eliminate the need for left-turn and U-turn movements, controlling vehicle speed, and providing a safer environment for pedestrians.

Additional features include specialized wildlife crossing on Streets “V” and “W,” which traverse the Habitat Preserve. To create a safe corridor for automobiles, accommodate nocturnal wildlife movement, and enhance the viability of planned wildlife crossings, these streets would be marked with highly reflective pavement markers instead of standard City roadside lights. A wildlife crossing tunnel would be provided under the extension of Cuyamaca Street near the entrance to Orchard Village. It has been demonstrated that, from an animal’s perspective, the pavement markers mimic a small rock in the landscape and would not negatively impact wildlife movement.

Retroreflective pavement markers (pursuant to the California Department of Transportation specifications) would be spaced 24 feet of center on these segments. Bollard-type lighting with touchactivated sensors would be located on the pedestrian walkway that runs along these streets to enhance pedestrian safety. In addition, there would be agricultural uses on the project site primarily within the central Farm. Outside materials storage would be provided for farming equipment and machinery. A tunnel would be constructed under Street “W” to allow for the movement of agriculture equipment to and from the Farm and avoid any potential conflicts with automobile traffic.

The proposed project would improve and construct new segments of two Santee General Plan Mobility Element streets: Fanita Parkway and Cuyamaca Street. Improvements would also occur at the terminus of Carlton Hills Boulevard and at existing dead-end streets that terminate at the project site boundary. Fanita Parkway and Cuyamaca Street would be widened and include sidewalks, multipurpose trails, emergency lanes and enhanced pedestrian crossings to encourage multimodal transportation and pedestrian safety.

RESOLUTION 093-2020
72 The proposed project would include transportation design features to enhance public safety and would not result in changes to roadway design that would cause increased hazards. Therefore, impacts would be less than significant.

2. Emergency Access
Threshold: Would the Project result in inadequate emergency access? Finding: Less than significant. (EIR, § 4.16.5.4.)
Explanation: The project proposes the extension of Fanita Parkway and Cuyamaca Street to allow access to and from the project site with planned improvements on the existing segments and intersections to accommodate additional project traffic.

A Fire Protection Plan and Wildland Fire Evacuation Plan were prepared for the proposed project to address emergency access and evacuation in the case of an emergency. The proposed project would provide emergency access that meets current City requirements throughout the proposed development areas. The proposed internal looped roadways would be built to the currently adopted California Fire Code and City Ordinance 545 (Sections 503.2.1, 503.2.3) requirements and would provide travel lane widths consistent with the Fanita Ranch Specific Plan standards, adequate parking, 28-foot inside radius, grade maximums, signals at intersections, and extremely wide roadside fuel modification zones. Interior residential streets would be designed to accommodate a minimum of a 77,000- pound fire truck. All dead-end streets would meet SFD requirements.

Additionally, the streets would provide residents the option to evacuate from at least two routes that lead to existing east-west roads connecting to existing Magnolia Avenue.

The project site would have two points of primary access for emergency response and evacuation. Depending on the nature of the emergency, future residents would exit to the south on Fanita Parkway or Cuyamaca Street. Magnolia Avenue could be used during an evacuation via existing cross-streets from Cuyamaca Street, but this would be an event-specific decision. It is anticipated that the majority of the community traffic would exit the project site via Cuyamaca Street. These are the most direct routes to the project site. Both streets would include bike lanes that could be used as an additional emergency lane for first responders. These streets would provide access to major traffic corridors including directly or indirectly to SR-52 to the south, SR-67 to the east, I-8 to the south, I-125 to the south, and I-15 to the west. Fanita Parkway would be used for emergency access by the western portion of the proposed project RESOLUTION 093-2020
73 development. The planned extension and improvements to Fanita Parkway and Cuyamaca Street would be sized to provide adequate access for fire equipment and personnel. The proposed project would not result in inadequate emergency access. Therefore, impacts would be less than significant.

Q. UTILITIES AND SERVICE SYSTEMS

1. Water Supplies
Threshold: Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Finding: Less than significant. (EIR, § 4.17.5.2.)
Explanation: Proposed project water demand was calculated based on land use type, number of residential units, the Santee Municipal Code, and the PDMWD-defined unit demand factors. The calculation also took into account the effects of climate change on water supply, including the rising sea levels and changes in weather events. For water demand per residential land use area, the residential units are multiplied by a per capita water-use factor of 100 gallons per capita per day obtained from PDMWD’s 2015 Comprehensive Facilities Master Plan and multiplied by the estimated number of persons per residential unit as defined in the Santee Municipal Code. Commercial and irrigation water demands are calculated per WAS design criteria based on land area type. The total projected water demand for the entire project site is 1.44 mgd, or 1,618 acre-feet per year (AFY).

PDMWD’s 2015 Urban Water Management Plan (UWMP) accounts for 840 AFY of demand associated with the proposed project. Thus, the WSA prepared for the project evaluated the additional demand of 778 AFY associated with the proposed project that was not previously accounted for.

Supply shortfalls are projected in the single and multiple dry year scenarios. PDMWD can address the shortfalls identified here and in its 2015 UWMP through the implementation of conservation measures identified in Section 8 of its 2015 UWMP, Water Shortage Contingency Planning (Appendix O3). The San Diego County Water Authority (SDCWA) 2015 UWMP has identified no shortages in a single dry year until 2035 and no shortages in multiple dry years until 2028, provided carryover storage supplies are utilized in both instances. Carryover storage currently totals 170,000 AFY. SDCWA maintains that single and multiple dry year shortages can be mitigated through extraordinary water conservation actions and dry year transfers, which the SDCWA successfully acquired and used RESOLUTION 093-2020
74 during the 2007–2011 shortage period (SDCWA 2015 UWMP Section 9.3.) Further, the shortfalls identified in the SDCWA’s 2015 UWMP would be mitigated by the interim demand forecast reduction of approximately 60,000 AFY for the 2020 to 2040 planning horizon identified in the 2018 SDCWA Annual Report based on water-use efficiency increase projections throughout the region and with the increased output at the Carlsbad Desalination Plant in comparison with the SDCWA’s 2015 UWMP. Similarly, PDMWD can address the shortfalls identified in its 2015 UWMP through the implementation of conservation measures identified in Section 8 of its 2015 UWMP, Water Shortage Contingency Planning.

The proposed project’s projected demand is 1,618 AFY. PDMWD’s projected total water demand for 2040 is 16,816 AFY (14,800 AFY potable and 2,016 AFY recycled) or 15 mgd. According to PDMWD’s 2015 Comprehensive Facilities Master Plan and Program
Environmental Impact Report, which were approved by the PDMWD Board in May 2017, only 0.75 mgd or 840 AFY of proposed project demand is accounted for in the 2040 projections for PDMWD because it was based on the previously proposed project from 2007.

Therefore, the 2015 UWMP only accounts for 56 percent of the proposed project’s calculated demand. The proposed project’s accounted for demand of 840 AFY is 5 percent of PDMWD’s total potable demand for the year 2040. The proposed project’s total demand of 1,618 AFY would be about 9.6 percent of PDMWD’s 2040 adjusted potable water demand of 15,578 AFY (14,800 AFY + 778 AFY [unaccounted for demand by the proposed project]).

Since PDMWD’s 2015 UWMP only accounts for 840 AFY of the proposed project’s total projected demand of 1,618 AFY over the 20- year planning horizon, the WSA evaluates and concludes that the additional required 778 AFY can be accommodated by additional imported water from the SDCWA. The SDCWA has confirmed in a response letter that it can meet the additional 778 AFY demand associated with the proposed project through the use of its accelerated forecast growth (AFG) component of its 2015 UWMP.

The AFG is incorporated into the SDCWA’s demand forecast at a regional level and is available to all member agencies to meet additional demand increments not previously identified. The demand associated with the AFG component is included in the SDCWA’s regional total demand forecast and is intended to account for a portion of SANDAG’s estimated residential land use development that is currently projected to occur beyond the SDCWA’s 2040 planning horizon but that has the potential to move forward on an accelerated schedule. This AFG demand was incorporated by the SDCWA at a regional level for planning purposes and is not portioned out by member agencies. This allows for an additional RESOLUTION 093-2020
75 4,807 AFY beginning in 2025, a portion of which (778 AFY) has been allocated by SDCWA to PDMWD for the proposed project.

In addition, the proposed project would implement water-efficient irrigation, landscaping, appliances, and fixtures to further reduce water demand. Landscape plans would be required to ensure compliance with applicable requirements, and the applicant would be required to plan and install water-efficient devices and landscaping in accordance with applicable PDMWD development guidelines and standards, ordinances, and requirements.

PDMWD is also planning and developing a regional drought-proof water supply known as the East County Advanced Water Purification (ECAWP) Project, which would decrease PDMWD’s reliance on imported water supplies and improve water supply reliability. The ECAWP Project, which is currently in the project procurement and permitting phase, is anticipated to treat the combined 2025 wastewater flow of approximately 15 million gallons per day (MGD) and produce up to 12,880 acre-feet per year (AFY), or 11.5 MGD, of new, reliable, and locally controlled potable water supply which represents approximately 30% of East County San Diego’s water demand. If the ECAWP Project is implemented, based on this projected time frame, the proposed project would utilize purified water from the ECAWP Project within the 20-year water supply planning horizon and beyond. The ECAWP Project is not necessary for PDMWD to meet the demand associated with the proposed project, however. But it could provide an additional supply source for further water supply security to the proposed project and other PDMWD customers if it is implemented. Further, PDMWD plans to reduce its dependence on imported supplies from the SDCWA by continuing permanent water conservation efforts.

The effects of climate change drastically alter the overall planning required for the conservation and distribution of Metropolitan’s water supply. Accounting for the effects of climate change is a challenging task because the events that can occur are unpredictable. However, previous hydraulic studies produced by Metropolitan have provided a strong basis for the prediction of future events. According to Metropolitan’s UWMP, the predicted impacts of global climate change that could affect Metropolitan’s water supply include, but are not limited to: (1) reduction in the average annual snowpack; (2) changes in the timing, intensity, and location of weather events; (3) rising sea levels; (4) decrease in local sources such as groundwater; (5) increase in urban and agricultural water demand; (6) degrading water source; (7) declines in ecosystem viability; and (8) changes to pumping and power operations.

RESOLUTION 093-2020
76 To prevent further greenhouse gases emissions, Metropolitan has implemented steps to reduce the carbon footprint of its facilities, including the addition of hydroelectric power plants that create energy from the water flowing through pipelines, and implementation of solar power technologies to its facilities. Metropolitan not only audits its own energy usage but also voluntarily reports its greenhouse gas emissions to California’s Climate Registry.

Metropolitan has taken steps to offset the effects of climate change on water supply. To reduce the water impacts due to climate change, Metropolitan has developed and implemented drought response action items. According to “Current Conditions” section of the Metropolitan 2015 UWMP, Metropolitan’s drought response actions include providing incentives for on-site recycled water hook ups; augmenting water supplies with water transfers and exchange; improving storage programs; upgrading its distribution system to enhance CRA water delivery; and implementing the Water Supply Allocation Plan to distribute the limited imported supplies and preserve storage reserves.

The conservation method allows for a reduction in energy that normally would have been used by exporting water instead of storing it. With the use of gravitational distribution for recycled water, less electricity is required to generate energy needed to distribute pressurized water. Efforts to implement water conservation include recycling and reusing sea water and wastewater as a reliable source of potable water. Applying such measures reduces the amount of water imported from the SWP and the Colorado River.

Likewise, SDCWA has developed strategies to manage the supply uncertainties associated with a changing climate. This includes the foundational strategy to diversify the region’s resource mix through development of local projects, such as recycled water and seawater desalination and reduce reliance on imported and local surface supplies whose yields could potentially decrease as a result of climate change (see Tables 10-3 and 10-4 of the SDCWA 2015 UWMP). SDCWA uses tracking metrics to monitor the progress on implementation of its water resource mix, which are then used in updates to its UWMP every 5 years.

Therefore, based on PDMWD’s projected supplies, combined with additional confirmed supplies from the SDCWA AFG, water supplies are sufficiently available to meet the proposed project’s demand in normal, single dry, and multiple dry years, provided that the water shortage contingency planning measures identified in PDMWD’s 2015 UWMP and the SDCWA’s 2015 UWMP are implemented in dry years. In addition, efforts underway by Metropolitan, SDCWA, and RESOLUTION 093-2020
77 PDMWD to diversify and augment their supplies provide further assurance of the sufficiency of the water supply for the proposed project. Therefore, the proposed project would have a less than significant impact on water supply availability.

2. Wastewater Capacity
Threshold: Would the Project 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?
Finding: Less than significant. (EIR, § 4.17.5.3.)
Explanation: The proposed project would construct new public sewer infrastructure that would be owned, operated, and maintained by PDMWD. Sewage generated on the project site would be treated at the existing Ray Stoyer WRF or at the new WRF to be constructed as part of the ECAWP Project. In instances where the WRF is offline for maintenance, capital improvement, etc., sewage generated on the project site would be diverted to the City of San Diego’s Metropolitan Sewerage System. PDMWD’s existing Ray Stoyer WRF does not have adequate capacity alone to serve the sewer demand generated by the proposed project. A combination of the WRF and the available capacity in the San Diego Metropolitan Sewerage System (Metro) would provide sufficient capacity to serve the proposed project.

The Sewer Service Study prepared for the proposed project used flow generation rates developed in PDMWD’s 2015 Comprehensive Facilities Master Plan. The study analyzed average dry weather flow (ADWF), peak dry weather flow (PDWF), and peak wet weather flow (PWWF) scenarios. The average daily flow was analyzed for the proposed project under both the preferred land use plan with school and the land use plan without school. Based on the analysis performed, the school site would produce an ADWF of 15,000 GPD while the alternative residential use would generate an ADWF of just under 11,000 GPD. Therefore, the preferred land use plan with school is used because it would generate a higher ADWF and thus represents a worst-case scenario based on PDMWD’s 2015
Comprehensive Facilities Master Plan consumption criteria. The proposed project would generate approximately 591,158 GPD of wastewater. This equates to approximately 662 AFY.

According to the 2015 UWMP, PDMWD’s wastewater collection system consists of sewer mains, lift stations, and flow diversion structures. Almost all of the collected wastewater flows to the RESOLUTION 093-2020
78 PDMWD’s influent pump station. Up to 2,240 AFY of wastewater is pumped to the PDMWD WRF and 2,175 AFY is pumped to the Metro system where it receives advanced primary treatment at the Point Loma Wastewater Treatment Plant. In total, PDMWD can collect approximately 4,426 AFY, or 3,951,277 GPD. However, the PDMWD’s Ray Stoyer WRF was analyzed for adequate treatment capacity for the proposed project, which can treat up to 2,240 AFY.

According to PDMWD’s 2015 UWMP, the Ray Stoyer WRF treated approximately 2,175 AFY in 2015.

The proposed project would generate approximately 662 AFY, or 591,158 GPD ADWF. In addition, PDMWD’s 2015 Comprehensive Facilities Master Plan has already included 1,380 residential units on the project site consistent with the Santee General Plan as part of the ADWF future projections. Therefore, a portion of the proposed project’s sewer demand totaling approximately 392 AFY has already been planned for by PDMWD. Further, there are plans to expand the existing PDMWD influent pump station and Ray Stoyer WRF through the ECAWP Program. This program would increase the capacity of the wastewater system to approximately 6,725 AFY by 2040, consistent with buildout of the proposed project. However, the remaining sewer demand of approximately 270 AFY from the proposed project would be capable of being treated by PDMWD facilities with or without this expansion. Thus, PDMWD has sufficient existing or planned capacity to receive and treat wastewater from the project site. The proposed project would have a less than significant impact on wastewater treatment capacity.

3. Solid Waste
Threshold: Would the Project 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? Finding: Less than significant. EIR, § 4.17.5.4.)
Explanation: Construction activities including clearing, grubbing, grading, and building would occur and produce green waste, scraps, and other debris typical of construction. Operation of the proposed project would require services to pick up solid waste generated by the proposed land uses on the project site.

Residential and commercial trash hauling and industrial solid waste, green waste, and recycling collection and disposal services for the proposed project would be provided by Waste Management, Inc., under a contractual franchise agreement with the City. Waste Management, Inc., would provide trash, recycling, and yard waste RESOLUTION 093-2020
79 pickup services on a weekly basis for residential customers and up to seven times per week for business customers. Waste
Management Inc., identified in the solid waste service letter that they are capable of adequately serving the proposed project and would not need to provide additional services or expand existing facilities to do so.

Solid waste from the proposed project that is not recycled or diverted would be hauled to Sycamore Landfill, a 349-acre site at 8514 Mast Boulevard approximately 1.7 miles southwest of the project site.

Sycamore Landfill is fully permitted as a Class III landfill and accepts only routine household and commercial waste; thus, hazardous wastes are not collected. According to the Solid Waste Information System database maintained by CalRecycle, the landfill’s maximum permitted capacity is approximately 147,908,000 cubic yards with a current remaining capacity of approximately 113,972,637 cubic yards as of 2016. Based on the remaining capacity and disposal rates, the Sycamore Landfill is expected to close December 31, 2042 (CalRecycle 2019).

Based on CalRecycle’s 2017 waste disposal rate of approximately

6.2 pounds per day per resident and recycling rate of 42 percent, the residential portion of the proposed project would dispose of approximately 28,675 pounds per day of waste (7,974 residents x

6.2 pounds per day – 42 percent) under the preferred land use plan with school and 28,289 pounds per day (8,145 residents x 6.2 pounds per day – 42 percent) under the land use plan without school.

Based on CalRecycle’s employee disposal rate of 11.9 pounds per employee per day and an employee recycling rate of 62 percent, the commercial portion of the proposed project would generate approximately 2,035 pounds per day (450 employees x 11.9 pounds per day – 62 percent) under the preferred land use plan with school and approximately 904 pounds per day (200 employees x 11.9 pounds per day – 62 percent) under the land use plan without school.

The total waste generated for the proposed project would be approximately 30,710 pounds of municipal solid waste per day under the preferred land use plan with school and approximately 29,193 pounds of municipal solid waste per day under the land use plan without school. Converting Sycamore Landfill’s remaining capacity to pounds, it has approximately 192 billion pound capacity as of 2016.

Thus, the landfill has adequate capacity to serve the proposed project. In addition, waste diversion rates are expected to continuously increase as more waste is diverted from the landfills as mandated by AB 1826 and SB 939. Therefore, the proposed project would not generate solid waste in excess of state or local standards or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals and impacts would be RESOLUTION 093-2020
80 less than significant.

4. Solid Waste Laws
Threshold: Will the Project comply with federal, state, and local statutes and regulations related to solid waste?
Finding: Less than significant. (EIR, § 4.17.5.5.)
Explanation: Development of the proposed project would result in an increase in domestic municipal solid waste generation. Solid waste generated by the proposed project would be hauled away by Waste
Management, Inc., to Sycamore Landfill in the City of San Diego. As California laws get more stringent, the amount of waste sent and managed at Sycamore Landfill would be expected to decrease.

Waste Management, Inc., is required to implement measures to divert 65 percent of waste generated during construction/demolition activities. Santee Municipal Code, Section 9.04.080, also requires that any covered project submit a completed C&D debris
management plan that identifies waste materials expected to be generated by the proposed project at the time of demolition or building permit application.

Standard solid waste practices identified in AB 939 and AB 1826 would be implemented throughout operation of the proposed project.

Example measures include waste characterization, source reduction, recycling, composting, education and public information, special waste, household hazardous waste, and programs for organic waste. Waste and recycling for project construction and operation would comply with CALGreen and current regulations, such as SB 1374, designed to divert waste from landfills. Effective January 1, 2017, all jurisdictions are required to divert 65 percent of construction waste. The proposed project would also comply with the City’s Construction and Demolition Debris Recycling Ordinance (Santee Municipal Code, Chapter 9.04) requiring the diversion of 65 percent of construction waste as required under AB 939.

Non-residential development and attached residential development in the proposed project would comply with the trash enclosure requirements. Detached residential development and attached residential development where private garages are attached to individual units would participate in the residential curbside pickup program managed by Waste Management, Inc. Solid waste
containers for these units, which would be stored in private side or rear yards or in garages, would be picked up from the street curbside or alley edge on collection days. In addition, the proposed project would be required to institute recycling services to divert at least 90 RESOLUTION 093-2020
81 percent of the waste generated and 70 percent of non-hazardous construction waste, and provide recycling and composting services (Mitigation Measure GHG-2), which includes providing recycling containers within multi-family residential communities and nonresidential buildings and providing composting containers and compost collection services within commercial and office facilities.

Proposed development on the project site would involve the reuse of on-site rock materials, such as large boulders, rock cobble, decomposed granite, and processed rock. There are large quantities of rock cobble existing on site. Rock cobble would be collected and used in the construction of water quality and landscape features. It is also anticipated that a temporary aggregate processing operation would be set up on site during construction. The aggregate processing plant would produce roadway sub-base and other aggregate materials for use on site. In addition to rock materials, there are large deposits of decomposed granite on site, which would be reused for trails and other landscape-related purposes. Use of onsite materials would eliminate the need for importing and exporting rough or finished materials, reducing the number of solid waste disposal truck trips and associated construction-related vehicle emissions in support of the Sustainable Santee Plan (2020).

The design of residences on the project site would be constructed of durable materials and simple design to minimize materials waste.

The Architectural Design Guidelines for the proposed project include recommendations for efficient residence designs that can potentially reduce the amount of lumber and other building materials needed.

Strategies include simple massing forms and efficient framing techniques, use of rapidly renewable resources, and installation of durable material that require less frequent replacement. Therefore, the proposed project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste. Impacts would be less than significant.

R. WILDFIRE

1. Response Plans
Threshold: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially impair an adopted emergency response plan or emergency
evacuation plan?
Finding: Less than significant. (EIR, § 4.18.5.1.)
RESOLUTION 093-2020
82 Explanation: According to the SFD, the proposed project would not interfere with the City’s adopted Emergency Operations Plan (2010) or the Unified San Diego County Emergency Services Organization and County Operational Area Emergency Operations Plan – Evacuation Annex (2018). As required by the SFD, the proposed project would provide new evacuation and emergency responses plans, including fire protection plan (FPP), Construction Fire Prevention Plan (CFPP), and Wildland Fire Evacuation Plan. The FPP addresses fire safety, prevention, and protection for the proposed project and provides measures for fire protection that would either meet or exceed the Santee Municipal Code and Ordinance 570. The CFPP provides standard protocols and approaches for reducing the potential for ignitions for typical construction site activities during proposed project construction. The Wildland Fire Evacuation Plan created for the proposed project was based on the City’s Emergency Operations Plan. The goal of the City’s Emergency Operations Plan is to incorporate and coordinate City facilities and personnel into an efficient organization capable of responding to any emergency.

The primary streets that would be used for evacuation from the project site are Fanita Parkway and Cuyamaca Street. These streets would provide access to major traffic corridors including directly or indirectly to State Route (SR-) 52 to the south, SR-67 to the east, Interstate (I-) 8 to the south, I-125 to the south, and I-15 to the west.

During an emergency evacuation from the project site, the primary and secondary roadways would be capable of providing resident egress while responding emergency vehicles are traveling inbound.

In addition, bicycle lanes would be provided in both directions that can act as emergency lanes for first responders and evacuation lanes for project occupants. Because the roadways are designed to meet or exceed the 2019 California Fire Code requirements, including unobstructed travel lanes consistent with the Fanita Ranch Specific Plan standards, adequate parking, 28-foot inside radius, grade maximums, signals at intersections, and extremely wide roadside fuel modification zones, potential conflicts that could reduce roadway efficiency would be minimized, allowing for smooth evacuations. Additionally, the streets would provide residents the option to evacuate from at least two routes that lead to three main arteries (including potentially Magnolia Avenue via existing crossstreets from Cuyamaca Street). Depending on the nature of the emergency, residents can exit south on Fanita Parkway or Cuyamaca Street. The available evacuation routes (Fanita Parkway and Cuyamaca Street) would meet the 2019 California Fire Code, Appendix D, and the Santee Municipal Code and Ordinance 570 requirement for multiple access points.

The internal roadways from the residences to existing and planned RESOLUTION 093-2020
83 off-site travel routes would be fuel modified passageways. Portions of the proposed project’s access roads would traverse through areas with natural vegetation that are considered wildland fuels. The proposed project would provide a minimum of 50 feet of modified fuel areas along both sides of each street to provide a buffer that would reduce ignitions from vehicle-related causes (e.g., catalytic converter, brake-related, broken chains, tossed cigarette) and provide a setback from wildland fuels. In emergencies where it is determined to be safer to remain on site, sheltering on the project site’s defensible residences and village buildings would be possible if evacuation was considered less safe.

The FPP and Wildland Fire Evacuation Plan developed for the proposed project provide measures for meeting City and County evacuation requirements. Therefore, the proposed project would not significantly impair an adopted emergency response plan or emergency evacuation plan and impacts would be less than significant.

2. Pollutant Concentrations
Threshold: Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of wildfire?
Finding: Less than significant. (EIR, § 4.18.5.2.)
Explanation: Construction. The proposed project is located within a Very High Fire Hazard Severity Zone (VHFHSZ) and heat or sparks from
construction equipment, vehicles, and the use of flammable hazardous materials have the potential to ignite adjacent vegetation and start a fire, especially during weather events that include low humidity and high wind speeds. The proposed project would implement the Construction Fire Protection Plan (CFPP) that has been prepared in compliance with the requirements of the Santee Municipal Code and Ordinance 570, the 2019 California Fire and Building Codes, and the County’s 2010 FPP Guidelines for Determining Significance. The potential risk of wildfire ignition and spread associated with construction of the proposed project can be managed so that the potential for vegetation ignition is substantially reduced. In addition, pre-planning and construction personnel training for fire awareness, reporting, and suppression not only results in lower probability of ignition but also in higher probability of fire control and extinguishment in its early stages. Data indicate that 95 percent of all wildfire ignitions are controlled during initial attack (Smalley 2008).

RESOLUTION 093-2020
84 Additionally, the proposed project would use construction measures as identified in the CFPP to avoid construction-related wildfire impacts. These measures include having adequate water available to service construction activities, implementing a CFPP, providing proper wildfire awareness, reporting, and suppression training to construction personnel, and requiring that all construction-phase components of the fuel modification are complete prior to delivery of combustible materials/lumber to the project site. Therefore, the proposed project would not exacerbate wildfire risks or expose project occupants to pollutant concentrations from a wildfire or uncontrolled spread of wildfire during construction, and impacts would be less than significant.

Operation. The proposed project would implement the FPP that has been prepared in compliance with the requirements of the Santee Municipal Code and Ordinance 570, the 2019 California Fire and Building Codes, and the County’s 2010 FPP Guidelines for Determining Significance. Slopes at the project site and in the region are variable, but do include steep topography that can facilitate fire spread. Conversely, prevailing winds, which are from the west and southwest and typically include higher humidity and lower wind speeds, would not tend to facilitate aggressive fire spread. However, the occurrence of the Santa Ana winds, which are dry and much higher velocity, could facilitate fire spread. The project’s FPP contemplated these conditions and designed fire protection features that are site specific and focused on protecting the project’s buildings and residents while simultaneously minimizing the likelihood for onsite fire to burn off site into open space.

The proposed project would include a variety of fire protection features that form a redundant system of protection to minimize the likelihood of wildfire exposing people or structures to a significant risk of loss, injury, or death involving wildland fires. The proposed project would provide a fire hardened landscape, ignition-resistant residences and other buildings, and conversion of fuels to maintained developed areas with designated review of all landscaping and fuel modification areas and highly ignition-resistant structures. The project site would implement the Wildland Fire Evacuation Plan compliant with City and County requirements, and if evacuation is not considered the preferred approach, such as during a short-notice evacuation, the proposed project offers a contingency option of temporarily sheltering on site.

Ignition-Resistant Structures. The Santee City Council adopted a wildland-urban interface (WUI) development standard in November 2004 and then amended the Fire Code with adoption in June 2006.

RESOLUTION 093-2020
85 Measures were also adopted into the 2007 California Building Code and have been retained and enhanced in code updates since then, including the 2019 California Building and Fire Codes. The following project features are required for new development in WUI areas and form the basis of the system of protection necessary to minimize structural ignitions and facilitate access by emergency responders as identified in the FPP (Appendix P1): Application of the latest adopted ignition-resistant building codes; Non-combustible or ignition-resistant exterior wall coverings; Multi-pane glazing with a minimum of one tempered pane; Ember resistant vents; Interior, automatic fire sprinklers for all structures; Modern infrastructure, access roads, and water delivery system; Maintained fuel modification areas; and Fire apparatus access roads throughout the proposed project.

Effective Fuel Modification Zones. The proposed fuel modification zones (FMZs) are designed to minimize wildfire encroaching upon the community and minimize the likelihood that an on-site ignition would spread into the Habitat Preserve areas. The proposed FMZs would provide separation from the unmaintained vegetation occurring outside the FMZs. The FMZs would include low-fuel, maintained vegetation, including 65 feet of irrigated zone, resulting in high vegetation moisture, which is ignition resistant. The FMZs would provide a buffer of reduced fuel densities, lack of fuel continuity, and a reduction in the receptiveness of the landscape to ignition and fire spread.