Cities Index.
Agenda packet

Santee City Council
October 12, 2022

Document
Agenda packet
Meeting
October 12, 2022
Body
Santee City Council
Pages
211
Original file
14.8 MB
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project would add density in locations proximate to transit, providing consistency with City policies. Furthermore, all future site-specific projects would be reviewed to ensure conflict with transit facilities. All development (discretionary and ministerial) would be subject to implementation of the City’s Public Works Standards which includes general design criteria related to circulation and parking.

The required engineering and Mobility Element consistency review, along with application of the objective design and performance standards for ministerial projects, associated with development at Rezone Sites would avoid conflicts with applicable plans or policies related to transit, roadway, bicycle, and pedestrian facilities.

Therefore, the project would not conflict with a plan, ordinance, or policy addressing transit, roadway, bicycle, and pedestrian facilities and impacts would be less than significant.

2. 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. (Draft PEIR, p. 4.13-18) Explanation: The project does not propose any changes to the existing roadway network. Future site-specific development may require
improvements to the existing roadway network. These improvements would be subject to an engineering review to ensure roads and access are configured consistent with established roadway design standards. While potential future ministerial development projects would not require a subsequent environmental review, these projects would be subject to a ministerial review that would include consistency with the City’s Public Works Standards. The Engineering Division review would ensure individual projects do not create hazards and are designed consistent with established standards.

Additionally, all future development would be subject to policies set forth in the Mobility Element of the General Plan. Implementation of Policy 3.1 (Streets and Freeway System) states the City to encourage the development of improved signalization and intersection design while taking into consideration the safety of all modes. In addition, Policy 3.1 (Streets and Freeway System) states the City should encourage the utilization of traffic control devices, such as center medians and/or left-turn pockets where appropriate and that do not conflict with safety and discourage the installation of median cute where traffic safety cannot be assured. Therefore, implementation of the existing regulatory framework would ensure Findings

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future development would not result in hazards due to a design feature. Impacts would be less than significant.

3. Emergency Access
Threshold: Would the Project result in inadequate emergency access? Finding: Less than significant. (Draft PEIR, p. 4.13-19) Explanation: The project does not propose any changes to the existing roadway network. Access for future site-specific development to the existing roadway network would be configured consistent with established roadway design standards that would allow for emergency access.

The City implements the Santee Emergency Operations Plan to ensure adequate emergency access within the City. Additionally, the City implements its Mobility Element Policy Objective 1.0, which ensures that the existing and future transportation system is accessible, safe, reliable, efficient, integrated, convenient, well‐ connected, and multimodal. The system will accommodate active transportation, and accommodate people of all ages and abilities, including pedestrians, disabled, bicyclists, users of mass transit, motorists, emergency responders, freight providers and adjacent land uses. In addition, Policy 3.3 states the City shall ensure that newly constructed roadways are designed to permit rapid access for emergency vehicles. To support implementation of the Mobility Element for ministerial projects, the project also includes adoption of objective design and performance standards that would be implemented during the review process for future ministerial development. The standards include a requirement that project applicants shall make roadway improvements along the project frontage including adjoining intersections in accordance with the Mobility Element. Therefore, the project would not result in inadequate emergency access, and impacts would be less than significant.

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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. (Draft PEIR, pp. 4.14-18 through 4.14.-19) Explanation: Water use within the PDMWD service area is projected to be 12,442 AFY in 2025 increasing to 15,944 AFY in 2045. Residential demands account for 7,438 AFY (or 60 percent) of the total projected 2025 demand and 10,070 AFY (or 63 percent) of the total projected 2045 demand. The estimate is based on SANDAG demographic estimates included in the PDWMD UWMP (PDMWD 2020) which included the anticipated increase in population from 92,434 in 2020 to 117,701 by the year 2045. The project would add an additional 1,209 multi-family housing units compared to what would be allowed under the City’s existing General Plan/Zoning. The increase in population associated with the project would be consistent with the anticipated population increase analyzed in the PDMWD UWMP. Water supplies are projected to exceed the needs of the PDMWD service area and would adequately cover the demands of the project. Specific projected demands related to normal, dry and multiple dry years are discussed in the PDMWD UWMP (2020). With continued
conservation, the use of recycled water, and the addition of added supply with the upcoming AWP Project, supplies are projected to meet demands through year 2045 under average year, single-dry year, and for a five-consecutive-year drought conditions.

The project does not propose the construction of new housing or other development; rather it provides capacity for future development consistent with the proposed rezones. Buildout potential within the Rezone Sites could result in the construction of up to 1,945 residential dwelling units that have not all been specifically accounted for within the latest PDMWD planning documents.

UWMPs are required to be updated on a five-year cycle and the next update to the PDMWD UWMP is anticipated by 2025. Future UWMP updates would account for the anticipated water use associated with future development consistent with any adopted rezones. While the proposed rezones would add development potential within the City, the increase water demand would be covered in the water district’s projected water supplies. Additionally, it is noted that higher density residential development is more water efficient than single-family residential.

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Existing regulations would ensure water-efficient fixtures are installed with new development. The California Green Building Standards Code requires 20 percent reduction in indoor water use relative to specified baseline levels. Santee Municipal Code Section

13.10.040 provides minimum standards for residential development and requires that all appliances and fixtures shall be energy conserving (e.g., reduced consumption showerheads, water conserving toilets, etc.). The requirements for the energy efficiency of buildings are set forth in the current California Energy Code for Climate Zone 10 in which the City is located. Additionally, all new residential units, including accessory dwelling units, shall meet or exceed California Green Building Standards Tier 2 Voluntary Measures.

Additionally, all future projects would be required to adhere to the following ongoing water conservation measures mandated by the PDMWD as authorized by Water Code sections 375 et seq.:
• Stop washing down paved surfaces, including but not limited to sidewalks, driveways, parking lots, tennis courts, or patios, except when it is necessary to alleviate safety or sanitation hazards.
• Stop water waste resulting from inefficient landscape irrigation, such as runoff, low head drainage, or overspray, etc. Similarly, stop water flows onto non-targeted areas, such as adjacent property, non-irrigated areas, hardscapes, roadways, or structures. Irrigation runoff is prohibited. • Irrigate residential and commercial landscape before 10 a.m. and after 6 p.m. only.
• Do not irrigate while it is raining and within 48 hours after it rains.
• Use a hand-held hose equipped with a positive shut-off nozzle or bucket to water landscaped areas, including trees and shrubs located on residential and commercial properties that are not irrigated by a landscape irrigation system. • Use recirculated or recycled water to operate ornamental fountains, ponds, and similar decorative water features. • Wash vehicles using a bucket and a hand-held hose with positive shut-off nozzle, mobile high pressure/low volume wash system, or at a commercial site that re-circulates (reclaims) water on-site. Boats and boat engines may be washed down immediately after use using a bucket or handheld hose with positive shut-off nozzle. Runoff is prohibited.

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• Repair all water leaks within five days of notification by Padre Dam unless other arrangements are made with the
CEO/General Manager. Severe water leaks must be stopped immediately.
• Use recycled or non-potable water for construction
purposes, such as dust control and soil compaction, when available and required by Padre Dam (PDMWD 2020).

Based on the PDMWD estimated water supply, water efficiency of multi-family development, water conservation requirements, along with existing regulations that require new construction to be water efficient, it is not anticipated that the project would affect the ability of PDMWD to plan for adequate water supplies within the City during normal, dry, and multiple dry years.

Future residential projects anticipated in the Rezone Sites would be required to adhere to state and local water conservation and efficiency measures. Based on the water efficiency of multi-family development and existing regulations that require new construction to be water efficient, future development consistent with the proposed rezones would affect the ability of PDMWD to plan for adequate water supplies within the City during normal, dry, and multiple dry years. Impacts would be less than significant.

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. (Draft PEIR, pp. 4.14-20 through 4.14-21) Explanation: Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing wastewater infrastructure, including pipelines to the PDMWD WWTP and WRF.

Although future development within the Rezone Sites would require connection to existing wastewater infrastructure within surrounding roadways and result in additional wastewater generation, the PDMWD is currently implementing plans to expand the Ray Stoyer Reclamation Facility, which would allow for treatment of wastewater for potable use that would otherwise be discharged to the ocean.

Thus, additional capacity improvements would not be anticipated with the project as wastewater flows would ultimately be managed as a potable resource or a recycled water resource. Furthermore, as Findings

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discussed in response to Issue 2, higher density residential development would generally be more water efficient that lower density residential and all new development would be subject to water conservation requirements that would help to minimize wastewater flows. All future project applications, whether discretionary or ministerial would be required to adhere to the City’s Municipal Code which requires the assurance of adequate water facilities through payment of development impact fees for the constructing public facilities, which are reasonably related to the impacts of the new development (SMC Chapter 12.30). Additionally, future projects would be required to comply with General Plan policies including Land Use Element Policy 3.6, which requires the review of development projects to ensure that all necessary utilities are available to serve the project.

Future development at the Rezone Sites is located within existing developed areas with access to utility infrastructure. No development is proposed as part of the project; however, it is anticipated that future projects would generate wastewater that would add to the providers existing commitments. Based on the PDMWD existing facility capacity and expansion plans for the Ray Stoyer WRF in addition to the water efficiency of multi-family residential development, the project would not result in a determination by the wastewater treatment provider that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. All projects whether discretionary or ministerial would be reviewed for conformance with local regulations and adherence to General Plan policies. Therefore, through regulatory conformance, impacts associated with the adequacy of infrastructure and capacity related to wastewater services would be less than significant.

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. (Draft PEIR, pp. 4.14-21 through 4.14-22) Explanation: Although waste generation associated with multi-family development is generally less than single-family homes, future development within the Rezone Sites would increase solid waste generation throughout the City due to the increase in the number of overall residential units that would be allowed with the proposed rezones. CalRecycle (2019) defines multi-family development as having a waste generation rate Findings

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of 4 pounds/dwelling unit/day. The project would add an additional 1,209 multi-family housing units compared to what would be allowed under the City’s existing General Plan/Zoning. The addition of 1,209 multi-family housing units would increase solid waste generation by 4,836 pounds per day. As detailed above, the Sycamore Landfill is expected to remain open until December 31, 2042 with current remaining capacity of approximately 113,972,637 cubic yards as of December 31, 2016. Future projects, whether discretionary or ministerial, would be required to adhere to state and local regulations relating to solid waste and recycling. Specifically, the City is required to meet solid waste diversion goals set forth in the California Integrated Waste Management Act which would decrease waste delivered to the landfill. Additional measures for the reduction of solid waste includes goals set by the state to reduce organic waste disposed of in landfills. The City would require future development to contract with available solid waste service providers that would provide the required solid waste disposal, including recycling and organic material recycling to meet exiting State and local requirements. Future projects would also be required to comply with General Plan Safety Element Policy 3.8 which promotes the safe, environmentally sound means of solid waste disposal for the community.

Future development at the Rezone Sites is located within existing developed areas with access to solid waste disposal services. No development is proposed as part of the project; however, it is anticipated that future projects would result in an increased in solid waste generation. Solid waste requirements associated with the future development of the Rezone Sites would be evaluated upon submittal of project specific development plans. All projects whether discretionary or ministerial would be reviewed for conformance with state and local regulations and adherence to General Plan policies.

Therefore, through regulatory conformance, impacts associated with the solid waste disposal and capacity would be 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. (Draft PEIR, pp. 4.14-21 through 4.14-22) Explanation: Although waste generation associated with multi-family development is generally less than single-family homes, future development within the Rezone Sites would increase solid waste generation throughout the City due to the increase in the number of overall residential units that would be allowed with the proposed rezones. CalRecycle (2019) Findings

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defines multi-family development as having a waste generation rate of 4 pounds/dwelling unit/day. The project would add an additional 1,209 multi-family housing units compared to what would be allowed under the City’s existing General Plan/Zoning. The addition of 1,209 multi-family housing units would increase solid waste generation by 4,836 pounds per day. As detailed above, the Sycamore Landfill is expected to remain open until December 31, 2042 with current remaining capacity of approximately 113,972,637 cubic yards as of December 31, 2016. Future projects, whether discretionary or ministerial, would be required to adhere to state and local regulations relating to solid waste and recycling. Specifically, the City is required to meet solid waste diversion goals set forth in the California Integrated Waste Management Act which would decrease waste delivered to the landfill. Additional measures for the reduction of solid waste includes goals set by the state to reduce organic waste disposed of in landfills. The City would require future development to contract with available solid waste service providers that would provide the required solid waste disposal, including recycling and organic material recycling to meet exiting State and local requirements. Future projects would also be required to comply with General Plan Safety Element Policy 3.8 which promotes the safe, environmentally sound means of solid waste disposal for the community.

Future development at the Rezone Sites is located within existing developed areas with access to solid waste disposal services. No development is proposed as part of the project; however, it is anticipated that future projects would result in an increased in solid waste generation. Solid waste requirements associated with the future development of the Rezone Sites would be evaluated upon submittal of project specific development plans. All projects whether discretionary or ministerial would be reviewed for conformance with state and local regulations and adherence to General Plan policies.

Therefore, through regulatory conformance, impacts associated with the solid waste disposal and capacity 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. (Draft PEIR, p. 4.15-7) Findings

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Explanation: The project does not propose the construction of new housing or other development; rather it provides capacity for future development consistent with state Housing Element Law. Buildout of the Rezone Sites would increase density and create new mixed-use and residential mixed-use development throughout the City, resulting in greater population concentrations within these redeveloped neighborhoods. This could result in an increase in demand on emergency evacuation.

The project does not propose any changes in the City’s existing circulation network, and no land uses are proposed that would impair implementation of or physically interfere with the City’s emergency response plan, evacuation routes, or conflict with any of the MHMP specific hazard mitigation goals, objectives, and related actions.

Specifically, the MHMP requires each jurisdiction to develop and publish evacuation procedures that are available to the public. The City provides educational materials related to emergency preparedness. All residents of the City have access to the materials, as well all Community Emergency Response Team training and information. Furthermore, applications for all future projects within the e Rezone Sites, whether discretionary or by-right, would be reviewed and approved by the City’s Fire Department prior to issuance of building permit to ensure consistency with fire standards and regulations (Fire Code). Additionally, future development would be required to adhere to the City’s General Plan (Safety Element) policies including, 4.2, 4.3, 4.4, 4.11, and 4.12 which address emergency response and emergency evacuation. Therefore, buildout of the Rezone Sites and Graves Avenue Rezone Sites would not conflict with emergency response, 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. (Draft PEIR, p. 4.15-8) Explanation: Rezone Sites 1 through 10 and 35 are located within the CAL FIRE VHFHSZ. Locating residential land uses adjacent to or within a high fire hazard area can result in increased fire-related risk to people and structures.

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Future development located within the VHFHSZ would be required to adhere to California Fire Code Title 19, Division 1, Section 3.07(b), requiring a minimum 30-foot brush clearance around structures for fire safety. Further codified by the City in Municipal Code Chapter

11.18, all new developments, subdivisions, or tracts that are planned in Fire Hazard Severity Zones and/or WUIA shall have a minimum of 100 horizontal feet of “fuel modified” defensible space between structures and wildland areas. The City’s General Plan policies 4.2 through 4.13 provide guidance for the minimization of fire hazards including ensuring adequate response times, setting standards for emergency access, structural standards, other planning design measures required to be considered in all new development.

Additionally, future discretionary projects would require review by the Building Official/Fire Marshal. Adherence to fire code regulations and General Plan policies would ensure impacts associated with risk of wildland fires would be less than significant.

3. Infrastructure Risks
Threshold: Would the Project require the installation or maintenance of associated infrastructure (such a roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Finding: Less than significant. (Draft PEIR, p. 4.15-9) Explanation: The project does not propose the construction of new housing or infrastructure. All impacts associated with required infrastructure improvements including any required measures to address fire safety would be evaluated in their respective subsequent environmental documents for discretionary projects, or as part of the ministerial review for by-right sites. Furthermore, all future development would undergo design review pursuant to the City’s Design Guidelines. With specific reference to Rezone Sites 1 through 10 and 35, which are located within the VHFHSZ, development on these sites would be required to include enhanced fire protection measures as detailed in the City’s building and fire codes. The City fire chief may also use their authority to require additional building, planning, or landscaping requirements that provide enhanced fire protection.

Future development within the Housing Sites, whether discretionary or by-right, would be required to adhere to all regulatory requirements in place to minimize wildfire hazards including applicable sections of the City fire and building codes, and Findings

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requirements from the fire chief that would be identified during future building permit reviews. Therefore, buildout of the project would not exacerbate fire risk or result in temporary or ongoing impacts on the environment. Impacts associated with the installation or maintenance of associated infrastructure would be less than significant.

4. Runoff Risks
Threshold: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Finding: Less than significant. (Draft PEIR, p. 4.15-10) Explanation: Wildfires can greatly reduce the amount of vegetation from hillsides.

Plant roots stabilize the soil and aboveground plant structures slow water, allowing it to percolate into the soil. Removal of surface vegetation as a result of a wildfire reduces the ability of the soil surface to absorb rainwater and can allow for increased runoff that may include large amounts of debris. If burned or exposed soil conditions exist post-fire, the rate of surface water runoff is increased as water percolation into the soil is reduced. The potential for surface runoff and debris flows increases significantly for areas recently burned by large wildfires (Moench and Fusaro 2012).

Slope failures, mudflows, and landslides are common in areas where steep hillsides and embankments are present, and such conditions would be exacerbated in a post-fire environment where vegetative cover has been removed. CAL FIRE mapping data indicates low to moderate erosion potential within the City limits.

Development at the Rezone Sites would be required to demonstrate that development would be elevated out of the floodplain and would not affect the conveyance of flood waters through elevated building pads, and/or other compliance measures as specified by the Federal Emergency Management Agency. All future development would conform to design requirements associated with proper site preparation and grading practices and would implement surface drainage improvements and erosion-control measures and
construction best management practices.

All future development would be required to meet the most current seismic safety requirements in the CBC, as adopted by the City, including design and construction measures intended to resist potential earthquake damage. Compliance with these requirements Findings

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would prevent exposure of people or structures to significant risks of downstream flooding or landslides due to post-fire slope instability or drainages changes.

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SECTION III.

IMPACTS THAT ARE LESS THAN SIGNIFICANT WITH MITIGATION

INCORPORATED
The City Council hereby finds that Mitigation Measures have been identified in the EIR and these Findings that will avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows:

A. AESTHETICS

1. 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 with mitigation. (Draft PEIR, pp. 4.1-16 through

4.1-18)
Explanation: Future development within Site 20B would have the potential to adversely affect the historic visual character of the site associated with the Edgemoor Dairy Barn, otherwise known as the Edgemoor Polo Barn. Future development of the area surrounding the Polo Barn including on Site 20A and 20B could result in indirect visual character and quality impacts due to changes affecting the visual environmental surrounding this historic resource. Specifically, development within a visual radius of the barn could result in indirect impacts to the historic resource related to the visibility of the resource and/or altering its surrounding visual character. General Plan policies 8-1 and 12.1 are aimed at the protection of historic buildings. Policy

12.1 requires that future development respects and enhances the Polo Barn setting. As part of the development review process, development at Site 20B would be required to demonstrate a project design that respects and enhances the adjacent historic resource.

Development on Sites 20A and 20B could result in a significant impact due to potential changes in visual character and quality surrounding the historic Polo Barn.

Implementation of MM-CUL-1 would reduce potential adverse impacts associated with changes in visual quality and character surrounding the Polo Barn to less than significant. Specifically, application of the Secretary of Interior Standards for the Treatment of Historic Properties provides guidelines for future development that would ensure maintenance of the historical integrity of the Polo Barn.

While the visual character of the site would change with new Findings

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development, the visual quality of the Polo Barn would be retained through application of the Secretary of Interior Standards.

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The City Council finds that MM-CUL-1 is feasible, is adopted, and will further reduce impacts related to visual character. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section
15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to visual character, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to visual character. (Draft PEIR, p. 4.1-18.) B. BIOLOGICAL RESOURCES

1. Sensitive Species
Threshold: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Finding: Less than significant with mitigation measures. (Draft PEIR, pp. 4.3- 17 through 4.3-23)
Explanation: While the project does not specifically propose activities such as grading or construction that would have the potential to displace sensitive species, future development within the Rezone Sites could have the potential to directly or indirectly impact sensitive species through such activities.

Direct impacts to sensitive plant and wildlife species could potentially result from the removal of occupied habitat within undeveloped or substantially unimproved sites through grading and other land development activities. Site-specific vegetation mapping would be required to verify resources present. Additionally, indirect impacts to sensitive plant or wildlife species could also result from excess noise, lighting, or runoff generated during project construction. Table 4.3-3 of the Draft PEIR identifies the potential species that could be impacted at each site. Future development of these sites has the potential to disturb sensitive on-site biological resources, specifically plants, wildlife, least Bell’s vireo, coastal California gnatcatcher, and nesting and migratory birds.

The following Rezone Sites are considered undeveloped or have a substantial portion of the site unimproved (e.g., have the potential to contain native and/or non-native habitats), and future development of these sites has the potential to impact sensitive plants or wildlife:

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1, 2, 3, 4, 5, 8, 10, 15, 16A, 16B, 17, 18, 19, 20A, 20B, and 35 .

Future development of these sites could result in direct and/or indirect impacts to sensitive plants and sensitive wildlife. At this program level of analysis, there are no project-specific development plans to review that would allow for site-specific impact identification and/or avoidance. Future development would proceed based on the timing and proposed designs of individual property owners.

Therefore, at a program level of review, impacts associated with sensitive plants and wildlife would be potentially significant.

Impacts to least Bell’s vireo could occur as a result of future development within Site 16A, 17, 18, and 35. Direct impacts to least Bell’s vireo could potentially result from the removal of riparian habitat during the least Bell’s vireo breeding season (April 10 to July 31). Additionally, indirect impacts could also result from excess noise or lighting generated during project construction should it occur within 300 feet of riparian habitat during the breeding season (April 10 to July 31).

The following Rezone Sites have been mapped as containing or adjacent to coastal sage scrub or chaparral habitat, and future development of these sites has the potential for direct and/or indirect impacts to coastal California gnatcatcher: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 16A, 16B, 17, and 35. Direct impacts to coastal California gnatcatcher could potentially result from the removal of coastal sage scrub habitat during the coastal California gnatcatcher breeding season (March 1 to August 15). Additionally, indirect impacts could also result from excess noise or lighting generated during project construction should it occur within 300 feet of coastal sage scrub or chaparral habitat during the breeding season (March 1 to August 15).

Direct and/or indirect impacts to coastal California gnatcatcher would be potentially significant.

Due to the potential for mature trees and/or native/non-native vegetation to support these nesting birds, future development at all of the Rezone Sites has the potential to directly impact nesting or migratory bird species should vegetation clearing and/or project construction occur during the general bird breeding season. Direct impacts to nesting or migratory birds, including raptors (as protected under the MBTA), could potentially result from the removal of mature trees and/or native vegetation within project areas during the typical bird breeding season (January 15–September 15). Direct impacts to migratory or nesting birds would be potentially significant.

Future development at the Rezone Sites would result in significant impacts, as follows:

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• Direct and/or indirect impacts to sensitive plants and sensitive wildlife within Rezone Sites 1, 2, 3, 4, 5, 8, 10, 15, 16A, 16B, 18, 19, 20A, 20B, and 35 would be potentially significant (Impact BIO-1).
• Direct and/or indirect impacts to least Bell’s vireo within Rezone Sites 16A, 17, 18, and 35 would be potentially
significant (Impact BIO-2).
• Direct and/or indirect impacts to coastal California
gnatcatcher within Rezone Sites 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 16A, 16B, 17, and 35. would be potentially significant (Impact BIO-3).
• Direct impacts to migratory or nesting birds within all Rezone Sites would be potentially significant (Impact BIO-4).

Direct and indirect impacts to sensitive plants and sensitive wildlife, including least Bell’s vireo, coastal California gnatcatcher, and migratory or nesting birds, would be reduced to a level less than significant with implementation of the mitigation framework MM-BIO1, MM-BIO-2, MM-BIO-3, and MM-BIO-4.

MM-BIO-1: Applications for future development, where the City has determined a potential for impacts to sensitive biological resources, shall be required to comply with the following mitigation measure. a) Prior to issuance of any construction permit or any earth-moving activities, a site-specific general biological resources survey shall be conducted to identify the presence of any sensitive biological resources, including any sensitive plant or wildlife species. A biological resources report shall be submitted to the City to document the results of the biological resources survey. The report shall include: (1) the methods used to determine the presence of sensitive biological resources; (2) vegetation mapping of all vegetation communities and/or land cover types; (3) the locations of any sensitive plant or wildlife species; (4) an evaluation of the potential for occurrence of any listed, rare, and narrow endemic species; and (5) an evaluation of the significance of any potential direct or indirect impacts from the proposed project. If suitable habitat for sensitive species is identified based on the general biological survey, then focused presence/absence surveys shall be conducted in accordance with applicable resource agency survey protocols and incorporated into the biological resources report. If potentially significant impacts to sensitive biological resources are identified, project-level grading and site plans shall incorporate project design features to avoid Findings

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or minimize direct impacts on sensitive biological resources to the extent feasible, and the report shall also recommend appropriate mitigation to reduce the impacts to below a level of significance, where feasible. Mitigation measures shall be consistent with the standards contained in Section 5.3 of the 2018 Draft Santee Subarea Plan, and projects shall be required to obtain all necessary permits to ensure compliance with applicable federal, state, and local regulations, such as the federal and state Endangered Species Acts.
b) Environmentally Sensitive Areas shall be identified in the biological resources report and avoided to the maximum extent practicable. In areas near or adjacent to Environmentally Sensitive Areas (i.e., natural habitats and vegetation, wetlands, wildlife areas, wildlife corridors), the biological resources report will consider the following measures:

Avoidance of Environmentally Sensitive Areas. In areas near or adjacent to Environmentally Sensitive Areas, construction limits shall be clearly demarcated using highly visible barriers (such as silt fencing), which shall be installed under the supervision of a qualified biologist prior to the commencement of work.

Construction personnel shall strictly limit their activities, vehicles, equipment, and construction materials to the project footprint, including designated staging areas, and routes of travel. The construction areas shall be limited to the minimal area necessary to complete the proposed project. The fencing shall remain in place until the completion of all construction activities and shall be promptly removed when construction is complete.

Biological Monitoring. A qualified biological monitor shall conduct construction monitoring of all work conducted within/adjacent to environmentally sensitive areas during all vegetation removal and ground-disturbing activities such as staging and grading, for the duration of the proposed project to ensure that practicable measures are being employed to avoid incidental disturbance of habitat outside the project footprints and to survey for sensitive wildlife species. When vegetation removal and ground-disturbing activities are not occurring, as-needed monitoring at the project sites shall occur.

Worker Environmental Awareness Program. In areas near or adjacent to Environmentally Sensitive Areas, a qualified biologist shall conduct a Worker Environmental Awareness Program
(WEAP) training session for project and construction personnel prior to the commencement of work. The training shall include a Findings

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description of the species of concern and their habitats, the general provisions of the Endangered Species Acts (FESA and CESA), the penalties associated with violating the provisions of the acts, the general measures that are being implemented to conserve the species of concern as they relate to the project, and the access routes to and project site boundaries.

Best Management Practices. During future project construction activities, the following best management practices (BMPs) shall be implemented:
• All equipment maintenance, staging, and dispensing of fuel, oil, or any other such activities shall occur in developed or designated non-sensitive upland habitat areas. The
designated upland areas shall be located to prevent runoff from any spills from entering Waters of the US.
• A construction Storm Water Pollution Prevention Plan
(SWPPP) and a soil erosion and sedimentation plan shall be developed (where requirements are met) to minimize erosion and identify specific pollution prevention measures that shall eliminate or control potential point and nonpoint pollution sources onsite during and following the project construction phase. The SWPPP shall identify specific BMPs during
project construction to prevent any water quality standard exceedances. In addition, the SWPPP shall contain
provisions for changes to the plan such as alternative
mechanisms, if necessary, during project design and/or
construction to achieve the stated goals and performance standards.
• Trash shall be stored in closed containers so that it is not readily accessible to scavengers and shall be removed from the construction site on a daily basis.
• Water quality shall be visually monitored by the biological monitor to ensure that no substantial increases in turbidity occur during construction.
• All relevant natural resource permits and authorizations shall be obtained from appropriate agencies (i.e., USACE,
RWQCB, and CDFW) prior to the initiation of construction activities. Permit conditions contained within the permits and authorizations shall be employed throughout the duration of the project.
• Hydrologic connectivity shall be maintained within drainages during the duration of construction. Brush, debris material, mud, silt, or other pollutants from construction activities shall Findings

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not be placed within drainages and shall not be allowed to enter a flowing stream.
• Dust control measures shall be implemented by the contractor to reduce excessive dust emissions. Dust control measures shall be carried out at least two times per day on all
construction days, or more during windy or dry periods, and may include wetting work areas, the use of soil binders on dirt roads, and wetting or covering stockpiles.
• No pets shall be allowed in, or adjacent to, the project sites. • Rodenticides, herbicides, insecticides, or other chemicals that could potentially harm wildlife or native plants shall not be used near or within Environmentally Sensitive Areas within or near the roadway segments.
• Construction equipment shall be cleaned of mud or other debris that may contain invasive plants and/or seeds and inspected to reduce the potential of spreading noxious weeds before mobilizing to the site and before leaving the site during the course of construction.
• The cleaning of equipment will occur at least 300 feet from Environmentally Sensitive Area fencing.

Use of Native Plants. All project-related planting and landscaping shall not use plants listed on California Invasive Plant Council.

Locally native plants shall be used near open space and native areas to the greatest extent feasible.

MM-BIO-2: Applications for future development, wherein the City has determined a potential for impacts to least Bell’s vireo, shall be required to comply with the following mitigation framework.

Prior to issuance of a permit for grading or vegetation removal, USFWS protocol surveys for least Bell’s vireo shall be required should project construction occur within 300 feet of riparian habitat during the breeding season (April 10 to July 31). If least Bell’s vireo are identified during the protocol surveys, then noise attenuation measures shall be required to ensure that noise levels from construction do not exceed a 60 dB(A) hourly average per hour at the edge of the riparian habitat or to the ambient noise level if it exceeds 60 dB(A) prior to construction. Construction noise monitoring shall be required to verify that noise levels at the edge of occupied habitat are maintained below 60 dB(A) hourly average unless an analysis completed by a qualified acoustician shows that noise generated by construction activities would not exceed 60 dB(A) hourly average at the edge of occupied habitat.

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MM-BIO-3: Applications for future development, where the City has determined a potential for impacts to coastal California gnatcatcher, shall be required to comply with the following mitigation framework.

Prior to issuance of a permit for grading or vegetation removal, USFWS protocol surveys for coastal California gnatcatcher shall be required where project construction is proposed within 300 feet of coastal sage scrub or chaparral habitat during the breeding season (March 1 through August 15). If coastal California gnatcatcher are identified during the protocol surveys, then noise attenuation measures shall be required to ensure that noise levels from construction do not exceed a 60 dB(A) hourly average per hour at the edge of the coastal sage scrub or chaparral habitat or to the ambient noise level if it exceeds 60 dB(A) prior to construction.

Construction noise monitoring shall be required to verify that noise levels at the edge of occupied habitat are maintained below 60 dB(A) hourly average unless an analysis completed by a qualified acoustician shows that noise generated by construction activities would not exceed 60 dB(A) hourly average at the edge of occupied habitat.

MM-BIO-4: Applications for future development, where the City has determined a potential for impacts to mature trees and/or native vegetation suitable for nesting birds, shall be required to comply with the following mitigation framework.

If any construction commences during the bird breeding season, a preconstruction survey for nesting birds shall occur within three days prior to construction activities by an experienced avian biologist. The survey shall occur within all suitable nesting habitat within the project impact area and a minimum 250-foot buffer (or as otherwise mandated by wildlife agencies [CDFW and USFWS]). If nesting birds are found, an avoidance area shall be established, in consultation with the wildlife agencies as appropriate, by a qualified biologist around the nest until a qualified avian biologist has determined that young have fledged or nesting activities have ceased. The project site shall be re-surveyed if there is a lapse in construction activities for more than 3 days.

The City Council finds that MM-BIO-1 through MM-BIO-4 are feasible, are adopted, and will further reduce impacts related to sensitive species. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate Findings

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or avoid the potentially significant impacts of the proposed Project to sensitive species, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to sensitive species. (Draft PEIR, pp. 4.3-20 through 4.3-23.)

2. Riparian Habitat
Threshold: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Finding: Less than significant with mitigation measures. (Draft PEIR, pp. 4.3- 24 through 4.3-25)
Explanation: While the project does not specifically propose vegetation removal, future development of the Rezone Sites could have the potential to directly impact sensitive vegetation communities through such activities. Sensitive vegetation communities which exist or have the potential to exist at Rezone Sites include coastal sage scrub, nonnative grasslands, and wetland/riparian. These communities are considered sensitive due to their limited occurrence and ability to support diverse and sensitive species. Approximately 37 acres, or 22 percent of the total land area affected by the proposed rezones may contain sensitive habitats. Actual impacts would require verification during the project level review process.

The following Rezone Sites are considered undeveloped or have a substantial portion of the site unimproved (e.g., have the potential to contain native and/or non-native habitats), and future development of these sites has the potential to result in impacts due to the removal of sensitive vegetation communities: 1, 2, 3, 4, 5, 8, 10, 16A, 16B, 17, 18, 19, 20A, 20B, and 35. Future development at these sites could directly impact sensitive vegetation communities. At this program level of analysis, there are no project-specific development plans available for review that would allow for site-specific identification of sensitive vegetation communities and/or determination of avoidance. Future development would proceed based on the timing and proposed designs of individual property owners. Therefore, at this program level of review, impacts associated with removal of sensitive vegetation communities would be potentially significant.

Direct impacts to sensitive vegetation communities within Rezone Sites 1, 2, 3, 4, 5, 8, 10, 15, 16A, 16B, 17, 18, 19, 20A, 20B, and 35 would be potentially significant.

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Mitigation is proposed for implementation of both discretionary and by-right development projects. Mitigation would either be applied during a future discretionary review or for by-right development or would be applied as a requirement of the City’s objective design and performance standards adopted as part of the project. Future development of Rezone Sites would require implementation of the following mitigation framework:

MM-BIO-1 would require site-specific biology surveys, at the time future projects are proposed, as determined by the City based on the conditions at the time of application. Potentially significant impacts to sensitive vegetation communities shall be identified during the biology survey and project-specific mitigation measures to reduce the impacts to below a level of significance shall be identified in a biological resources report. Impacts to sensitive vegetation communities would be reduced to a level less than significant with implementation of MM-BIO-1 and MM-BIO-5.

MM-BIO-5: Prior to issuance of any grading or removal of sensitive vegetation communities, the applicant shall provide evidence to the City that replacement habitats have been preserved in accordance with the mitigation ratios in the 2018 Draft Santee Subarea Plan. The required acreages and types of replacement habitat shall be included as a note on the grading plans and the City shall require evidence of satisfaction prior to grading. Replacement habitats may be in the form of a dedicated easement, proof of purchase of mitigation credits, or other method of conservation. The applicant shall additionally implement all feasible avoidance and minimization measures to protect habitats remaining on-site.

The City Council finds that MM-BIO-1 and MM-BIO-5 are feasible, are adopted, and will further reduce impacts related to riparian habitat. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to riparian habitat, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to riparian habitat. (Draft PEIR, pp. 4.3-24 through 4.3-25.)

3. Wetlands
Threshold: Would the Project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act Findings

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(including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Finding: Less than significant with mitigation measures. (Draft PEIR, pp. 4.3- 26 through 4.3-27)
Explanation: While the project does not specifically propose alteration of a known or potential jurisdictional water or wetland, future development of the Rezone Sites have the potential to directly or indirectly impact jurisdictional waters or wetlands by vegetation removal and/or grading activities associated with development. Rezone Sites 1, 2, 3, 4, 5, 16A, 16B, 17, and 18 have been mapped as potentially containing a wetland or water resource (USFWS 2021a).

Additionally, Rezone Sites 8, 10, 19, 20A, and 35 have the potential for unmapped jurisdictional waters or wetlands. Because the biological resource assessment associated with Rezone Sites are based on secondary source information rather than site-specific field surveys, specific impacts would be refined for individual projects.

Site-specific analysis and determination of feasibility of avoidance is not possible at this program level of review due to the absence of any project specific development proposals. At the time development is proposed and where the potential for jurisdictional waters or wetlands may be present, a formal wetland delineation would be required in conjunction with future project applications to identify the precise boundaries of jurisdictional resources. While it is possible that specific projects may be able to avoid wetland resources through project design, at this program level of analysis, there are no projectspecific development plans that would allow for site-specific identification of wetland resources or jurisdictional waters. Future development would proceed based on the timing and proposed designs of individual property owners which is unknown at this time.

Therefore, impacts to jurisdictional waters and wetlands would be potentially significant.

Impacts to jurisdictional waters and wetlands within Rezone Sites 1, 2, 3, 4, 5, 8, 10, 16A, 16B, 17, 18, 20A, and 35) would be potentially significant. However, they would be reduced to a level less than significant with implementation of the mitigation framework including MM-BIO-6.

MM-BIO-6: Applications where the City has determined a potential for impacts to jurisdictional waters and wetlands, shall be required to comply with the following mitigation framework.

Prior to issuance of any construction permit or any earth-moving activities, a site-specific general biological resources survey (BIO-1) Findings

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shall be conducted to identify the presence of any sensitive biological resources, including any wetlands. Should any potential jurisdictional waters or wetlands be identified on-site during the general biological resources survey, then a jurisdictional wetlands delineation shall be conducted following the methods outlined in the USACE’s 1987 Wetlands Delineation Manual and the Regional Supplement to the Corps of Engineers Delineation Manual for the Arid West Region.

The limits of any wetland habitats on-site under the sole jurisdiction of CDFW shall also be delineated, as well as any special aquatic sites that may not meet federal jurisdictional criteria but are regulated by the RWQCB.

Avoidance measures based on project-level grading and site plans shall be incorporated into the project design to minimize direct impacts to jurisdictional waters consistent with federal, state, and City guidelines. Unavoidable impacts to wetlands shall be minimized to the maximum extent practicable and would be subject to alternatives and mitigation analyses consistent with U.S.

Environmental Protection Agency 404(b)(1) findings and procedures under the USACE’s permit process. Unavoidable impacts would require the in-kind creation of new wetland of the same type lost, at a ratio determined by the applicable regulatory agencies that would prevent any net loss of wetland functions and values. Wetland creation on-site or within the same wetland system shall be given preference over replacement off-site or within a different system. The City shall also control use and development in surrounding areas of influence to wetlands with the application of buffer zones. Buffer widths shall be 50 to 200 feet from the edge of the wetland/riparian habitat, unless the applicant demonstrates that a buffer of lesser width would protect the resources of the wetland based on sitespecific information related to construction and operation. Use and development within buffer areas shall be limited to minor passive recreational uses with fencing, desiltation or erosion control facilities, or other improvements deemed necessary to protect the habitat, to be located in the upper (upland) half of the buffer when feasible. All wetlands and buffers shall be permanently conserved or protected through the application of an open space easement or other suitable device.

Additional requirements apply for development along the San Diego River to implement Draft Subarea Plan Section 5.3.4.3. Specifically, wherever development is proposed in or adjacent to riparian habitats along the main stem San Diego River, the riparian area and other wetlands or associated natural habitats located on the project site shall be designated as biological open space and incorporated into the preserve, including recordation of an easement to ensure their Findings

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protection in perpetuity. In addition, a minimum 100-foot biological buffer shall be established for upland habitats, beginning at the outer edge of riparian vegetation. Within the 100-foot biological buffer, no new development shall be allowed, and the area shall be managed for natural biological values as part of the preserve system. In the event that natural habitats do not cover the 100-foot buffer area at the time of the proposed action, habitats appropriate to the location and soils shall be restored as a condition for the proposed action. In most cases, coastal sage scrub vegetation shall be the preferred habitat to restore within the biological buffer.

The City Council finds that MM-BIO-6 is feasible, is adopted, and will further reduce impacts related to wetlands. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to wetlands, as identified in the EIR.

Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to wetlands. (Draft PEIR, pp. 4.3-26 through 4.3-27.)

4. Wildlife Movement
Threshold: Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Finding: Less than significant with mitigation. (Draft PEIR, p. 4.3-27) Explanation: The Rezone Sites are primarily restricted by developed land.

Although Rezone Sites 10, 16A, 16B, 18, and 35 are bounded, in part, by undeveloped land, they do not meet the criteria for a wildlife movement corridor as they are restricted by roads and other development. Additionally, they are not identified as a wildlife movement corridor in the Draft Santee Subarea Plan.

A portion of Rezone Sites 17 and 18 contain areas associated with the San Diego River and its tributaries. While the Draft Santee Subarea Plan identifies the San Diego River as a regionally significant wildlife movement corridor; the Subarea Plan anticipated development of Rezone Sites 17 and 18. Refer to Subarea Plan Figure 5-1, Subarea Plan Preserve Santee MSCP Subarea Plan, which shows those sites as being located outside of the Preserve.

Retention of the river corridor outside of these sites would be consistent with the Subarea Plan assumptions for wildlife movement.

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Furthermore, any potential impacts to wetland and riparian habitats within Rezone Sites 17 and 18 would be required to comply with State and Federal requirements for wetland avoidance and implementation of MM-BIO-6 which ensures wetland resources are avoided or mitigated and adequate buffers are retained adjacent to the San Diego River.

Application of the mitigation measures described in this section to both ministerial and discretionary development projects would ensure impacts to wildlife corridors would be reduced or avoided to a level that would be less than significant. Impacts associated with wildlife movement corridors would be less than significant with mitigation.

The City Council finds that MM-BIO-6 is feasible, is adopted, and will further reduce impacts related to wildlife movement. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to wildlife movement, as identified in the EIR. Therefore, impacts are considered less than significant.

Mitigation measures will further reduce impacts related to wildlife movement. (Draft PEIR, pp. 4.3-27 through 4.3-28.)
C. 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 with mitigation measures. (Draft PEIR, pp. 4.4- 13 through 4.4-15)
Explanation: The record search identified two historic resources: one adjacent to Site 20 and one within Site 24. Adjacent to Site 20 is the Edgemoor Farm Dairy Barn which is listed on the NRHP. Impacts to this historical resource would be significant if future development would cause a substantial adverse change in the significance of a historical resource, as defined in the CEQA Guidelines Section 15064.5. As defined in the CEQA Guidelines Section 15064.5, “substantial adverse change means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the historical resource is materially impaired.” If future development is not designed with sensitivity to the historic Findings

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context of the Edgemoor Farm Dairy Barn, including adherence to Secretary of Interior Standards for the Treatment of Historic Properties and standards and guidelines prescribed by the State Office of Historic Preservation, indirect impacts to this historic structure could result. Development within a visual radius of the Barn, specifically development at Site 20, could result in indirect impacts to the historic resource related to the visibility of the resource and/or altering its surrounding visual character.

Site 24 contains a single-family house built circa 1915. This property has been recommended not eligible under any California Register of Historical Resources criteria. Future development would not result in a significant impact.

While the project does not specifically propose alteration of a known historic resource, it can be assumed that future development within the Rezone Sites could have the potential to directly or indirectly impact resources through such activities. The Rezone Sites have the potential to contain buildings or structures that may be 50 years of age or older at the time of future development and, therefore, may need to be evaluated for historical significance. Direct impacts to historical resources could potentially result from the physical demolition, destruction, relocation, or alteration of potential historic resources within the project areas. Policies 8-1 and 12.1 of the City’s General Plan (2003) are aimed at the protection of historic buildings.

As future projects are planned, they must adhere to these policies and regulations through application of requirements for development review. However, because site-specific details of specific projects are not known at this program-level of analysis including project footprints, project designs, and timelines for development, impacts to historic resources would be considered potentially significant.

Future development at the Rezone Sites could result in significant impacts to historic resources. Potentially significant impacts to historical resources would be mitigated through the application of MM-CUL-1 that would verify the age of a buildings or structures that could be impacted by future development, and require an evaluation of its historical significance. Implementation of MM-CUL-1 would ensure that significant impacts associated with historic resources would be reduced to a less than significant level.

MM-CUL-1: Applications for future development of project areas, wherein the City Development Services Director has determined a potential for impacts to historical resources, shall be required to comply with the following mitigation framework:

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a) Prior to the issuance of any permit for a future development project, the age and original structural integrity and context of any buildings/structures occurring on the project areas shall be verified.

A staff level evaluation is required in conjunction with the development permit application to verify the age and original structural integrity of all on-site structures.
b) For any building/structures in excess of 50 years of age having its original structural integrity intact, a qualified professional historian may be required to determine whether the affected building/structure is historically significant. The evaluation of historic architectural resources shall be based on criteria such as age, location, context, association with an important person or event, uniqueness, or structural integrity, as indicated in CEQA Guidelines Section 15064.5. A historical resource report shall be prepared by a Secretary of Interior’s Standard Historic Architect or Architectural Historian and submitted by the project applicant to the City and shall include the methods used to determine the presence or absence of historical resources, identify potential impacts from the proposed project, evaluate the significance of any historical resources, and identify mitigation measures.
c) Future development at Rezone Site 20 shall be required to obtain the services of a Secretary of Interior’s Standard Historic Architect or Architectural Historian to submit a report to the City demonstrating how development adjacent to the Polo Barn would adhere to Secretary of Interior Standards for the Treatment of Historic Properties and standards and guidelines prescribed by the State Office of Historic Preservation to ensure indirect impacts are avoided. Development on Site 20 is not subject to items (a) and (b) above as the Polo Barn is already known to be a significant historical site
The City Council finds that MM-CUL-1 is feasible, is adopted, and will further reduce impacts related to historical resources.

Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to historical resources, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to historical resources. (Draft PEIR, pp. 4.4- 14 through 4.4-15.)
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2. Archaeological Resources
Threshold: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: Less than significant with mitigation measures. (Draft PEIR, pp. 4.4- 15 through 4.4-18)
Explanation: The evaluation of potential impacts to archeological resources analysis within the Rezone Sites followed one of two different levels of analysis. Those sites identified for eligibility for by-right development including Sites 15, 16A, 17, 18, 20B and 24, along with the two Graves Avenue sites were evaluated at a site-specific level, including completion of cultural resource surveys to identify the potential for archaeological resources. The remainder of the Rezone Sites are discussed using a programmatic analysis, with the expectation that future discretionary review and associated sitespecific analysis would be required prior to development.

There are eight parcels within the Moderate Potential for Register Eligible Buried Archaeological Sites and 10 parcels within the Moderate Potential for Register Eligible Archaeological Sites. These sites are located within areas with higher potential to encounter Register Eligible resources either on the surface or during ground disturbance activities.

The records search identified one historic-period archaeological (CASDI-22504) site within four Rezone Sites. This resource was determined not eligible for listing on the CRHR; therefore, future development would not result in a significant impact. The records search and survey also identified one prehistoric resource (CA-SDI5669) and one isolated artifact within a Rezone Site. The isolated artifact does not possess the characteristics to qualify as significant under CEQA. The prehistoric resource could potentially be significant and would require further testing and excavation to determine its CEQA significance. Based on the fact that there is no development proposed at the site with the potentially significant prehistoric resource, archaeological testing has not been completed at this program level of review. An appropriate testing program would need to be developed concurrent with a specific project application to take into consideration the project footprint and potential for avoidance of resources. Therefore, future development would have the potential to directly or indirectly impact potentially significant archaeological resources. The location of potential archaeological sites is undisclosed for confidentiality per 14 California Code of Regulations Section 15120 (d); however, the City maintains a record Findings

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of the survey results and is able to use these findings to determine applicability of mitigation measures.

Additionally, there is a possibility of unknown subsurface deposits to be present within the Rezone Sites because of the thousands of years of use of the northern El Cajon Valley. Such buried sites would be composed of the same artifacts as surface deposits such as projectile points, scrapers, milling implements (manos and metates), flakes, and possibly animal bone and marine shell. While the project does not specifically propose alteration of the known archaeological resource or ground-disturbing activities such as grading or excavation, future development within the Rezone Sites would have the potential to directly or indirectly impact undiscovered subsurface archaeological resources that have not been evaluated. Policies 8-1 and 8.2 of the City’s General Plan (2003) are aimed at the protection of prehistoric sites. As future projects are planned, they would be required to adhere to these policies and regulations through a discretionary review or a ministerial development review process.

Additionally, for certain environmental documents, AB 52 requires early consultation with culturally affiliated tribes in the area that request consultation. However, because site-specific details are not known at this program-level of analysis, potential impacts to archaeological resources or tribal cultural resources would be significant.

Potential direct and/or indirect impacts to archaeological resources would be potentially significant. Impacts to surface and subsurface archaeological resources within the Rezone Sites would be mitigated through the implementation of MM-CUL-2 and MM-CUL-3, that would require significance evaluation of archaeological resources, mitigation for potential impacts to these resources, and a requirement for archaeological and Native American construction monitoring to avoid significant impacts to unknown buried archaeological resources. Implementation of MM-CUL-2 and MMCUL-3 would reduce impacts to a less than significant level.

MM-CUL-2: Applications for future development, wherein the City Development Services Director has determined a potential for impacts to subsurface archaeological resources, shall be required to comply with the following mitigation framework:

Prior to the issuance of any permit for future development consistent with the project and if the project has not been surveyed within the last five years, an archaeological survey shall be conducted by a qualified archaeologist to evaluate the presence of archaeological Findings

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resources and the need for project impact mitigation by preservation, relocation, or other methods. The archaeological survey shall include a records search at the South Coastal Information Center branch of the California Historical Research Information System, to determine if previously recorded prehistoric or historic archaeological resources exist on the housing site. In addition, the Native American Heritage Commission should be contacted to perform a Sacred Lands File Search. An archaeological resource report detailing the results of the record search, Sacred Lands Search, and the field survey of the project area shall be submitted by the project applicant to the City.

The report shall include the methods used to determine the presence or absence of archaeological resources, identify potential impacts from the proposed project, and evaluate the significance of any archaeological resources identified. If potentially significant impacts to an identified archaeological resource are identified, the report shall also recommend appropriate mitigation to reduce the impacts to below a level of significance, which could include avoidance as the preferred method, a data recovery program and/or construction monitoring. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum and not be made available for public disclosure. Reports shall be submitted to the South Coastal Information Center upon finalization.

MM-CUL-3: Applications for future development wherein the City Development Services Director or a site specific report has determined a potential for discovery of buried archaeological resources shall be required to comply with the following mitigation framework for archaeological and Native American construction monitoring:

Prior to issuance of a grading permit, the City’s Project Planner at the City must verify that the requirements for archaeological and Native American construction monitoring have been noted on the construction documents.

The applicant must provide written verification to the City Project Planner stating that a Secretary of Interior’s Standards qualified archaeologist and Native American monitor have been retained by the owner/applicant to implement construction monitoring.

The qualified archaeologist and Native American monitor shall be invited to attend the pre-construction meeting with the contractor and any subcontractors to describe the goal of construction monitoring.

Archaeological and Native American monitors shall be present during ground-disturbing activities (grubbing, demolition of Findings

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foundations, grading, trenching) that have the potential to unearth unknown subsurface archaeological deposits or Tribal cultural resources. If archaeological or Tribal cultural resources are discovered, both monitors may halt or divert ground-disturbing activities within 50 feet to allow for a determination of the resource’s potential significance. The qualified archaeologist shall notify the City Project Planner of the discovery. Isolates and non-significant deposits shall be minimally documented in the field. Significant archaeological discoveries include intact features, stratified deposits, previously unknown archaeological sites, and human remains.

If a significant discovery is made, the qualified archaeologist shall prepare a data recovery plan in consultation with the Native American monitor to submit for approval by the City Project Planner.

The plan shall be implemented using professional archaeological methods. Construction ground-disturbing activities, including grubbing, grading, and trenching, would be allowed to resume after the completion of the recovery of an adequate sample and recordation of the discovery.

All cultural material collected during the monitoring and data recovery program shall be processed and curated at a San Diego facility that meets federal standards per 36 CFR Part 79 unless the tribal monitors request the collection.

If human remains are discovered, work shall halt in that area and the procedures set forth in the California Public Resources Code (Sec. 5097.98) and State Health and Safety Code (Sec. 7050.5) will be followed. The qualified archaeologist shall contact the County Coroner.

After the completion of the monitoring, an appropriate report shall be prepared by project archaeologist. If no significant cultural resources are discovered, a brief letter to City Project Planner and South Coastal Information Center shall be prepared by the project archaeologist. If significant cultural resources are discovered, a report with the results of the monitoring and data recovery (including the interpretation of the data within the research context) shall be prepared by project archaeologist, reviewed by a Native American representative, and submitted to the City Project Planner and South Coastal information Center.

The City Council finds that MM-CUL-2 and MM-CUL-3 are feasible, are adopted, and will further reduce impacts related to archaeological resources. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State Findings

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CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to archaeological resources, as identified in the EIR.

Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to archaeological resources. (Draft PEIR, pp. 4.4-16 through 4.4-18.)
D. GEOLOGY AND SOILS

1. Paleontological Resources
Threshold: Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Finding: Less than significant with mitigation. (Draft PEIR, pp. 4.5-15 through

4.5-18)
Explanation: The Rezone Sites are all located within the City either within existing developed sites or vacant sites with some history of disturbance.

Unique geologic features have not been identified at any of the sites.

Impacts to unique geology would be less than significant.

According to the San Diego Natural History Museum’s
Paleontological Resources, County of San Diego, both the Friars Formation and the Stadium Conglomerate are considered to have a high paleontological resource potential (Deméré and Walsh 1993).

None of the Rezone Sites are located within either of these geologic formations. However, other formations in the City may have a moderate potential for paleontological resource discovery, particularly in the case of grading volumes with significant volume and/or depth. Geologic formations in the San Diego region have been rated according to the potential, or sensitivity, for yielding paleontological resources. The County of San Diego has developed its own guidelines for assigning paleontological potential, which include a five-tiered scale of high potential, moderate potential, low potential, marginal potential, and no potential. A description of each paleontological potential rating, as outlined by the County, is provided below (County of San Diego 2009):
• High Potential: Geologic units with high potential are known to contain paleontological areas with rare, well preserved, critical fossil materials for stratigraphic or paleoenvironmental interpretation, and fossils providing important information about the paleoclimatic, paleobiological, and/or evolutionary history (phylogeny) of animal and plant groups. Highly
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sensitive formations contain vertebrate fossil remains or are considered to have the potential to contain such remains. • Moderate Potential: Moderate potential is assigned to geologic units known to contain paleontological areas with fossil material that is poorly preserved, common elsewhere, or stratigraphically unimportant. This category is also applied to formations judged to have strong, but unproven, potential for containing important remains.
• Low Potential: Low potential is assigned to geologic units that, based on their relatively young age and/or high-energy
depositional history, are judged unlikely to produce important fossil remains. Typically, low potential units produce fossil remains in low abundance, or only produce
common/widespread invertebrate fossils whose taphonomy, phylogeny, and ecology is already well understood.
• Marginal Potential: Marginal potential is assigned to geologic units that are composed either of volcaniclastic (derived from volcanic sources) or metasedimentary rocks (metamorphized sediment), but that nevertheless have a limited probability for producing fossils from certain formations at localized
outcrops.
• No Potential: Geologic units with no potential are either entirely igneous in origin and therefore do not contain fossil remains, or are moderately to highly metamorphosed and
thus any contained fossil remains have been destroyed.

Artificial fill materials also have no potential, because the stratigraphic and geologic context of any contained organic remains (i.e., fossils) has been lost.

Grading into a geologic formation with high or moderate sensitivity has the potential to result in impacts to paleontological resources. At a program level of review, it is not possible to investigate each individual site to determine the depth of geologic formations and identify their associated paleontological sensitivity. For example, while the Rezone Sites are not located on formations with High Sensitivity (Friars and Mission Valley Formation), they could underly formations with moderate sensitivity. If grading were to occur at depths sufficient to disturb a moderate sensitivity geologic formations with potential paleontological resources, significant impacts could result. Potential impacts to paleontological resources would be significant. With implementation of MM-GEO-1, impacts associated with paleontological resources would be reduced to less than significant.

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MM-GEO-1: Paleontological Resources. To address potential impacts to paleontological resources, the City shall review the project application materials including the geotechnical report to determine if project grading has the potential to disturb geologic formations with the potential to contain paleontological resources. If grading depths remain within the organic and soil layers, no monitoring would be required. The City may request information from the applicant such as the depth of grading, geologic formations and paleontological sensitivity in order to determine the potential for impacts. In the event grading may disturb geologic formations with a moderate or high potential to contain paleontological resources, the following monitoring program shall be implemented prior to and during grading operations:

1. Preconstruction Personnel and Repository: Prior to the commencement of construction, a qualified project
paleontologist shall be retained to oversee the mitigation program. A qualified project paleontologist is a person with a doctorate or master’s degree in paleontology or related field and who has knowledge of the County of San Diego
paleontology and documented experience in professional
paleontological procedures and techniques. In addition, a regional fossil repository, such as the San Diego Natural History Museum, shall be designated by the City of Santee to receive any discovered fossils.

2. Preconstruction Meeting: The project paleontologist shall attend the preconstruction meeting to consult with the grading and excavation contractors concerning excavation schedules, paleontological field techniques, and safety issues.

3. Preconstruction Training: The project paleontologist shall conduct a paleontological resource training workshop to be attended by earth excavation personnel.

4. During-Construction Monitoring: A project paleontologist or paleontological monitor shall be present during all earthwork in formations with moderate to high paleontological sensitivity.

A paleontological monitor (working under the direction of the project paleontologist) shall be on site on a full-time basis during all original cutting of previously undisturbed deposits.

5. During-Construction Fossil Recovery: If fossils are
discovered, the project paleontologist (or paleontological monitor) shall recover them. In most cases, fossil salvage can be completed in a short period of time. However, some fossil specimens (e.g., a bone bed or a complete large mammal
skeleton) may require an extended salvage period. In these instances, the project paleontologist (or paleontological Findings

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monitor) has the authority to temporarily direct, divert, or halt grading to allow recovery of fossil remains in a timely manner.

6. Post-Construction Treatment: Fossil remains collected during monitoring and salvage shall be cleaned, repaired, sorted, and cataloged.

7. Post-Construction Curation: Prepared fossils, along with copies of all pertinent field notes, photos, and maps, shall be deposited in the designated fossil repository.

Post-Construction Final Report: A final summary paleontological mitigation report that outlines the results of the mitigation program shall be completed and submitted to the City of Santee within two weeks of the completion of each construction phase of the proposed project. This report shall include discussions of the methods used, stratigraphic section(s) exposed, fossils collected, inventory lists of cataloged fossils, and significance of recovered fossils.

The City Council finds that MM-GEO-1 is feasible, is adopted, and will further reduce impacts related to paleontological resources.

Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to paleontological resources, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to paleontological resources. (Draft PEIR, pp. 4.5-17 through 4.5-18.)
E. HAZARDOUS AND HAZARDOUS MATERIALS

1. Accident or Upset
Threshold: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Finding: Less than significant with mitigation measures. (Draft PEIR, pp. 4.7- 18 through 4.7-19)
Explanation: An accidental release of hazardous materials could occur during: (1) the routine use, transport, and disposal of materials during project operation (as discussed above); or (2) through the accidental upset of hazardous materials – either known or unknown – during excavation and construction of future development. Exposure to Findings

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hazardous materials could occur through contact with contaminated soil or groundwater, skin contact, or the inhalation of vapors or dust.

Future redevelopment or construction activities within the Rezone Sites may pose hazards to the public or the environment through the disturbance of existing contaminated soils, groundwater, or hazardous building materials. Grading and excavation activities could disturb soils and cause contaminants below ground to become airborne. Excavation below the groundwater table or dewatering could also bring construction workers in contact with contaminants through skin contact, ingestion, or inhalation.

During construction, workers also could be exposed to hazardous materials during demolition of buildings. Numerous structures within the Rezone Sites were constructed prior to 1978. Demolition of buildings built prior to 1978 may expose workers to ACMs or LBPs.

Inhalation of asbestos-containing dust may cause acute or chronic toxicity. Exposure to persons other than construction workers would be reduced by the exclusion of non-authorized personnel in construction areas determined to contain potentially hazardous materials. Exposure to construction workers would be controlled through conformance with Cal-OSHA worker safety standards.

Additionally, California law requires a licensed company to perform asbestos testing and abatement. These requirements ensure that all asbestos removal is completed with all required safety precautions to avoid release of hazardous materials into the environment. CCR Section 1532.1 requires construction workers to establish and implement a compliance program to ensure property handling and monitoring of lead-based paint exposure.

Although, there are regulations and standards in place to protect against the accidental release of asbestos and lead-based paints and other hazardous materials during demolition, there could be potentially unknown sources of surface or subsurface hazardous materials on development sites that may be subject to a release during development .

In the unlikely event of upset or accidental release, mandated protocols for reporting the release, notifying the public, and remediating the event (if determined necessary by regulatory agencies) are intended to reduce public risks. Specifically, the risks associated with the accidental release of hazardous materials would be managed through the implementation of AB 3205, California Hazardous Waste Control Law, California H&SC, California Fire Code, and RCRA regulations.

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Potentially significant impacts associated with the accidental release of unknown hazardous materials during future construction would be reduced to a level less than significant through implementation of the mitigation framework HAZ-1.

MM-HAZ-1: Applications for future development in the Rezone Sites, wherein the City has determined a potential for impacts to known and unknown hazardous materials sites, shall be required to comply with the following mitigation framework.

Future projects shall be required to identify potential conditions, which require further regulatory oversight and demonstrate compliance based on the following measures prior to issuance of any permits.

A. A Phase I Environmental Site Assessment (ESA) shall be completed in accordance with American Society of Testing and Materials (ASTM) Standards. If hazardous materials are identified requiring remediation, a Phase II ESA and
remediation effort shall be conducted in conformance with federal, state, and local regulations.

B. If the Phase II ESA identifies the need for remediation, then the following shall occur prior to the issuance of grading permits:

1. The applicant shall retain a qualified environmental engineer to develop a soil and/or groundwater management plan to address the notification, monitoring, sampling, testing, handling, storage, and disposal of contaminated media or substances (soil, groundwater). The qualified environmental consultant shall monitor excavations and grading activities in accordance with the plan. The plans shall be approved by the City prior to development of the site.

2. The applicant shall submit documentation showing that contaminated soil and/or groundwater on proposed
development parcels have been avoided or remediated to
meet cleanup requirements established by appropriate local regulatory agencies (Regional Water Quality Control Board [RWQCB]/DTSC/DEH) based on the future planned land use
of the specific area within the boundaries of the site (i.e., commercial, residential), and that the risk to human health of future occupants of these areas therefore has been reduced to below a level of significance.

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3. The applicant shall obtain written authorization from the appropriate regulatory agency (RWQCB/DTSC/DEH)
confirming the completion of remediation. A copy of the authorization shall be submitted to the City to confirm that all appropriate remediation has been completed and that the proposed development parcel has been cleaned up to the
satisfaction of the regulatory agency. In the situation where previous contamination has occurred on a site that has a previously closed case or on a site included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, the DEH shall be notified of the
proposed land use.

4. All cleanup activities shall be performed in accordance with all applicable federal, state, and local laws and regulations, and required permits shall be secured prior to commencement of construction to the satisfaction of the City and compliance with applicable regulatory agencies such as but not limited to the City of Santee Municipal Code.

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The City Council finds that MM-HAZ-1 is feasible, is adopted, and will further reduce impacts related to accident or upset. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section
15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project regarding accident or upset, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to accident or upset. (Draft PEIR, pp. 4.7-19 through 4.7-20.)
F. NOISE

1. Noise Standards
Threshold: Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Finding: Less than significant with mitigation. (Draft PEIR, pp. 4.10-21 through 4.10-35)
Explanation: Vehicle Traffic Noise – Land Use Compatibility.

Sites 1 through 10
Sites 1 through 10 are located off Summit Avenue and Summit Crest Avenue, north of SR-52 and northwest of SR-67. Sites 1 through 10 have a total development potential of 124 multi-family units. Future noise levels are projected to exceed 65 dB(A) Ldn only immediately adjacent to Summit Avenue. To accommodate project access, Summit Avenue would need to be improved and the 65 dB(A) Ldn noise contour may fall within the Summit Avenue right-of-way.

Development of Sites 1 through 10 would require future discretionary review. Any siting of new noise-sensitive land uses within a noise environment that exceeds the normally acceptable land use compatibility criterion represents a potentially significant impact and would require a separate noise study through the development review process to determine the level of impacts and required mitigation. Noise Element Policy 2.1 would require that future development include noise control for exterior and interior living spaces of all new residential development. Section 8.0 of the Noise Element provides implementation measures that may be
incorporated into a project to reduce noise levels. Additionally, as required by the CCRs, future ministerial and discretionary projects would be required to demonstrate that interior noise levels would be Findings

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reduced to 45 dB(A) Ldn or less. However, absent a specific development proposal with site designs, the potential for shielding of exterior use areas cannot be known at this programmatic level of review. Therefore, due to the siting of new noise-sensitive land uses in an area that may exceed normally acceptable land use compatibility criterion due to transportation noise sources, a significant impact would result.

Sites 11 and 12
Sites 11 and 12 are located off Conejo Road, north of SR-52 and northwest of SR-67. Site 11 has the potential to be developed with eight multi-family units, and Site 12 has the potential to be developed with six multi-family units. These sites are located well outside the 65 dB(A) Ldn noise contour. Noise levels would be less than the City’s normally acceptable noise standard, and impacts would be less than significant.

Site 15
Site 15 is located north of SR-52, on Town Center Parkway within the Santee Town Center. Site 15 has the potential to be developed with 115 multi-family units. The driveway access to Site 15 is located within the 65 dB(A) Ldn noise contour for Mission Gorge Road, however, the developable area of Site 15 is located outside the dB(A) Ldn noise contour. These noise contours do not take into account shielding provided by the buildings located between the site and the adjacent roadways. Therefore, actual future noise levels at the project site would be less than shown. Noise levels at Site 15 would be compatible with the City’s noise normally acceptable noise standard of 65 dB(A) Ldn, and noise impacts would be less than significant.

Site 15 is eligible for by-right development. Since noise levels would be less than 65 dB(A) Ldn, no noise reduction measures would be required.

Sites 16A and 16B
Sites 16A and 16B are located north of SR-52 and west of SR-67, off Civic Center Drive near town center. Site 16A has the potential to be developed with 333 multi-family units, and Site 16B has the potential to be developed with 120 multi-family units. Additionally, Site 16A could include ground-floor retail uses. Sites 16A and 16B are located outside the 65 dB(A) Ldn noise contour. Noise levels would be less than the City’s normally acceptable noise standard, and impacts would be less than significant.

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Site 16A is eligible for by-right development. Since noise levels would be less than 65 dB(A) Ldn, no noise reduction measures would be required.

Sites 17 and 18
Sites 17 and 18 are located off Cottonwood Avenue, north of SR-52 and west of SR-67. Site 17 has the potential to be developed with 279 multi-family units, and Site 18 has the potential to be developed with 98 multi-family units. Park Center Drive currently terminates in a cul-du-sac at the western boundary of Site 18 and northern boundary of Site 17. The future circulation element roadway plan includes extensions through these sites, and those roadway extensions were reflected in the future year 2050 SANDAG traffic modeling. Future noise levels are projected to exceed 65 dB(A) Ldn only immediately adjacent to these future roadway extensions, and the 65 dB(A) Ldn noise contour may fall within the roadway right-ofway. Future noise levels at the majority of Sites 17 and 18 would be less than 65 dB(A) Ldn. Noise levels would not exceed the conditionally acceptable noise standard of 70 dB(A) Ldn. Sites 17 and 18 are eligible for by-right development. Under the current circulation element roadway system, exterior noise levels would not exceed 65 dB(A) Ldn, and no noise reduction measures would be required. Should the roadway extensions be included in the future project design, noise levels would exceed 65 dB(A) Ldn immediately adjacent to the roadways, but would not exceed 70 dB(A) Ldn.

At any specific location, the actual existing noise would depend upon not only the source noise level but also the nature of the path from the source to the sensitive receptor. Buildings, walls, dense vegetation, and other barriers would block the direct line of sight and reduce noise levels at the receptor. As an example, a first row of buildings would reduce traffic noise levels at receptors by 3 to 5 dB(A) behind those structures depending on the building-to-gap ratio. Large continuous structures can provide substantially greater attenuation of traffic noise. Additionally, due to the provision of common exterior use areas, multi-family residential land uses can generally provide greater shielding to these areas, thus providing exterior use areas that comply with the compatibility guidelines.

Any siting of new noise-sensitive land uses within a noise environment that already exceeds the normally acceptable land use compatibility criterion represents a potentially significant impact and would require a separate noise study through the development review process to determine the level of impacts and required mitigation. Noise Element Policy 2.1 would require that future development include noise control for exterior and interior living Findings

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spaces of all new residential development. Section 8.0 of the Noise Element provides implementation measures that may be
incorporated into a project to reduce noise levels. Additionally, as required by the California Code of Regulations, future ministerial and discretionary projects would be required to demonstrate that interior noise levels would be reduced to 45 dB(A) Ldn or less. However, absent a specific development proposal with site designs, the potential for shielding of exterior use areas cannot be known at this programmatic level of review. Therefore, due to the siting of new noise-sensitive land uses in an area that may exceed normally acceptable land use compatibility criterion due to transportation noise sources, a significant impact would result.

Site 19
Site 19 is off Park Center Drive, north of SR-52 and west of SR-67.

Site 19 has the potential to be developed with 32 multi-family units.

Site 19 is eligible for by-right development. Site 19 is located outside the 60 dB(A) Ldn noise contour. Noise levels would be less than the City’s normally acceptable noise standard, and impacts would be less than significant. Since noise levels would be less than 65 dB(A) Ldn, no noise reduction measures would be required.

Sites 20A and 20B
Sites 20A and 20B are located west of SR-67 and north of SR-52, along Magnolia Avenue. Site 20A has the potential to be developed with 170 multi-family units, and Site 20B has the potential to be developed with 300 multi-family units. Additionally, Site 20B could include ground-floor retail uses. Future exterior noise levels are projected to exceed 65 dB(A) Ldn at the eastern portion of the sites adjacent to Magnolia Avenue. As with Sites 17 and 18, due to the provision of common exterior use areas, multi-family residential land uses can generally provide greater shielding to these areas, thus providing exterior use areas that comply with the compatibility guidelines. However, absent a specific development proposal with site designs, the potential for shielding of exterior use areas cannot be known at this programmatic level of review. Therefore, due to the siting of new noise-sensitive land uses in an area that may exceed normally acceptable land use compatibility criterion due to transportation noise sources, a significant impact would result.

Site 24
Site 24 is located at 9953 Buena Vista Avenue, north of SR-52 and west of SR-67. Site 24 has the potential to be developed with 105 multi-family units, and is eligible for by-right development. Future exterior noise levels are projected to exceed 65 dB(A) Ldn due to vehicle traffic on SR-52. It should be noted that SR-52 is elevated Findings

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above Site 24 and includes a concrete masonry wall between the project site and SR-52. The noise contours due not take into account the difference in elevation or the shielding provided by the wall.

Therefore, noise levels at Site 24 are less than represented in Figure

4.10-5.7 of the Draft PEIR. The measured noise levels at Site 24 were 56.7 and 65.2 dB(A) Leq. As with other identified sites with the potential to exceed 65 dB(A) Ldn, due to the provision of common exterior use areas, multi-family residential land uses can generally provide greater shielding to these areas, thus providing exterior use areas that comply with the compatibility guidelines. However, absent a specific development proposal with site designs, the potential for shielding of exterior use areas cannot be known at this programmatic level of review. Therefore, due to the siting of new noise-sensitive land uses in an area that may exceed normally acceptable land use compatibility criterion due to transportation noise sources, a significant impact would result.

Site 25
Site 25 is located at 8801 Olive Lane, north of SR-52 and east of SR67. Site 25 has the potential to be developed with 41 multi-family units. Future exterior noise levels are projected to exceed 65 dB(A) Ldn due to vehicle traffic on SR-52. It should be noted that SR-52 is elevated above Site 25. The noise contours do not take into account the difference in elevation, or shielding provided by buildings located between the site and SR-52. Therefore, noise levels at Site 25 are less than represented in Figure 4.10-5.8 of the Draft PEIR. Absent a specific development proposal with a detailed site plan and site specific noise modeling, the potential for exterior use areas to be designed to meet noise standards cannot be known at this programmatic level of review. Therefore, due to the siting of new noise-sensitive land uses in an area that may exceed normally acceptable land use compatibility criterion due to transportation noise sources, a significant impact would result.

Sites 29 and 30
Site 29 is located at 7737 Mission Gorge Road, west of SR-52. Site 30 is located directly next to Site 29 at 8714 Starpine Drive. Site 29 has the potential to be developed with 64 multi-family units, and Site 30 has the potential to be developed with 28 multi-family units. Future exterior noise levels are projected to exceed 65 dB(A) Ldn at the northern half of Site 29 due to vehicle traffic on Mission Gorge Road.

Noise levels would be less than 65 dB(A) Ldn at the southern half of Site 29 and all of Site 30. Noise levels at Site 30 would be less than the City’s normally acceptable noise standard, and impacts would be less than significant. Since noise levels would be less than 65 dB(A) Ldn, no noise reduction measures would be required for Site 30.

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However, future development at Site 29 could exceed exterior noise standards. Absent a specific development proposal with a detailed site plan and site-specific noise modeling, the potential for exterior use areas to be designed to meet noise standards cannot be known at this programmatic level of review. Therefore, due to the siting of new noise-sensitive land uses in an area that may exceed normally acceptable land use compatibility criterion due to transportation noise sources, a significant impact would result with respect to Site

29. Site 35
Site 35 is located northwest of SR-67 and north of SR-52, adjacent to the termini of Mast Boulevard. Mast Boulevard does not currently connect adjacent to the project site, but a connection is identified in the future year 2050 SANDAG traffic modeling. However, City Council adopted a policy in 2017 to not extend Mast Boulevard.

Therefore, noise levels would be less than those identified in Figure

4.10-5.10 of the Draft PEIR. Site 35 has the potential to be developed with 122 multi-family units, and would be eligible for by-right development. Future noise levels are not projected to exceed 65 dB(A) Ldn at Site 35. The future 65 dB(A) Ldn noise contour for the Mast Boulevard connection would lie within the roadway right-ofway. Noise levels would be less than the City’s normally acceptable noise standard, and impacts would be less than significant. Since noise levels would be less than 65 dB(A) Ldn, no noise reduction measures would be required.

As discussed, exterior noise levels are projected to exceed 65 dB(A) Ldn at the following Rezone Sites: Sites 1 through 10, Sites 17 and 18, Sites 20A and 20B, Site 24, Site 25, and Site 29. Impacts to sensitive receivers from exterior noise levels from vehicle traffic would be significant. With implementation of MM-NOS-1, and implementation of the General Plan policies and implementation measures listed above, impacts from transportation noise sources would be reduced to less than significant.

Regarding interior noise, as required by the CCRs, future ministerial and discretionary projects would be required to demonstrate that interior noise levels would be reduced to 45 dB(A) Ldn or less.

Therefore, vehicle traffic noise affecting building interiors would be less than significant.

Construction Noise
Future development implemented under the project could result in a temporary ambient noise increase due to construction activities.

Construction noise typically occurs intermittently and varies Findings

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depending upon the nature or phase of construction (e.g., demolition; land clearing, grading, and excavation; erection). Construction noise would be short term and would include noise from activities such as site preparation, truck hauling of material, pouring of concrete, and the use of power tools. Noise would also be generated by construction equipment use, including earthmovers, material handlers, and portable generators, and could reach high noise levels for brief periods. Significant noise impacts may occur from operation of heavy earthmoving equipment and truck haul that would occur with construction of individual development projects. Implementation of the project anticipates an increase in development intensity.

The City’s Municipal Code Section 5.04.090 regulates noise associated with construction equipment and activities through time of day restrictions (e.g., days of the week and hours of operation), and requires that notice be given when construction equipment with a manufacturer’s noise rating of 85 dB(A) Lmax will operate at a specific location for 10 consecutive workdays. Future development at the Rezone Site would be subject to this standard.

Hourly average noise levels would be approximately 83 dB(A) Leq at 50 feet from the center of construction activity when assessing three pieces of common construction equipment working simultaneously.

Noise levels would vary depending on the nature of the construction activities including the duration of specific activities, the equipment involved, the location of the sensitive receivers, and the presence of intervening barriers. Using a construction equipment noise level of 83 dB(A) Leq at 50 feet, construction noise level contours for the sites that would have the potential to be developed ministerially were calculated. Construction noise levels would generally range from 65 to 75 dB(A) Leq near the project boundaries.

Construction of individual developments associated with potential future development at Rezone Sites would temporarily increase the ambient noise environment in the vicinity of each individual project.

Because construction activities associated with any individual development may occur near noise-sensitive receptors and depending on the project type noise disturbances may occur for prolonged periods of time, construction noise impacts associated with potential future development at Rezone Sites are considered significant.

Although residences adjacent to the Rezone Sites would be exposed to construction noise levels that could be heard above ambient conditions, the exposure would be temporary. Both discretionary and ministerial project would be required to adhere to the time of day Findings

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restrictions and notification requirements of Santee Municipal Code Section 5.04.090. However, construction activities associated with any individual development may occur near noise-sensitive receptors. Depending on the equipment list, time of day, phasing, and overall construction durations, noise disturbances may occur for prolonged periods of time or during the more sensitive nighttime hours. Therefore, construction noise impacts would be considered potentially significant. Without project-specific information to evaluate potential construction noise impacts and specific distances to sensitive receptors, impacts are considered significant at this programmatic level of review With implementation of MM-NOS-2, impacts associated with construction noise would be reduced to less than significant.

MM-NOS-1: Applications for future development, where the City has determined a potential for land use compatibility impacts related to vehicle traffic, shall be required to comply with the following mitigation measure:

Prior to the issuance of a permit to develop at the Rezone Sites, the City shall assess whether proposed noise-sensitive receivers or associated noise-sensitive exterior use areas would be subject to transportation noise levels that potentially conflict with policies established in the City’s General Plan. Based on the analysis herein, the following sites are anticipated to require implementation of this measure: Sites 1 through 10, Sites 17 and 18, Sites 20A and 20B, Site 24, Site 25, and Site 29. Where noise levels would potentially conflict with City policies, the City shall require preparation of a noise technical analysis by a qualified professional that demonstrates (1) noise levels would not exceed the City’s General Plan Noise Element compatibility guidelines, or (2) noise levels which already exceed the levels considered compatible for that use are not increased by 3 dB or more. In lieu of detailed analysis, the City will accept information demonstrating that noise reduction techniques have been incorporated that would reduce noise levels at exterior use areas consistent with City standards Noise reduction techniques may include site design (including building orientation) that provides noise barriers free of gaps and obstructs line-of-sight between the source and receiver, and has a weight of at least 2 pounds per square foot, or other noise reduction technique as applicable.

MM-NOS-2: The City shall review applications for future development to determine applicability of a Construction Noise Best Management Plan. An applicant may provide site-specific noise generation information demonstrating that construction activities will not exceed 75 dB at the nearest sensitive receptor. If this site-specific information is not provided, a construction best management plan Findings

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shall be required when the construction site is located within 150 feet of a sensitive receptor. The criteria of 150 feet is provided as a screening tool for use by the City, based on an average construction noise level of 83 dB, attenuating to 75 dB at 150 feet.

Construction Noise Best Management Practice Plan
Where applicable based on the criteria provided above, the City shall require preparation and implementation of a best management practice plan that demonstrates how noise levels would be minimized to comply with the time of day restrictions and notification requirements of Santee Municipal Code Section 5.04.090.

Noise reduction measures can include, but are not limited to, the following:

1. Construction equipment with a manufacturer’s noise rating of 85 dB(A) Lmax or greater may only operate at a specific location for 10 consecutive workdays. If work involving such equipment would involve more than 10 consecutive workdays, a notice must be provided to all property owners and residents within 300 feet of the site no later than 10 days before the start of construction.

The notice must be approved by the City and describe the proposed project and the expected duration of work and provide a point of contact to resolve noise complaints.

2. Idling times for noise-generating equipment used in demolition, construction, site preparation, and related activities shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes.

3. Demolition, construction, site preparation, and related activities within 100 feet from the edge of properties with existing, occupied noise-sensitive uses shall incorporate all feasible strategies to reduce noise exposure for noise-sensitive uses, including:
a. Provide written notice to applicable noise-sensitive land uses at least two weeks prior to the start of each
construction phase of the construction schedule;
b. Ensure that construction equipment is properly maintained and equipped with noise control components, such as
mufflers, in accordance with manufacturers’ specifications; c. Re-route construction equipment away from adjacent
noise-sensitive uses;
d. Locate noisy construction equipment away from
surrounding noise-sensitive uses;
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e. Use sound aprons or temporary noise enclosures around noise-generating equipment;
f. Position storage of waste materials, earth, and other supplies in a manner that will function as a noise barrier for surrounding noise-sensitive uses;
g. Use the quietest practical type of equipment;
h. Use electric powered equipment instead of diesel or
gasoline engine powered equipment;
i. Use shrouding or shielding and intake and exhaust
silencers/mufflers; and
j. Other effective and feasible strategies to reduce
construction noise exposure for surrounding noisesensitive uses.

4. For construction of buildings that require the installation of piles, an alternative to installation of piles by hammering shall be used where sensitive receptors are located within 150 feet. This could include the use of augured holes for cast-in-place piles, installation through vibration or hydraulic insertion, or another low-noise technique.

The City Council finds that MM-NOS-1 and MM-NOS-2 are feasible, are adopted, and will further reduce impacts related to noise.

Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to noise, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to noise. (Draft PEIR, pp. 4.10-45 through 4.10-46.)

2. Vibration
Threshold: Would the Project result in the exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Finding: Less than significant with mitigation. (Draft PEIR, pp. 4.10-47 through 4.10-48)
Explanation: Vibration generated by construction equipment has the potential to be substantial, since it has the potential to exceed the FTA criteria for architectural damage (FTA 2018). Construction details and equipment for future project-level development is not known at this Findings

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time. Therefore, construction vibration impacts would be considered potentially significant.

Construction details, locations, and equipment for future project-level developments under the project are not known at this time but may cause vibration impacts. Impacts related to vibration associated with future development within the Rezone Sites would be potentially significant.

Implementation of the controls outlined in MM-NOS-3 would ensure future development with the potential to generate substantial vibration implement a plan to ensure vibration thresholds are not exceeded during construction. With implementation of MM-NOS-3, impacts related to groundborne vibration would be reduced to less than significant.

MM-NOS-3: Applications for future development, where the City has determined a potential for vibration impacts in relation to sensitive receptors, shall be required to comply with the following mitigation measure:

Prior to the issuance of a permit to develop at the Rezone Sites, the City shall determine whether the construction process will require equipment or activities that may result in vibration, such as pile driving. For projects requiring pile driving during construction within 135 feet of fragile structures, such as historical resources, 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no plaster); or a vibratory roller within 25 feet of any structure, the project applicant shall prepare a noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these activities. These distances are based on reference vibration levels generated by pile drivers and vibratory rollers and standard vibration propagation rates as published by the Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual (FTA 2018). This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed Federal Transit Administration architectural damage thresholds (e.g., 0.12 inches per second [in/sec] peak particle velocity [PPV] for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, and static rollers as opposed to vibratory rollers, shall be used. If necessary, Findings

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construction vibration monitoring shall be conducted to ensure vibration thresholds are not exceeded.

The City Council finds that MM-NOS-3 is feasible, is adopted, and will further reduce impacts related to vibration. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to vibration, as identified in the EIR.

Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to vibration. (Draft PEIR, pp. 4.10-48 through 4.10-49.)
G. TRIBAL CULTURAL RESOURCES

1. Tribal Cultural Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: (i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or (ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in Public Resources Code section 5024.1?
Finding: Less than significant with mitigation. (Draft PEIR, pp. 4.4-15 through

4.4-16)
Explanation: The evaluation of potential impacts to tribal cultural resources analysis within the Rezone Sites followed one of two different levels of analysis. Those sites identified for eligibility for by-right development including Sites 15, 16A, 17, 18, 20B and 24, along with the two Graves Avenue sites were evaluated at a site-specific level, including completion of cultural resource surveys to identify the potential for archaeological resources. The remainder of the Rezone Sites are discussed using a programmatic analysis, with the expectation that future discretionary review and associated sitespecific analysis would be required prior to development.

There are eight parcels within the Moderate Potential for Register Eligible Buried Archaeological Sites and 10 parcels within the Findings

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Moderate Potential for Register Eligible Archaeological Sites. These sites are located within areas with higher potential to encounter Register Eligible resources either on the surface or during ground disturbance activities.

The records search identified one historic-period archaeological (CASDI-22504) site within four Rezone Sites. This resource was determined not eligible for listing on the CRHR; therefore, future development would not result in a significant impact. The records search and survey also identified one prehistoric resource (CA-SDI5669) and one isolated artifact within a Rezone Site. The isolated artifact does not possess the characteristics to qualify as significant under CEQA. The prehistoric resource could potentially be significant and would require further testing and excavation to determine its CEQA significance. Based on the fact that there is no development proposed at the site with the potentially significant prehistoric resource, archaeological testing has not been completed at this program level of review. An appropriate testing program would need to be developed concurrent with a specific project application to take into consideration the project footprint and potential for avoidance of resources. Therefore, future development would have the potential to directly or indirectly impact potentially significant archaeological resources. The location of potential archaeological sites is undisclosed for confidentiality per 14 California Code of Regulations Section 15120 (d); however, the City maintains a record of the survey results and is able to use these findings to determine applicability of mitigation measures.

Additionally, there is a possibility of unknown subsurface deposits to be present within the Rezone Sites because of the thousands of years of use of the northern El Cajon Valley. Such buried sites would be composed of the same artifacts as surface deposits such as projectile points, scrapers, milling implements (manos and metates), flakes, and possibly animal bone and marine shell. While the project does not specifically propose alteration of the known archaeological resource or ground-disturbing activities such as grading or excavation, future development within the Rezone Sites would have the potential to directly or indirectly impact undiscovered subsurface archaeological resources that have not been evaluated. Policies 8-1 and 8.2 of the City’s General Plan (2003) are aimed at the protection of prehistoric sites. As future projects are planned, they would be required to adhere to these policies and regulations through a discretionary review or a ministerial development review process.

Additionally, for certain environmental documents, AB 52 requires early consultation with culturally affiliated tribes in the area that request consultation. However, because site-specific details are not Findings

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known at this program-level of analysis, potential impacts to archaeological resources or tribal cultural resources would be significant.

Potential direct and/or indirect impacts to tribal cultural resources would be potentially significant. Impacts to surface and subsurface archaeological resources within the Rezone Sites would be mitigated through the implementation of MM-CUL-2 and MM-CUL-3, that would require significance evaluation of archaeological resources, mitigation for potential impacts to these resources, and a requirement for archaeological and Native American construction monitoring to avoid significant impacts to unknown buried archaeological resources. Implementation of MM-CUL-2 and MMCUL-3 would reduce impacts to a less than significant level.

The City Council finds that MM-CUL-2 and MM-CUL-3 are feasible, are adopted, and will further reduce impacts related to tribal cultural resources. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to tribal cultural resources, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to tribal cultural resources. (Draft PEIR, pp.

4.4-16 through 4.4-18.)
H. UTILITIES AND SERVICE SYSTEMS

1. Wastewater Treatment Requirements
Threshold: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Finding: Less than significant with mitigation. (Draft PEIR, pp. 4.14-15 through 4.14-17)
Explanation: Water. Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing water utility infrastructure. Expansion of water infrastructure is not anticipated to adequately serve future development beyond lateral connections to serve individual projects. While future Rezone Sites would require connection to existing water pipelines, localized water Findings

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utility infrastructure improvements and relocations would be evaluated upon submittal of project specific development plans. All future project applications, whether discretionary or ministerial would be required to comply with relevant City regulations and adhere to the mitigation framework presented in this PEIR, including MM-VIS1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-1,
MM-NOS-1 through MM-NOS-3, and MM-TRA-1, which would
ensure that any physical impacts associated with construction of pipeline connections to existing water infrastructure would be addressed as part of the City review for each individual project.

Additionally, future projects would be required to comply with General Plan policies including Land Use Element Policy 3.6, which requires the review of development projects to ensure that all necessary utilities are available to serve the project.

Wastewater. Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing wastewater utility infrastructure and no expansion of existing facilities would be required to serve the project. Although future Rezone Sites would require localized connection to existing wastewater pipelines, wastewater utility infrastructure improvements and relocations would be evaluated upon submittal of project specific development plans.

All future project applications, whether discretionary or ministerial would be required to comply with relevant City regulations and adhere to the mitigation framework presented in this PEIR, including MM-VIS-1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1
through MM-CUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MMHAZ-1, MM-NOS-1 through MM-NOS-3, and MM-TRA-1, which would ensure that any physical impacts associated with construction of pipeline connections to wastewater infrastructure would be addressed as part of the City review for each individual project.

Additionally, future projects would be required to comply with General Plan policies including Land Use Element Policy 3.6, which requires the review of development projects to ensure that all necessary utilities are available to serve the project.

Stormwater. Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing stormwater infrastructure. Existing stormwater infrastructure would be able to accommodate post project stormwater flows considering existing requirements for detention and on-site infiltration. Although future Rezone Sites would require connection to existing stormwater facilities, localized stormwater infrastructure improvements would be evaluated upon submittal of project specific development plans. All future project applications, whether discretionary or ministerial would Findings

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be required comply with relevant City regulations and adhere to the mitigation framework presented in this PEIR, including MM-VIS-1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1 through MMCUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-1, MMNOS-1 through MM-NOS-3, and MM-TRA-1, which would ensure that any physical impacts associated with construction of pipeline connections to existing water infrastructure would be addressed as part of the City review for each individual project. Additionally, future projects would be required to comply with General Plan policies including Land Use Element Policy 3.6, which requires the review of development projects to ensure that all necessary utilities are available to serve the project.

It is further noted that future projects would be required to design all on-site storm water facilities to comply with the City’s BMP Design Manual. Adherence to the BMP Design Manual ensures new
development and redevelopment provide adequate storm water facilities that are compatible with existing City systems and conform to all performance standards presented in the MS4 permit. Physical impacts of all utility improvements would be addressed as part of the future project-specific applications and appropriate mitigation for impacts would be applied consistent with this PEIR.

Electric Power, Natural Gas, and Telecommunications.

Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing electrical, natural gas, and telecommunications utility infrastructure. Although future Rezone Sites would require connection to these existing facilities, localized utility infrastructure improvements and relocations would be evaluated upon submittal of project specific development plans. All future project applications, whether discretionary or ministerial would be required to comply with relevant City regulations and adhere to the mitigation framework presented in this PEIR, including MM-VIS1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-1,
MM-NOS-1 through MM-NOS-3, and MM-TRA-1, which would
ensure that any physical impacts associated with construction of connections to existing electrical, natural gas, and
telecommunications utility infrastructure would be addressed as part of the City review for each individual project. Additionally, future projects would be required to comply with General Plan policies including Land Use Element Policy 3.6, which requires the review of development projects to ensure that all necessary utilities are available to serve the project.

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Mitigation is proposed for implementation of both discretionary and by-right development projects. Mitigation would be either be applied during a future discretionary review or for by-right development, would be applied as a requirement of the City’s objective design and performance standards adopted as part of the project. Future development of Rezone Sites would require implementation of the following mitigation framework:

See MM-VIS-1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL1 through MM-CUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-1, MM-NOS-1 through MM-NOS-3, and MM-TRA-1.

Impacts associated with the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities would be would be reduced to a level less than significant with implementation of the mitigation framework MM-VIS-1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1,
MM-GHG-1 and MM-GHG-2, MM-HAZ-1, MM-NOS-1 through MMNOS-3, and MM-TRA-1.

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The City Council finds that MM-VIS-1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1, MM-GHG1 and MM-GHG-2, MM-HAZ-1, MM-NOS-1 through MM-NOS-3, and MM-TRA-1 are feasible, are adopted, and will further reduce impacts related to utilities. Accordingly, the City Council finds that, pursuant to Public Resources Code section 21081(a)(1) and State CEQA Guidelines section 15091(a)(1), changes or alterations have been required in, or incorporated into, the proposed Project that mitigate or avoid the potentially significant impacts of the proposed Project to utilities, as identified in the EIR. Therefore, impacts are considered less than significant. Mitigation measures will further reduce impacts related to utilities. (Draft PEIR, p. 4.14-17.)
SECTION IV.

IMPACTS THAN CANNOT BE FULLY MITIGATED TO A LESS THAN SIGNIFICANT LEVEL
The City Council hereby finds that, despite the incorporation of Mitigation Measures identified in the EIR and in these Findings, the following environmental impacts cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein:

A. AIR QUALITY

1. Air Quality Plans and Air Quality Standards
Threshold: Would the Project conflict with or obstruct implementation of the applicable air quality plan; violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Finding: Significant and unavoidable. (Draft PEIR, pp. 4.2-15 through 4.2-17) Explanation: The project would result in additional housing opportunities throughout the City consistent with the Regional Housing Needs Assessment. The project would also result in increased commercial opportunity within the Graves Avenue sites compared to what is allowed under current General Plan and Zoning regulations. When compared to the existing zoning and land use designations, the project would increase the development potential in the City, which would increase the amount of vehicle traffic generated in the City.

Although the project would increase the amount of traffic in the City, it would not result in an increase in the average VMT per capita. As concluded in the Transportation Impact Study, with the
implementation of the project, including buildout of the City’s General Findings

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Plan land use and transportation network, the average resident VMT per capita for the City is reduced from 20.5 (in base year 2016) to

18.7 VMT per capita, although this level of VMT per capita would still exceed the VMT significance threshold of 85 percent of the regional average. The City’s goal for residential land uses is to allow for the development of a wide range of housing types. This includes the development of higher density residential developments in areas close to multi-modal transportation facilities, transit stations, and along major corridors where transit and other convenience services and accommodating land uses are available. Additionally, new residential developments should provide adequate open space, recreational facilities, schools, interior circulation patterns and other amenities and facilities. By bringing in varied and complementary uses and a mobility network that supports and encourages walking, biking and taking transit, the project could contribute to a more VMT efficient and sustainable future for the community. However, because buildout of the project would result in an increase in development and an increase in traffic generation over what would occur under buildout of the adopted zoning and land use designations, the project would result in an increase in emissions that are not already accounted for in the RAQS.

Future development at the Rezone Sites would result in an increase in development and an increase in traffic generation over what would occur under buildout of the adopted zoning and land use designations, and would therefore result in an increase in emissions.

Therefore, buildout of the project would exceed the assumptions used to develop the RAQs, resulting in a significant impact.

The project would be inconsistent with the RAQs because buildout of the Rezone Sites would exceed the population estimates assumed for the RAQs. This impact is based on plan inconsistency only as emissions with the project would not exceed stated thresholds. As a result, no mitigation measures are available that would reduce impacts associated with inconsistency with the RAQs. The inconsistency with the RAQS would remain until the RAQs are revised and incorporate the growth projections with the project.

Impacts would be significant and unavoidable.

2. Cumulatively Considerable Pollutant Emissions
Threshold: Would the Project result in cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? Finding: Significant and unavoidable. (Draft PEIR, pp. 4.2-17 through 4.2-22) Findings

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Explanation: Construction. Construction emissions were calculated for development of the Rezone Sites that are eligible for by-right development. The construction of all the Rezone Sites would not necessarily occur simultaneously. For assessing the significance of the air quality emissions, the construction emissions were compared to the SDAPCD screening levels. The emissions associated with construction of the Rezone Sites that are eligible for by-right development would be less than the applicable thresholds for all criteria pollutants. As noted, the greatest amount of development would occur on Site 16A. Since construction emissions would be less than the applicable thresholds for Site 16A, it can be concluded that emissions associated with construction of each of the Rezone Sites would also be less than the applicable thresholds. Thus, construction of any individual site would be less than significant. However, if development of multiple sites were to occur simultaneously, there is the potential to exceed significance thresholds.

Future development of the Rezone Sites, whether processed through the City’s discretionary process or ministerially, would be required to implement construction Best Management Practices at all construction sites consistent with SDAPCD rules and regulations and the City’s standard project conditions of approval. The following regulatory requirements would be required for all construction activities:
• Construction activities will be conducted in compliance with California Code of Regulations, Title 13, Section 2449, which requires that nonessential idling of construction equipment be restricted to five minutes or less.
• Construction activities will be conducted in compliance with any applicable SDAPCD rules and regulations, including but not limited to:
o 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.
o Rule 52, Particulate Matter: establishes limits to the discharge of any PM from non­stationary sources.
o Rule 54, Dust and Fumes: establishes limits to the
amount of dust or fume discharged into the
atmosphere in any 1 hour.

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

Approval of the project would not specifically permit the construction of an individual project, and no specific development details are available at this program level of analysis. The thresholds presented above would be applied to future development within the City on a project-by-project basis and are not used for assessment of regional planning impacts. The information is presented to illustrate the potential scope of air impacts for a site-specific project that could be developed in the future. Additionally, the regulations at the federal, state, and local level provide a framework for developing projectlevel air quality protection measures for future projects.

While individual site-specific projects may not exceed the SDAPCD regional significance thresholds, the scale and extent of construction activities associated with buildout of the Rezone Sites may result in some instances where future development would occur
simultaneously resulting in a cumulative impact. Therefore, cumulative construction­related regional air quality impacts would be potentially significant.

Operation. Air pollutant emissions were calculated for the existing condition and for buildout potential of the Rezone Sites, as well as individual buildout of the Rezone Sites that would be eligible for byright development. Operational emissions associated with the Rezone Sites that would be eligible for by-right development would be less than the applicable project-level screening thresholds for all criteria pollutants. As noted, the greatest amount of development would occur on Site 16A. Since operational emissions would be less than the applicable thresholds for Site 16A, it can be concluded that emissions associated with operation of each individual Rezone Site would also be less than the applicable thresholds, and project-level impacts would be less than significant.

Generally, discretionary, program-level planning activities, such as general plans, community plans, specific plans, housing elements etc., are evaluated for consistency with the local air quality plan. In contrast, project-level thresholds are applied to individual projectspecific approvals, such as a proposed development project.

Therefore, the analysis of the buildout of the Rezone Sites is based Findings

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on the future emissions estimates and related to attainment strategies derived from the adopted land use plan. At the program level, the analysis compares the development potential and associated emissions of Rezone Sites buildout to the development potential under buildout of the existing zoning designations to determine if the emissions would exceed the emissions estimates included in the RAQS, and to determine whether it would obstruct attainment, or result in an exceedance of AAQS. As such, this analysis evaluates the potential for future development within the Rezone Sites to result in a cumulatively considerable net increase in emissions based on consistency with the RAQS. Buildout of the Rezone Sites would result in an increase in development and an increase in traffic generation over what would occur under buildout of the adopted zoning and land use designations, and would therefore result in an increase in emissions. Therefore, buildout of the Rezone Sites would exceed the assumptions used to develop the RAQs. At the program level, because the project would conflict with implementation of the RAQS, air quality impacts related to the cumulative net increase in criteria pollutants would be significant.

Construction and operational emissions associated with the individual Rezone Sites (both those that would be eligible for by-right development and those that would require future discretionary review) would be less than the applicable project-level screening thresholds for all criteria pollutants. Therefore, project-level impacts for each individual Rezone Site would be less than significant.

However, the scale and extent of construction activities associated with buildout of the Rezone Sites may result in some instances where future development would occur simultaneously and would cumulatively exceed the relevant thresholds. Therefore, cumulative construction-related regional air quality impacts would be potentially significant.

When evaluating the project as a whole, buildout of the project would conflict with implementation of the RAQS. Operation of the project would result in a cumulatively considerable net increase in emissions compared to the emissions that would occur under existing land use designations.

Mitigation is proposed for implementation of both discretionary and by-right development projects. Mitigation would be either be applied during a future discretionary review or for by-right development, would be applied as a requirement of the City’s objective design and performance standards adopted as part of the project. Future development of Rezone Sites would require implementation of the following mitigation framework:

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MM-AQ-1: The City shall require project applicants to identify the measures that would be taken at the construction site to reduce construction-related criteria air pollutants such that they do not exceed the SDAPCD screening thresholds. Based on typical construction emissions, implementation of the following measures would be sufficient to reduce air pollutant emissions during construction:
• Requiring fugitive dust control measures that exceed
SDAPCD’s Rules 52, 54, and 55, such as:
o Requiring use of non-toxic soil stabilizers to reduce wind erosion.
o Applying water every four hours to active soildisturbing activities. o Tarping and/or maintaining a minimum of 24 inches of
freeboard on trucks hauling dirt, sand, soil, or other
loose materials.
• Using construction equipment rated by the United States Environmental Protection Agency as having Tier 3 (model year 2006 or newer) emission limits, applicable for engines between 50 and 750 horsepower.
• Ensuring construction equipment is properly serviced and maintained to the manufacturer’s standards.
• Limiting nonessential idling of construction equipment to no more than five consecutive minutes.
• Using Super-Compliant VOC paints for coating of
architectural surfaces whenever possible. A list of SuperCompliant architectural coating materials can be found on the SCAQMD’s website at:
http://www.aqmd.gov/prdas/brochures/SuperCompliant_AIM.pdf In regard to operational emissions, measures included as part of the Sustainable Santee Plan, such as expansion of the pedestrian and bicycle networks, installation of electric vehicle charging stations, and solar photovoltaics requirements, would also reduce criteria air pollutants within the City. However, because the project would exceed the growth projections used to develop the RAQS, no mitigation measures are available that would reduce impacts below the screening thresholds.

Buildout of the Rezone Sites would occur over a period of approximately 25 years or longer. Construction activities could Findings

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generate short-term emissions that individually would be less than the screening level thresholds, but cumulatively could exceed the thresholds and cumulatively contribute to the nonattainment designations of the SDAB. Implementation of mitigation measure AQ-1 would reduce criteria air pollutant emissions from constructionrelated activities to the extent feasible. However, construction time frames and equipment for site-specific development projects are not available at this time, and there is a potential for multiple development projects to be constructed at one time, resulting in significant construction-related emissions. Therefore, despite adherence to mitigation measure AQ-1, impacts associated with criteria pollutants would remain significant and unavoidable.

For operational emissions, because the significant air quality impact stems from an inconsistency between the project and the adopted land use plan upon which the RAQS is based, impacts would remain significant and unavoidable.

B. GREENHOUSE GAS EMISSIONS

1. Emissions Generation
Threshold: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Finding: Significant and unavoidable. (Draft PEIR, pp. 4.6-16 through 4.6-19) Explanation: The project includes adoption of a number of rezones to accommodate the City’s RHNA allocation. Because implementation of the rezones would ultimately result in increased density on sites that are currently underdeveloped as well as the development of parcels that are currently vacant, GHG emissions would increase upon project implementation. Approval of the project would not specifically permit the construction of an individual project, and no specific development details are available at this program level of analysis. As discussed above, for the purposes of this analysis, emissions were calculated for the existing condition and for buildout of all Rezone Sites. Additionally, a separate analysis was provided to address buildout of the Rezone Sites that would be eligible for byright development. Buildout of the Rezone Sites was modeled in year 2035 to align with the Sustainable Santee Plan emission projections and for the Housing Element buildout year 2050.

Buildout of the project would generate 22,665 MT CO2E in 2035 and 21,920 MT CO2E in 2050. Given the estimated service population, Findings

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this equates to 3.41 MT CO2E per service population in 2035 and

3.30 MT CO2E per service population in 2050. The emission reductions from 2035 to 2050 are associated with improved vehicle emissions through federal and state regulations and improved technologies. While the project would result in an increase in GHG emissions, climate change is occurring on a global scale; therefore, it is not possible to quantify the true effect of new GHG emissions caused by a single project or whether a project’s net increase in GHG emissions, when combined with other activities in the region, is cumulatively considerable. GHG emissions would be expected to decrease over the life of the project due to the fact that mobile emissions would decrease over time due to a more fuel-efficient vehicle fleet mix in the project area over the life of project implementation as well as the increase in renewable energy and netzero energy goals. When compared to the no project scenario, the project would result in an increase in GHG emissions due to the fact that the project proposes an increase in land use density at Rezone Sites which would involve emissions associated with vehicles, energy, are sources, water use, and waste generation.

Future housing development implemented under the proposed project would require compliance with the State Building Code energy efficiency and applicable green building standards.

Development plans would be reviewed at project intake to ensure the inclusion of all applicable energy efficiency and applicable green building requirements of the applicable building and energy codes.

Additionally, both future ministerial and discretionary development would be required to demonstrate with Sustainable Santee Plan GHG reduction measures through completion of the Consistency Checklist. Individual projects would be required to complete the Consistency Checklist as part of discretionary reviews or for by-right projects, as a requirement of the Objective Design Standards for byright development.

Project implementation would result in significant VMT impacts. The Office of Planning and Research (OPR) Technical Advisory recommends setting a VMT per capita threshold of 15 percent below that of existing development as a reasonable threshold based on an extensive review of applicable research, and in light of CARB assessments of the VMT reductions that would be needed to meet the state’s long-term climate goals. With buildout of the project, Santee is projected to have an average resident VMT per capita at

18.7, which is 98 percent of the base year regional average. VMT associated with the project would exceed the 85 percent threshold at buildout of the project, resulting in a significant VMT impact.

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Additionally, the project would result in an increase in development that was not accounted for in the Sustainable Santee Plan. The first step in determining consistency with the Sustainable Santee Plan is determining if a project is consistent with the land use assumptions used to develop the Sustainable Santee Plan. For a majority of the Rezone Sites, future development would not be consistent with the existing zoning and land use designation and would result in development that is more GHG-intensive than a project developed under the existing designations.

However, the Sustainable Santee Plan provides for regular monitoring the effectiveness of the programs and to undertake emission inventory updates. Specifically, starting in 2021, the City would update the inventory of emissions and continue updates every three years to ensure they are on track to meet their GHG reductions goals (City of Santee 2019). Development of these sites could occur before any updates to the Sustainable Santee Plan. As stated in the Consistency Checklist, if a project is not consistent with the existing designations and would be more GHG-intensive, in accordance with the City’s significance determination thresholds, the project’s GHG impact may be significant. Pursuant to CEQA Guidelines Section 15183.5, if a future project is not consistent with the Consistency Checklist/existing GHG reduction plan, a project-specific analysis would be required. Although, future development would be required to incorporate each of the applicable measures identified in the Consistency Checklist to mitigate cumulative GHG emissions (unless the decision maker finds that a measure is infeasible in accordance with CEQA Guidelines Section 15091), it is not feasible to determine at this program level of review whether future projects would be consistent with or otherwise mitigate GHG emissions to meet the inventory reduction goals.

The adoption of the project would result in an increase in GHG emissions that would exceed the assumption used in development of the Sustainable Santee Plan and would result in an increase in VMT that exceeds the 85 percent thresholds, resulting in a significant impact. Both ministerial and discretionary development implemented under the project would be required to demonstrate compliance with Sustainable Santee Plan through completion of the Consistency Checklist. The project would result in an increase in development and associated emissions not accounted for in the Sustainable Santee Plan and, therefore, GHG emissions would not be
adequately addressed through compliance with Sustainable Santee Plan and GHG emissions associated with the project would be significant.

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Potentially significant impacts associated with GHG emissions would be mitigated through the application of MM-GHG-1 and MM-GHG-2 which requires preparation of project-specific GHG emissions analysis or compliance with the Consistency Checklist, after the Sustainable Santee Plan has been updated to reflect the increased density within the Rezone Sites. Additionally, implementation of MMTRA-1 would potentially reduce VMT associated with development at the Rezone Sites. However, the effectiveness of GHG and VMT reducing measures is context-sensitive and would vary depending on the site-specific project site, such as the location, access to transit, etc. At a program level of review, it is not guaranteed that each individual project would fully mitigate the potential impacts.

While the requirement for future development to demonstrate compliance with the Consistency Checklist in addition to implementation of MM-GHG-1, MM-GHG-2, and MM-TRA-1 would minimize GHG impacts associated with future development at the Rezone Sites, at this program level of review, it is not feasible to conclude whether impacts would be fully mitigated. Therefore, impacts associated with GHG emissions would remain significant and unavoidable.

MM-GHG-1 For development at Rezone Sites that proceed before an update to the Sustainable Santee Plan is adopted, as detailed in MM-GHG-2, a site-specific GHG analysis is required. The site-specific GHG analysis shall (1) determine whether the project would result in GHG emissions that may have a significant impact on the environment and specifically must demonstrate how the project would reduce emissions to achieve consistency with the State Scoping Plan and applicable GHG reduction targets, and (2) the analysis must demonstrate how the project would be consistent with the Sustainable Santee Plan Consistency Checklist in addition to other applicable GHG reduction plans. The site-specific GHG analysis shall be completed to the satisfaction of the City during the permitting process.

For development at Rezone Sites that proceed after the Sustainable Santee Plan is adopted as detailed in MM-GHG-2, only project consistency with the Sustainable Santee Plan Consistency Checklist is required.

MM-GHG-2 Within one year of adoption of the rezone program, the City shall prepare an update to the Sustainable Santee Plan to incorporate the additional emissions that would result from development at the rezone sites as part of the baseline inventory. The updated Sustainable Santee Plan shall determine GHG emission reduction targets consistent with the current Scoping Plan, based on the Findings

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updated inventory and provide any necessary updates to the Consistency Checklist.

Additionally, to reduce potentially significant impacts associated with VMT from future development within the Rezone Sites, MM-TRA-1 would require incorporation of applicable Transportation Demand Management (TDM) measures.

2. Emission Reduction Plans
Threshold: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse gases?
Finding: Less than significant. (Draft PEIR, pp. 4.6-20 through 4.6-29) Explanation: The following analysis is based on whether development at the Rezone Sites would conflict with policies, plans, or regulations adopted for the purposes of reducing the emissions of GHG, thereby creating a condition in which in the policy, plan, or regulation would not be implemented and the goals would not be achieved.

State Plans. EO S-3-05 establishes GHG emission reduction targets for the state, and AB 32 launched the Climate Change Scoping Plan that outlines the reduction measures needed to reach these targets.

CARB adopted the 2017 Scoping Plan which provided an updated framework for actions to reduce statewide GHG emissions. The 2017 Scoping Plan builds on existing programs and requires CARB and other state agencies to adopt regulations and incentives to reduce GHG emissions. As such, the Scoping Plan is not directly applicable to City planning efforts and projects, although there are several regulatory measures aimed at the identification and reduction of GHG emissions.

Most of these regulatory measures focus on area source emissions (e.g., energy usage, high-global warming-potential GHGs in consumer products) and changes to the vehicle fleet (e.g., more fuelefficient vehicles, reduced VMT, fuel economy). This includes EO N19-19 that redoubles the state’s efforts to lower GHG emissions specifically through VMT reductions. Out of the recommended actions contained in CARB’s Scoping Plan, the actions that are most applicable to the proposed project would be those that are aimed at efficiency of utilities, and adoption of more stringent building and appliance standards.

The 2017 Scoping Plan identifies state strategies for achieving the state’s 2030 interim GHG emissions reduction target codified by SB Findings

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32. Measures under the 2017 Scoping Plan scenario build on existing programs such as the Low Carbon Fuel Standard, Advanced Clean Cars Program, RPS, SCS, Short-Lived Climate Pollutant Reduction Strategy, and the Cap-and-Trade Program. The project would comply with all applicable provisions contained in the 2017 Scoping Plan since the adopted regulations would apply to new development or the emission sectors associated with new development.
1) Transportation – State regulations and 2017 Scoping Plan measures that would reduce the project’s mobile source
emissions include the California Light-Duty Vehicle GHG Standards (AB 1493/Pavley I and II), the Low Carbon Fuel Standard, and the heavy-duty truck regulations. These
measures are implemented at the state level and would result in the reduction of project-related mobile source GHG
emissions associated with the project.
2) Energy – State regulations and 2017 Scoping Plan
measures that would reduce the project’s energy-related GHG emissions include RPS, Title 24 Energy Efficiency
Standards, and CALGreen. The project would be served by SDG&E, which has achieved 38.2 percent renewables as of 2020. The project’s energy-related GHG emissions would
decrease as SDG&E increases its renewables procurement
beyond 2020 towards the 2030 goal of 60 percent.

Additionally, future development would be constructed in accordance with energy efficiency standards effective at the time building permits are issued as well as energy-related GHG reduction measures identified in the Sustainable Santee Plan. The current 2019 Energy Code will result in more energy efficient development compared previous versions of the Energy Code and requires that solar photovoltaic systems be installed on all residential development. The Sustainable Santee Plan also requires that new residential construction meet or exceed CALGreen Tier 2 Voluntary Measures, such as obtaining green building ratings including LEED, Build it Green, or Energy Star Certified building certifications as well as the installation of solar PV.
3) Water – State regulations and 2017 Scoping Plan
measures that would reduce the project’s electricity
consumption associated with water supply, treatment, and distribution, and wastewater treatment include RPS,
CALGreen, and the Model Water Efficient Landscape
Ordinance. The project would be required to reduce indoor Findings

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water consumption by 20 percent in accordance with
CALGreen. Additionally, the project would be subject to all City landscaping ordinance requirements.
4) Waste – State regulations and 2017 Scoping Plan
measures that would reduce the project’s solid waste-related GHG emissions are related to landfill methane control,
increased efficiency of landfill methane capture, and high recycling/zero waste. The project would be subject to
CALGreen and the Sustainable Santee Plan, which require a diversion of construction and demolition waste from landfills.

Additionally, the project would include recycling storage and would divert waste from landfills in accordance with AB 341.

Future housing development implemented under the proposed project would require compliance with the State Building Code energy efficiency and applicable green building standards.

Development plans would be reviewed at project intake to ensure the inclusion of all applicable energy efficiency and applicable green building requirements of the applicable building and energy codes.

Additionally, both future ministerial and discretionary development would be required to demonstrate with Sustainable Santee Plan GHG reduction measures through completion of the Consistency Checklist.

However, although future development would generally be consistent with Scoping Plan measures, buildout of the project would result in an increase in GHG emissions that exceed the 2017 Scoping Plan efficiency metrics and an increase in VMT. The Sustainable Santee Plan provides for regular monitoring and will be updated every three years to ensure the City is on track to meet their GHG reduction goals that are consistent with the Scoping Plan. As required by MM-GHG-2, the City shall prepare an update to the Sustainable Santee Plan to incorporate the GHG emissions associated with development authorized by the rezones evaluated in this PEIR. The updated Sustainable Santee Plan would provide emission inventories and projections, and updated GHG emission reduction targets that are consistent with the Scoping Plan.

Prior to the Sustainable Santee Plan updates, future discretionary projects would demonstrate consistency with the Scoping Plan through preparation of project-specific GHG analysis, as required by MM-GHG-1. Once the Sustainable Santee Plan is updated to account for the rezones, then future projects would be able to rely on completion of the Consistency Checklist to demonstrate consistency with the Scoping Plan. However, at this program level of review, it is Findings

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not guaranteed that each individual project would be able to fully mitigate potential GHG emission impacts. Impacts would be significant.

Sustainable Communities Strategy. SANDAG’s 2021 Regional Plan includes an SCS that identifies how the region will achieve state-mandated GHG emissions reductions from cars and light-duty trucks. The SCS uses areas in the region called Mobility Hubs to concentrate future development. Mobility Hubs are communities with a high concentration of people, destinations, and travel choices. In the SCS land use pattern, forecasted growth for housing and jobs are within these areas of the region. Additionally, this SCS land use pattern identifies areas within the region that are sufficient to house the 6thCycle RHNA Plan allocations. Portions of Santee (along the SR-52 corridor from SR-125 to SR-67 and then the SR-67 corridor south to the City of El Cajon) are identified as a Gateway Mobility Hub in the 2021 Regional Plan. Eleven policy and program areas were identified for the 2021 Regional Plan. They include:
1) Land Use and Regional Growth – Land use and regional growth policies outlined through the 2021 Regional Plan build on the smart growth planning tools and projects that SANDAG and the region’s cities and other local jurisdictions have put in place. These include the Smart Growth Concept Map and
Smart Growth Toolbox, Designing for Smart Growth
guidelines and scorecard, Smart Growth Incentive Program, and Transit-Oriented Development Strategy, among others.

The 2021 Regional Plan vision for land use focuses on
development and growth in Mobility Hub areas to preserve San Diego’s open space and support transportation
investments by reducing VMT. As discussed, portions of the City are identified as a Gateway Mobility Hub. However, VMT associated with residential development would exceed the 85 percent threshold at buildout of the project, and the project would not meet the regional VMT reduction goals.
2) Housing – SANDAG is overseeing the sixth RHNA cycle, and approved the final methodology for allocating housing units to each city and county in the region based on the transit and jobs in each jurisdiction. SANDAG coordinates with
member agencies to implement strategies to support housing availability and affordability throughout the region. As discussed in Section 3.0, the City prepared its 6thCycle Housing Element, adopted by City Council on July 14, 2021, which covers the planning period from April 15, 2021 to April 15, 2029. As the City’s main housing policy and planning document, the Housing Element identifies housing needs and Findings

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constraints, sets forth goals, policies and programs that address these needs and constraints, and plans for projected housing needs for all income levels over an eight-year
planning period that coincides with the RHNA allocation as prescribed by SANDAG. As such, the project is consistent with the 2021 Regional Plan housing policies and
implementing actions.
3) Climate Action Planning – To help reach regional and GHG emissions reduction targets, the 2021 Regional Plan focuses heavily on the conversion to clean transportation and a shift from personal vehicle dependency. SANDAG will
support local and regional efforts to implement and monitor CAPs by providing grant funding, guidance resources, and templates for CAP implementation. The project would not conflict with SANDAG’s regional planning efforts related to CAP implementation. As discussed in Section 4.6.2.3(c), the City developed a Sustainable Santee Plan that provides GHG emissions reduction goals and strategies focused on reducing resource consumption, improving alternative modes of
transportation, and reducing overall emissions throughout the City. Both ministerial and discretionary development
implemented under the project would be required to
demonstrate compliance with Sustainable Santee Plan
through completion of the Consistency Checklist. Overall, the project would be consistent with the Sustainable Santee Plan goals and measures (discussed in the following section; however, because the project would result in an increase in development not accounted for the in Sustainable Santee Plan and would result in significant VMT impacts, buildout of the project would not be consistent with the Sustainable Santee Plan.
4) Climate Adaptation and Resilience – Adaptation is the way communities and people change how they respond to the impacts of climate change. SANDAG will establish a regional vision and coordination to enhance and sustain existing planning and implementation obligations across agencies, sectors, and organizations through the development of a Regional Resilience Framework. In addition, SANDAG will establish a Nature-Based Climate Solutions Program that will promote natural infrastructure that uses or mimics natural processes to benefit people and wildlife. The project would not conflict with SANDAG planning efforts related to climate adaptation and resilience.

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5) Electric Vehicles (EVs) – SANDAG aims to incentivize and encourage the incorporation of all types of EVs into Flexible Fleets, Transit Leap, and goods movement and to support funding programs that increase the number of EVs and charging stations throughout the region and within
Mobility Hubs and as part of the Complete Corridor strategy.

As discussed in the following section, future multi-family development implemented under the project would be
required to install e-chargers for 13 percent of total parking.

Both ministerial and discretionary development implemented under the project would be required to demonstrate
compliance with this measure through completion of the
Sustainable Santee Consistency Checklist. The project would therefore be consistent with SANDAG EV goals.
6) Parking and Curb Management – Proactively managing
parking and curb space enables more people to access
places using alternatives to driving. In the San Diego region, cities are responsible for adopting policies to manage parking and curbs. SANDAG plays the role of informing these policies by sharing resources and best practices. Future development would be required to implement City parking requirements, and would increase development near transportation
corridors and mixed-use development, thereby reducing the need to drive. The project would be consistent with parking and curb management goals.
7) Transportation Demand Management – Transportation
Demand Management (TDM) refers to policies and programs that help reduce commute-related traffic congestion. Typical TDM programs promote carpooling, vanpooling, taking transit, biking, and walking to work. SANDAG operates a TDM
program called iCommute for the San Diego region.
iCommute manages the regional vanpool program,
Guaranteed Ride Home services, bike encouragement
programs, and various incentive and marketing programs, mostly through its work with more than 200 employers.

SANDAG will continue to provide various programs, services, and financial subsidies that support sustainable transportation options. Future development implemented under the project would benefit from participation in SANDAG programs. The project would not conflict with SANDAG’s TDM goals.
8) Vision Zero – Vision Zero is a national campaign that uses a variety of strategies to work toward eliminating deaths and severe injuries on streets. Vision Zero is primarily focused on Findings

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policies and roadway designs that affect people’s choices.

SANDAG will develop and implement a regional safety policy and work with local jurisdictions to provide technical resources and assistance on roadway design. The project would not conflict with SANDAG Vision Zero planning efforts.
9) Fix It First – The 2021 Regional Plan focuses on improving upon existing roads, rails, and sidewalks. The Fix It First strategy aims to repair existing roads and create a system for sustained maintenance in the future, creating a safe and efficient transportation network for all users. The project would not conflict with SANDAG efforts to repair and maintain the regional transportation system.
10) Transportation System Management and Operations
– Transportation systems management and operations
encourages agencies to combine tools, resources, and
solutions to achieve greater performance of the entire system.

Transportation systems management and operations
includes the establishment of institutional and governance actions to help advance and facilitate cross-agency
collaboration to ensure existing and proposed transportation systems are not operated or managed as independent
systems but as a multimodal transportation system. The
project would not conflict with SANDAG and regional planning efforts to maintain an efficient transportation system. 11) Value Pricing and User Fees – User fee systems can
feature distance-based (per mile) or segment-based (per toll zone) pricing with rates that are either flat, adjusted in response to congestion levels, or vary according to a known schedule. The 2021 Regional Plan considers a suite of user fees aimed at encouraging travelers to consider more
sustainable travel choices and manage congestion. The
project would not conflict with user fees.

Generally, the project would not conflict with the policies of the 2021 Regional Plan and would promote several concepts and strategies of the SCS. However, because a goal of the 2021 Regional Plan is to reduce GHG emissions in accordance with SB 375 state mandates, and because VMT associated with the project would exceed the 85 percent threshold at buildout, impacts related to VMT would be significant and the project would conflict the 2021 Regional Plan.

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Sustainable Santee Plan. The City has adopted the Sustainable Santee Plan which sets GHG reduction targets for the City to achieve. Additionally, the Sustainable Santee Plan includes measures for the City to implement in support of achieving the reduction targets. Although future development would be consistent with Sustainable Santee Plan Goals and Implementing Measures, development that would be authorized with the rezones was not accounted for in the emissions inventories used to develop the Sustainable Santee Plan. However, the Sustainable Santee Plan provides for regular monitoring the effectiveness of the programs and to undertake emission inventory updates. Specifically, the City has plans to update the inventory of emissions and continue updates every three years to ensure they are on track to meet their GHG reductions goals (City of Santee 2019). As updates occur, the GHG emissions associated with development allowed by the proposed rezones would be accounted for, ultimately ensuring future development would be consistent with the Sustainable Santee Plan.

However, until such time the emission inventories are updated, the project would conflict with the Sustainable Santee Plan.

Development at the Rezone Sites would increase GHG emissions and would exceed VMT thresholds. Although the project would not conflict with the policies of the 2021 Regional Plan and would promote several concepts and strategies of the SCS, a goal of the 2021 Regional Plan is to reduce GHG emissions in accordance with SB 375 state mandates. Since VMT associated with the project would exceed the 85 percent threshold at buildout, impacts related to VMT would be significant and the project would conflict the 2021 Regional Plan/SCS.

Additionally, the project would exceed the emissions assumptions used to develop the Sustainable Santee Plan, resulting in a conflict with the plan. This conflict would remain until such time that the City updates emission inventories to account for the proposed rezones, and amends the Sustainable Santee Plan accordingly.

Overall, the project would be consistent with goals and policies from the 2017 Scoping Plan, 2021 Regional Plan/SCS, and Sustainable Santee Plan; however, because the project would result in an increase in development not accounted for in the Sustainable Santee Plan emission inventories and the project would result in significant VMT impacts, the project would conflict with GHG emissions reduction plans and impacts would be significant.

Mitigation is proposed for implementation of both discretionary and by-right development projects. Mitigation would either be applied Findings

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during a future discretionary review or for by-right development or as a requirement of the City’s objective design standards adopted as part of the project. Both ministerial and discretionary development implemented under the project would be required to prepare a sitespecific GHG analysis as detailed in MM-GHG-1 or demonstrate consistency with the Sustainable Santee Plan which will be updated to ensure emissions associated with increased density resulting from the proposed rezones evaluated in this PEIR are addressed, as detailed in MM-GHG-2. Both ministerial and discretionary development implemented under the project would be required to incorporate each of the applicable measures identified in the updated Consistency Checklist to mitigate cumulative GHG emissions.

Additionally, to reduce potentially significant impacts associated with VMT associated with future development within the Rezone Sites, MM-TRA-1 would be implemented by the City.

Potentially significant impacts associated with GHG emissions would be mitigated through the application of MM-GHG-1 and MM-GHG-2.

MM-GHG-1 requires implementation of a site specific GHG emissions analysis demonstrating how the project would achieve GHG reductions and/or compliance with the Consistency Checklist.

MM-GHG-2 would require the City to incorporate updates to the Sustainable Santee Plan to reflect the increased density within the Rezone Sites. Implementation of MM-GHG-2 would require the City to update the Sustainable Santee Plan to ensure emissions associated with future development allowed at the rezone sites is addressed in the emission inventory. While this would ultimately achieve consistency with applicable plans and policies addressing GHG emissions, until the updated plans are adopted the project would conflict with plans adopted for the purpose of reducing GHG emissions. Therefore, impacts associated with consistency with policies, plans and regulations adopted for the purpose of reducing GHG emissions would remain significant after mitigation.

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C. LAND USE AND PLANNING

1. 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: Significant and unavoidable. (Draft PEIR, pp. 4.9-17 through 4.9-20) Explanation: San Diego County Airport Land Use Compatibility Plans Portions of the City are subject to regulation by the ACLUP for the Gillespie Field and MCAS Miramar airports. Future development within airport influence areas (AIAs) of Gillespie Field and MCAS Miramar would be subject to the land use compatibility policies and development criteria associated with each respective ALUCP.

Several proposed Rezone Sites are located within an AIA and some proposed densities may exceed limits for the corresponding airport safety zone.

The City is responsible for submitting the Application for a Consistency Determination to the Authority. Airport staff would review and make recommendations to the ALUC as to the
appropriate determination. The ALUC must act upon an application for a determination of consistency with an ALUCP within 60 days of the ALUC deeming such application complete. The City may override an ALUC determination of inconsistency by a two-thirds vote of the City Council if it can make certain findings and provide a 45-day notice of the same to the ALUC and the California Department of Transportation per Public Utilities Code Section 21676.5(a). Where possible conflict between the residential density provisions mandated by state law and Airport Safety Zones are identified with a specific land use proposal, the ALUCP density limitations shall apply unless overridden by the City Council. Since this process is not unique to the City, it does not constitute a distinct or unusual constraint.

Therefore, it is possible that future development plans would not be entirely compatible with the ALUCPs. When development proposals do come forth, they would be required to complete consultation with the ALUC and depending on the ultimate density of the proposal, future development could be found incompatible with the ALUCP.

Therefore, at this level of program review, a significant impact could occur with respect to consistency with ALUCPs.

No feasible mitigation is available to reduce the potential conflict between the allowable density within the airport safety zones and the Findings

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proposed Rezone Sites. Actual incompatibilities with the ALUCP for future development would be considered by City Council on a project-by-project basis as future development is proposed. If determined not to be compatible, impacts would be significant and unavoidable.

D. NOISE

1. Noise Standards
Threshold: Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Finding: Significant and unavoidable. (Draft PEIR, pp. 4.10-20 through 4.10- 21)
Explanation: Vehicle Traffic Noise – Increase in Ambient Noise. The project does not propose the construction of new housing or other development; rather it provides capacity for future development consistent with the proposed rezones. Future development as a result of development at the Rezone Sites would increase traffic volumes on local roadways. A significant impact would occur if, as a direct result of the project, (1) noise levels would exceed the compatibility standards identified in Table 4.10-2 of the Draft PEIR, or (2) noise levels which already exceed the levels considered compatible for that use are increased by 3 dB or more.

The noise analysis is based on the existing (year 2020) and future (year 2050) traffic volume data. The traffic analysis included approximately 400 circulation element roadway segments within the City and vicinity. The change in noise level was calculated for these roadway segments, as well as SR-52, SR-126, and SR-67, for the existing condition and buildout of the project. Noise impacts were determined by comparing the change in noise levels between the existing condition and buildout of the project to the criteria listed above.

Based on the impact criteria above, project buildout would result in a significant noise increase over existing ambient noise levels at nine of the analyzed roadway segments. Impacts related to the permanent increase in ambient noise would be significant. The Noise Element contains Policies 2.2 and 2.3 that requires new development to mitigate the noise impact to existing uses resulting from new development. Possible noise-reduction measures would Findings

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include retrofitting older homes with new window and door components with higher sound transmission class (STC) ratings.

However, for existing uses, it cannot be determined whether the existing structures contain adequate attenuation to reduce interior noise to the 45 dB(A) Ldn standard nor what measures would be required to retrofit these structures. In addition, there is no mechanism in place for implementing such a retrofit. Because the significant noise impacts are to existing homes in an already urbanized area, there is no feasible mitigation. Thus, impacts to existing sensitive land uses due to the increase in ambient noise levels associated with buildout of the project would remain significant and unavoidable.

E. TRANSPORTATION

1. VMT
Threshold: Would the Project conflict or be inconsistent with CEQA Guidelines sections 15064.3, subdivision (b)?
Finding: Significant and unavoidable. (Draft PEIR, pp. 4.13-15 through 4.13- 17)
Explanation: The Transportation Impact Study (TIS) evaluated project impacts based on the resident VMT per capita metric, which includes all daily vehicle-based person trips originated from or ending at the home location of the individual (driver or passenger). The VMT/Capita includes, for all San Diego County residents, all vehicle-based resident travel grouped and summed to the home location of the individual. It includes all resident vehicle travel: home-based and non-home-based. The VMT for each individual is then summed for all individuals residing in a particular census tract and divided by the population of that census tract to arrive at Resident VMT/Capita.

The City of Santee VMT Analysis Guidelines (adopted on April 27, 2022) recommends setting a VMT per capita threshold of 15 percent below that of existing development as a reasonable threshold based on an extensive review of applicable research, including California Air Resources Board assessments of the VMT reductions that would be needed to meet the state’s long-term climate goals. In other words, in order to result in a less than significant impact, VMT per capita resulting from a project should be at or below the 85thpercentile of the citywide average for that land use type (City of Santee 2022).

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The VMT analysis utilized the average resident VMT per capita for the City and was determined using SANDAG’s Series 14 Base Year (2016). The 2016 baseline is the base year model in the SANDAG Series 14 Regional Transportation Model. The City’s VMT per capita is 20.5 miles per person.

With implementation of the Rezone Sites, including buildout of the City’s General Plan land use and transportation network, the average resident VMT per capita of City would be reduced to 18.7 (from 20.5 under base year). While the project would result in a reduction in VMT per capita which would move the City in the direction of reducing VMT Citywide, the 18.7 VMT per capita represents 91.2 percent of the base year citywide average. As a result, VMT per capita associated with the project would be greater than 85 percent of the citywide average and would exceed the VMT threshold, which would be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). In order to have a less than significant VMT impact, a project must demonstrate it can achieve a VMT per capita of 85 percent or less than the citywide average.

Future development of the Rezone Sites in conjunction with the project would change the Citywide VMT efficiency to 18.7 compared to 20.5 under the Base Year (2016), representing a slight increase in VMT efficiency with the project. However, this VMT efficiency of 18.7 with the project represents 91 percent of the citywide average, which exceeds the VMT significance threshold. Therefore, projected VMT per capita with the project would exceed the 85 percent threshold representing a significant impact.

Implementation of the MM-TRA-1 as part of future projects reviews would potentially reduce VMT per capita. However, the effectiveness of VMT reducing measures is context-sensitive and would vary depending on project details, such as the location, access to transit, etc. At a program level of review, it is not guaranteed that each individual project would be able to fully mitigate the potential impacts particularly considering the high VMT per capita in the City compared to the citywide average. While MM-TRA-1 would minimize VMT impacts associated with future development at the Rezone Sites, impacts would not be fully mitigated. Therefore, impacts associated with VMT would remain significant and unavoidable.

MM-TRA-1: VMT Reduction
The City shall require implementation of applicable Mobility Element Policies that would support VMT reductions for individual projects.

Specifically, the City shall require that future projects are compliant with Mobility Element Policies 9.1 through 9.5, which encourage the Findings

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use of Transportation Demand Management (TDM) strategies, such as ride sharing programs, flexible work schedule programs, and incentives for employees to use transit. Additionally, alternative transportation modes, such as walking, cycling and public transit are encouraged to reduce peak hour vehicular trips, save energy, and improve air quality. Sample TDM measures that may be applied at the project-level are provided below:
• Increase mixed-use development
• Increase transit accessibility
• Provide pedestrian network improvement along project
frontage
• Provide bicycle network improvement along project frontage • Provide bicycle parking and bike lockers
• Implement subsidized or discounted transit passes
• Provide rider-sharing programs
• Implement commute trip reduction marketing
• Implement school pool program
• Implement bike-sharing or micro mobility program
• Provide local shuttle to connect visitors to different attractions throughout the City
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SECTION V.

CUMULATIVE IMPACTS
Regarding the Project’s potential to result in cumulative impacts, the City hereby finds as follows:

A. AESTHETICS
Based on the location of the Rezone Sites, the study area for the assessment of cumulative visual impacts includes the entirety of the City in addition to portions of each of the surrounding cities within the viewshed of the project area including: the City of El Cajon to the south and southeast; the City of San Diego to the west and northwest; and the County of San Diego to the east and northeast. The project is comprised of 25 Rezone Sites that are a part of the Housing Element sites inventory, with two additional sites located on Graves Avenue. Future development within these Rezone Sites could have a cumulative impact on visual resources due to changes in the existing visual quality and aesthetics resulting from incremental increases in density and urbanization. This growth could gradually alter the visual quality of the study area. The following is a summary of the project’s contribution to cumulative aesthetic impacts.

The vacant and underutilized sites are primarily located within urbanized areas that are surrounded by residential and commercial development. Development of these Rezone Sites would be consistent with the visual quality and character of surrounding development based on application of required design review and consistency with City Municipal Code standards. Additionally, some of the underutilized sites consist of aging structures with poor visual quality, and redevelopment of these structures would result in new residential structures developed consistent with the visual requirements of the City’s Municipal Code. Furthermore, development of vacant and underutilized sites within the City’s General Plan and/or Town Center Specific Plan areas would be required to adhere to the land use plans that provide supplemental development regulations of those sites.

Regarding public views, the Rezone Sites are located throughout the City. Development at most sites would constitute infill development resulting in development consistent with surrounding urbanization that would not affect existing views. However, some larger vacant sites located near the San Diego River or within undeveloped lands that are not surrounded by urbanized lands could affect views. Both future ministerial and discretionary development would be required to adhere to relevant portions of the City’s Municipal Code including Chapter 13.08, et seq., which establishes the City’s development review procedures. For ministerial and discretionary development of Rezone Sites, the requirement for Development Review consistent with Municipal Code Chapter 13.08 would ensure consistency with General Plan policies and applicable design and development review requirements including supplemental development regulations from the Town Center Specific Plan. The Development Review process would ensure that future development would not degrade scenic vistas and views and, therefore, there would be no substantial cumulative obstruction of public views.

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Regarding light pollution, development of the Rezone Sites would be required to comply with the City’s Municipal Code standards related to light and glare (Chapter

13.08.070(G)), which requires that outdoor lighting be directed away from adjacent properties and set in a way to avoid any detriment to the surrounding area. Additionally, the City’s General Plan Community Enhancement Element includes the standard for lighting and signage to minimize spillover of lighting through use of directional, cut-off, and non-glare fixtures.

Overall, the development of the Rezone Sites combined with development in the surrounding cumulative study areas would not result in a cumulatively significant visual impact due to the urbanized nature of the cumulative study area. Adherence to regulatory requirements including Development Review consistent with Municipal Code Chapter

13.08 implementation and Town Center Specific Plan development regulations would ensure that future development would not substantially degrade scenic resources. Thus, the project’s incremental contribution to visual impacts would not be cumulatively considerable and cumulative visual impacts would be less than significant. (Draft PEIR, pp. 7-3 through 7-4)
B. AGRICULTURE AND FORESTRY RESOURCES
The FMMP classifies the majority of the Rezone Sites as “Urban and Built Up Land,” “Other Land,” and “Grazing Land.” The areas classified as “Grazing Lands” are not considered a significant farmland resource under CEQA. A few Rezone Sites are classified as “Farmland of Local Importance”; however, there is no recent history of agricultural use at these sites. There are no lands protected by a Williamson Act Contract within the City. Additionally, there is no forestland within the City, and the City does not possess any zoning classifications for forestland, timberland, or timberland production zones. Therefore, no cumulative impacts to agricultural and forestry resources would occur.

C. AIR QUALITY
Cumulative impacts to air quality may be regional or localized. Regional air quality would be impacted if emissions from the project contributed to cumulative degradation of air quality in the San Diego Air Basin (SDAB). Localized air quality would be impacted if emissions from the project and other proximate emissions sources resulted in pollutant concentrations that exceeded standards at a sensitive receptor. The analysis provided in Section 4.2 is cumulative in nature as it considers buildout of land uses to the year 2045.

The study area for the assessment of cumulative regional air quality impacts is the SDAB which is considered a nonattainment area due to exceedances of the California Ambient Air Quality Standards (CAAQS) for ozone and inhalable particulate matter (PM10). Future development within the study area could have a cumulative impact on air quality due to increased air pollution emissions associated with construction and operations, including transportation.

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The cumulative assessment of regional air quality impacts to the SDAB relies partially on assessment of the project’s consistency with the adopted Regional Air Quality Strategies (RAQS) and State Implementation Plan (SIP). The RAQS and SIP are based on growth forecasts for the region, which are in turn based on maximum buildout of land uses as allowed in the adopted community and general plans. As discussed in Section 4.2.5, the project would result in increased land use intensity compared to what is anticipated under the adopted General Plan, and thereby would likely result in increased air emissions that are not accounted for in the RAQS. Because the significant air quality impact stems from an inconsistency between the project and the adopted land use plans upon which the RAQS was based, a significant impact would occur until the San Diego Air Pollution Control District updates the RAQS.

Construction and operational emissions associated with cumulative construction activities associated with buildout of the Rezone Sites may result in some instances where future development would occur simultaneously and would cumulatively exceed the relevant thresholds. Therefore, cumulative construction-related regional air quality impacts would be potentially significant (Impact AQ-2). Regarding cumulative operational emissions, since buildout of the project would conflict with implementation of the RAQS, a cumulatively considerable net increase in emissions would occur compared to the emissions that would occur under existing land use designations. This is the same impact identified above as Impact AQ-1 related to inconsistency with the RAQs.

Mitigation Measure AQ-1 would be applied to address significant cumulative construction impacts. This measure would apply as a requirement of the City’s Objective Design and Performance Standards, and would ensure individual projects apply measures to reduce construction related air pollutants. No feasible mitigation has been identified to address the project’s inconsistency with the RAQs. The RAQS is updated periodically by the San Diego Air Pollution Control District, at which time the growth projections of jurisdictions would be incorporated, and consistency would be achieved.

Therefore, until the anticipated growth is included in the emissions estimates of the RAQs and the SIP, cumulative impacts relative to conformance with the RAQs would remain significant and unavoidable. (Draft PEIR, pp. 7-4 through 7-5)

D. BIOLOGICAL RESOURCES
The study area for the assessment of cumulative impacts to biological resources includes the East County inland region composed of the City and neighboring jurisdictions identified above. The Rezone Sites are largely located on existing urbanized properties that contain limited biological value. Future development of Rezone Sites that require a discretionary process would be subject to future environmental review. For these projects, site-specific analysis would be required to identify the presence of sensitive species and appropriate mitigation would be applied to reduce potential impacts. Application of a future discretionary review and implementation of the City’s General Plan Mitigation Monitoring Requirements for biological resources would ensure impacts would not be cumulatively considerable.

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However, some future development on Rezone Sites may proceed with ministerial process which would not require a subsequent environmental review. For ministerial projects, potential development could occur on lands that support sensitive species, wildlife, or nesting/migratory birds, resulting in a potentially significant impact.

Additionally, indirect impacts could occur from development located adjacent to sensitive habitats. However, implementation of mitigation measure BIO-1 would require all future development projects to conduct surveys to identify potential sensitive plant or wildlife species, including any migratory or nesting birds. If potentially significant impacts to sensitive biological resources are identified, the future projects shall recommend appropriate mitigation to reduce the impacts to below a level of significance. Therefore, implementation of mitigation measure BIO-1 would reduce potentially significant cumulative impacts to a level less than significant. Compliance with existing federal and state regulations, General Plan policies and implementation of mitigation measures BIO1 through BIO-4 would ensure that future development within the Rezone Sites would not result in a cumulatively considerable contribution to biological resources impacts. Impacts to sensitive vegetation communities would be reduced to less than significant levels with the implementation of mitigation measures BIO-2 and BIO-5, for both discretionary and by-right development projects.

Impacts to state or federally protected wetlands associated with future discretionary projects within the Rezone Sites would require mitigation framework for the implementation of both discretionary and by-right development projects. The implementation of mitigation measure BIO-6 would reduce impacts to a level less than significant and ensure that the project would not contribute to a significant cumulative impact to biological resources. (Draft PEIR, p. 7-5)
E. CULTURAL RESOURCES
The study area for the assessment of cumulative impacts to cultural resources includes the entirety of the City because loss of cultural resources would be detrimental to the entire City. Future development within the cumulative study area could have a cumulative impact on cultural resources through loss of records or artifacts as land is developed (or redeveloped).

Future development in accordance with the project could impact historical or archaeological resources, which may be present within the project. Implementation of mitigation measures CUL-1, CUL-2, and CUL-3 would reduce impacts to cultural resources to less than significant through the requirement for historic and archaeological surveys and archaeological monitoring during grading and construction. Implementation of these measures would ensure that the project would not contribute to a significant cumulative impact to historical or archaeological resources. (Draft PEIR, p. 7-6) F. ENERGY
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Consistent with state requirements, all construction equipment would meet CARB Tier 3 In-Use Off-Road Diesel Engine Standards. CARB’s Tier 3 In-Use Off-Road Diesel Engine Standards requires that construction equipment fleets become cleaner and use less energy over time. The project would not result in a wasteful and inefficient use of energy resources during construction of future development. Although the project would provide capacity for future housing development that could increase energy use, energy demand of future residential development would be consistent with energy demand for multi-family housing within other cities in the region and would not be associated with inefficient or wasteful energy use. Implementation of the project would not result in any unusual characteristics that would result in excessive long-term operational building energy demand. Future development associated with implementation of residential development at the Rezone Sites would be subject to compliance with the California Building Code (Title 24) which aims to reduce excessive and inefficient energy use. By locating housing at existing retail sites and developing retail uses along with multi-family residential uses at the Rezone Sites, non-commute vehicle trips may be reduced. The City shall ensure that future projects are compliant with Mobility Element Policies 9.1 through 9.5, which encourage the use of Transportation Demand Management (TDM) strategies, such as ride sharing programs, flexible work schedule programs, and incentives for employees to use transit. Future projects would be required to comply with the Sustainable Santee Plan by promoting non-motorized transportation options, improving bicycle transit, installing electric vehicle charging stations, and improving traffic flow. This would be demonstrated through completion of the Sustainable Santee Plan Consistency Checklist. Additionally, alternative transportation modes, such as walking, cycling, and public transit are encouraged to reduce peak hour vehicular trips, save energy, and improve air quality. (Draft PEIR, pp. 8-2 through 8-4) Thus, the project would not result in cumulatively significant impacts with respect to energy.

G. GEOLOGY AND SOILS
The study area for the assessment of cumulative impacts related to geology and soils is the City. Future development would be required to adhere to regulatory requirements including the California Building Code and City’s Municipal Code requirements for soils engineering/engineering geology reports and erosion control plans would prevent adverse effects associated with fault rupture, ground shaking, liquefaction, or landslides.

Like the project, all future development would be required to adhere to all regulations applicable to the site/zone, including Chapter 11.40 (Grading Ordinance), which include objective standards relating to the elimination or reduction of potential seismic hazards prior to the issuance of permits. Additionally, all development would be subject to General Plan policies from the Safety Element. Future development at the Rezone Sites in addition to other future development within the City would be required to adhere to regulatory requirements including preparation of Storm Water Pollution Prevention Plan and Municipal Code Chapter 11.40 (Grading Ordinance) to ensure that they would not result in substantial soil erosion or the loss of topsoil. Adherence to California Building Code requirements as adopted by the City would ensure that future development would not create substantial direct or indirect risks associated with expansive soils.

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Regarding paleontological resources, the mitigation measure GEO-1 would reduce project impacts to less than significant. Additionally, other development in the City would be required to implement measures identified in the City’s General Plan mitigation monitoring program for paleontological resources which would reduce impacts to a level less than significant. All potential impacts associated with geology and soils would be reduced to less than significant levels because future development would be required to adhere to regulations and implement the General Plan EIR’s existing mitigation framework. Additionally, mitigation measure GEO-1 would require applicants to provide information to the City regarding the paleontological sensitivity of the site. On properties determined to be moderately to highly sensitive for paleontological resources where grading would disturb sensitive formations, the ordinance shall require implementation of a mitigation plan. Therefore, implementation of mitigation measure GEO-1 would ensure that the project would not contribute to a significant cumulative impact to paleontological resources. (Draft PEIR, p. 7-6)
H. GREENHOUSE GAS EMISSIONS
The analysis of greenhouse gas (GHG) emissions is, by its nature, a cumulative issue; thus, the study area is global in nature. The analysis was modeled in year 2035 to align with the Sustainable Santee Plan emission projections and for the Housing Element buildout year 2050. The Rezone Sites were modeled in the soonest operational year of 2024. Development at the Rezone Sites would increase GHG emissions and would exceed VMT thresholds. Both ministerial and discretionary development implemented under the project would be required to demonstrate compliance with Sustainable Santee Plan through completion of the Consistency Checklist. Overall, the project would be consistent with the 2017 Scoping Plan, 2021 Regional Plan/SCS, and Sustainable Santee Plan goals; however, because the project would result in an increase in development not accounted for in the Sustainable Santee Plan and would result in significant VMT impacts, the project would conflict with GHG emissions reduction plans and impacts would be significant. To reduce potentially significant impacts associated with VMT associated with future development within the Rezone Sites, mitigation measure TRA-1 would be implemented. While the Consistency Checklist and the requirement for implementation of measures associated with mitigation measure TRA-1 would minimize GHG impacts associated with future development at the Rezone Sites, impacts would not be fully mitigated. Likewise, cumulatively significant impacts associated with GHG emissions would remain significant and unavoidable. (Draft PEIR, p. 7-7) I. HAZARDOUS AND HAZARDOUS MATERIALS
The study area for the assessment of cumulative impacts to hazards and hazardous materials impacts is the City. As population growth increases, the number of people potentially exposed to hazards and hazardous materials would increase.

Generally, the release of hazardous materials has site-specific impacts that do not compound or increase in combination with impacts elsewhere. Future development in Findings

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within the Rezone Sites could result in hazards to the public or the environment by disturbance of existing unknown contaminated soils. Mitigation measure HAZ-1 would require that future projects identify potentially hazardous conditions prior to grading, through preparation of a Phase I Environmental Site Assessment (ESA) and a Phase II ESA if necessary. Remediation of any contaminated soils would be required prior to development. Additionally, cumulative projects within the region would be required to comply with applicable federal, state, and local regulations of agencies having jurisdiction over hazardous materials, including the U.S. EPA, federal Resource Conservation and Recovery Act, County Department of Health Services, and County of San Diego Department of Environmental Health. Therefore, implementation of mitigation measure HAZ-1 would ensure that the project would not contribute to a significant cumulative impact to hazards or the release of hazardous materials. The cumulative study area for airport hazards includes the entirety of the airport influence area (AIA) for the Gillespie Field Airport. The Airport Land Use Compatibility Plan (ALUCP) includes policies that are applicable within the AIA. In order to assure safety compliance with the Gillespie Field ALUCP, future development must adhere to the existing City policies and regulations, and policies of the ALUCP. Therefore, the project’s incremental contribution to airport hazard impacts would not be cumulatively considerable. The project would not impair implementation of or physically interfere with the City’s emergency response plan, evacuation routes and would not conflict with any Multi-Jurisdictional Hazard Mitigation Plan hazard mitigation goals. Furthermore, applications for all future projects within the project areas in addition to cumulative projects in the surrounding area would require review and approval by the Santee Fire Department prior to issuance of building permit.

Therefore, the cumulative impacts associated with airport safety would be less than significant.

Regarding potential cumulative impacts related to wildfire, Rezone Sites 1 through 10 and 35 are located within the City’s designated Very High Fire Hazard Severity Zone.

However, cumulative impacts resulting from development of these sites in addition to development of cumulative projects within high fire hazard areas would be reduced through adherence to California Fire Code Title 19, Division 1, Section 3.07(b), which requires a minimum 30-foot brush clearance around structures for fire safety. Additionally, future cumulative projects would be required to comply with state and local regulations including City Municipal Code Chapter 11.18, which states all new developments, subdivisions, or tracts that are planned in Fire Hazard Severity Zones and/or Wildland Urban Interface Areas shall have a minimum of 100 horizontal feet of “fuel modified” defensible space between structure and wildland areas. Adherence to these regulations and the General Plan policies would reduce risks in conjunction with future development related to wildland fire. Thus, the project’s incremental contribution to wildfire impacts would not be cumulatively considerable and cumulative impacts would be less than significant. (Draft PEIR, pp. 7-7 through 7-8)
J. HYDROLOGY AND WATER QUALITY
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Water Quality. While future development within the drainage basins of each Rezone Site has the potential to increase pollutants discharged into surface waters, all future development would be subject to federal, state, and local regulations aimed at controlling water quality impacts. Both discretionary and ministerial development would be required to adhere to regulatory requirements including Santee Municipal Code Chapters 9.06 (Stormwater Ordinance) and Chapter 11.40 (Grading Ordinance), which include requirements to ensure storm water runoff is captured and treated and erosion control measures are implemented. Thus, based on the requirements of future development within the Rezone Sites to comply with the existing regulatory framework that requires treatment of pollutants generated on-site, the project’s incremental contribution to cumulative water quality impacts would be less than cumulatively considerable and cumulative impacts associated with water quality would be less than significant.

Drainage. While future development has the potential to alter drainage patterns resulting in increased erosion, stormwater runoff, and impacts to the existing drainage system, all future development would be subject to federal, state, and local regulations aimed at reducing polluted storm water and avoiding overloading the City’s drainage system. Both ministerial and discretionary development would be required to adhere to regulatory requirements including City Municipal Chapter 9.06 (Stormwater Ordinance), which includes requirements for the elimination or reduction of storm water runoff. Impacts associated with drainage patterns and storm water runoff would be less than cumulatively considerable and cumulative impacts associated with drainage would be less than significant.

Flooding. Future development of the Rezone Sites would be required to conform to applicable federal, state, and City regulatory standards to effectively avoid and/or address potential impacts associated with development in flood zones. The Rezone Sites are not within an area anticipated to be adversely affected by a tsunami. Implementation of all regulatory requirements would ensure that cumulative impacts related to flood hazards would be less than significant. (Draft PEIR, pp. 7-8 through 7-9) K. LAND USE AND PLANNING
The study area for the assessment of cumulative land use impacts would be the City and neighboring jurisdictions as detailed above. Cumulative land use impacts could result from changes to land use plans, which become incompatible and/or unsustainable.

Adoption of the project could contribute to cumulative impacts if buildout would conflict with land use plans and/or policies. Policy consistency review associated with future discretionary development at the Rezone Sites would ensure no conflict would occur related to policies or regulations adopted for the purpose of mitigating an environmental impact. Future development at the Rezone Sites may occur either with a discretionary action, or with a ministerial approval for project that meet certain criteria. Future discretionary development would require a subsequent site-specific environmental review that would consider each project’s consistency with all applicable plans, including the City’s General Plan. Future by-right development would be required to adhere to the City’s Findings

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proposed Objective Design Standards which includes design guidelines and regulations to ensure consistency with City plans and policies. Both future ministerial and discretionary review would be subject to review for consistency with the City’s General Plan and Municipal Code regulations that serve to reduce or avoid environmental impacts.

Therefore, cumulative impacts related to policy inconsistency would be less than significant. (Draft PEIR, p. 7-9)
L. MINERAL RESOURCES
Rezone Sites 15, 16A, 16B, 17, and 20A are designated as MRZ-2, Sites 1-12, 19, 24, 29, 30 and both Graves Avenue sites are designated as MRZ-3, and Sites 18, 20B, 35, and 25 are designated as a mix of both MRZ-2 and MRZ-3. Although some Rezone Sites are located within a MRZ-2 designated area, these areas are not zoned for mining operations and the existing land use would also not be a mining land use as mining would not be a consistent land use with the surrounding area. While these lands may support mineral resources, mining operations at these sites would not be feasible considering the proximity to sensitive receptors and existing established neighborhoods. Furthermore, the Rezone Sites are not designated as locally important mineral resource recovery sites in the Santee General Plan. Therefore, the project would not result in the loss of availability of a known mineral resource or locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. (Draft PEIR, p. 8-6) There would be no cumulative impacts to mineral resources from the proposed project.

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M. NOISE
Future development at the Rezone Sites would result in a significant noise increase over existing ambient noise levels at nine of the analyzed roadway segments. The Noise Element contains Policies 2.2 and 2.3 that requires new development to mitigate the noise impact to existing uses resulting from new development. Possible noise-reduction measures would include retrofitting older homes with new window and door components with higher sound transmission class ratings. However, for existing uses, it cannot be determined whether the existing structures contain adequate attenuation to reduce interior noise to the 45 A-weighted decibels day-night equivalent level [dB(A) Ldn] standard nor what measures would be required to retrofit these structures. In addition, there is no mechanism in place for implementing such a retrofit. Because the significant noise impacts are to existing homes in an already urbanized area, there is no feasible mitigation and potentially significant cumulative noise impacts would remain significant and unmitigated.

Future development at the Rezone Sites could expose sensitive receivers to exterior noise levels that exceed 65 community noise equivalent level and impacts from vehicle traffic would be significant. Regarding interior noise, future ministerial and discretionary projects would be required to demonstrate that interior noise levels would be reduced to 45 dB(A) Ldn or less. Mitigation measures NOS-1 would address land use compatibility impacts related to vehicle traffic and requires the City to assess whether proposed noisesensitive receivers or associated noise-sensitive exterior use areas would be subject to transportation noise levels that potentially conflict with policies established in the City’s General Plan. Therefore, implementation of mitigation measure NOS-1 and implementation of the General Plan policies would reduce noise impacts associated with transportation to a level less than significant ensuring that the project would not contribute to a significant cumulative noise impact.

Regarding stationary noise, the City requires that noise from new stationary sources comply with the City’s Noise Abatement and Control Ordinance, which provides general noise regulations, prohibits disturbing, excessive or offensive noises, and places noise limitations on motorized equipment and loading and unloading operations. Noise Abatement and Control Ordinance requirements would reduce nuisances to sensitive land uses. With enforcement of the Noise Abatement and Control Ordinance, noise impacts (direct and cumulative) associated with stationary sources of noise would be less than significant.

Construction activities associated with any individual development may occur near noisesensitive receptors and noise disturbances may occur. Without project-specific information to evaluate potential construction noise impacts and specific distances to sensitive receptors, impacts are considered significant at this programmatic level of review. Mitigation measures NOS-2 and NOS-3 would address potentially significant impacts related to construction noise associated with development within the Rezone Sites. The City shall require preparation and implementation of a construction noise best Findings

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management practice plan that demonstrates house noise levels would be minimized to comply with the time of day restrictions and notification requirements of the City’s Municipal Code. Mitigation measure NOS-3 would ensure future development with the potential to generate substantial vibration implement a plan to ensure vibration thresholds are not exceeded during construction. Implementation of the requirements specified in mitigation measures NOS-2 and NOS-3 would reduce construction noise exposure to a level less than significant. However, for construction sites that are adjacent to noisesensitive uses, there still could be a substantial temporary increase in noise levels that could lead to adverse noise-related impacts. Other construction sites could create similar increases in noise levels, resulting in a cumulative construction noise impact, which would be significant and unavoidable. (Draft PEIR, pp. 7-9 through 7-10) N. POPULATION AND HOUSING
The study area considered for the population and housing cumulative impact analysis is defined as the region. Buildout of the project would respond to the need for affordable housing in compliance with Regional Housing Needs Assessment allocation and associated projected population increase within the City through the horizon year. The increase in housing stock would accommodate the projected growth in population in the region and is consistent with adopted plans and regional growth principles. No permanent displacement of housing or people would occur with implementation of the project.

Significant population and housing impacts associated with cumulative development within the region is not anticipated to result in a displacement of housing or people because future development is generally growth accommodating and each jurisdiction has a mandate to comply with its adopted Housing Element and associated Regional Housing Needs Assessment allocation. Therefore, cumulative impacts associated with population and housing would be less than significant. (Draft PEIR, pp. 7-10 through 7- 11)
O. PUBLIC SERVICES
The study area for public services is the applicable provider’s service area. New development or redevelopment within the service area could result in cumulative impacts associated with additional demands for public services, resulting in the need for new or expanded facilities. All future development within the City would be reviewed to ensure that adequate facilities and services are available at the time of application. Other projects proposed in the City would similarly be required to demonstrate adequate facilities are available prior to development. All future development is required to pay applicable fees that support schools, parks, and recreational facilities. Cumulative impacts would be less than significant. (Draft PEIR, p. 7-11)
P. RECREATION
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with additional demands for public services, resulting in the need for new or expanded facilities. All future development within the City would be reviewed to ensure that adequate facilities and services are available at the time of application. Other projects proposed in the City would similarly be required to demonstrate adequate facilities are available prior to development. All future development is required to pay applicable fees that support schools, parks, and recreational facilities. Cumulative impacts would be less than significant. (Draft PEIR, p. 7-11)
Q. TRANSPORTATION
The Office of Planning and Research (OPR) Technical Advisory recommends setting a VMT per capita threshold of 15 percent below that of existing development as a reasonable threshold. In other words, in order to result in a less than significant impact, VMT per capita resulting from a project should be at or below the 85thpercentile of the region’s average for that land use type (OPR 2018). The VMT analysis utilized the average resident VMT per capita for San Diego County as the regional average. A planto-ground analysis compared the project to Base Year (2016), which is representative of the baseline conditions. The City has a less efficient VMT per capita when compared to the region, at approximately 108 percent of the region’s resident VMT per capita. The higher VMT per capita in the City compared to the greater San Diego County is representative of major job centers being located in other areas of San Diego County and City residents relying heavily on commutes to job centers in other cities.

Future development at the Rezone Sites in conjunction with buildout of the City’s General Plan land use map and transportation network would result in a change from 20.5 VMT per capita in the base year (2016) to 18.7 VMT per capita, representing a slight increase in VMT efficiency in the City. Mitigation measure TRA-1 would ensure implementation of the Mobility Element Policies outlined in Chapter 4.13 that would support VMT reductions for individual projects. While mitigation measure TRA-1 would minimize VMT impacts associated with future development at the Rezone Sites, impacts would not be fully mitigated. This analysis is cumulative in nature as it considers citywide buildout of the existing plan plus the project. Based on the City’s higher VMT per capita compared to the regional average, other development in the City is also likely to result in significant VMT impacts. Therefore, cumulative impacts related to VMT would be significant and unavoidable. (Draft PEIR, pp. 7-11 through 7-12)
R. TRIBAL CULTURAL RESOURCES
The study area for the assessment of cumulative impacts to cultural resources includes the entirety of the City because loss of tribal cultural resources would be detrimental to the entire City. Future development within the cumulative study area could have a cumulative impact on tribal cultural resources through loss of records or artifacts as land is developed (or redeveloped).

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Future development in accordance with the project could impact historical or archaeological resources, which may be present within the project. Implementation of mitigation measures CUL-1, CUL-2, and CUL-3 would reduce impacts to tribal cultural resources to less than significant through the requirement for historic and archaeological surveys and archaeological monitoring during grading and construction. Implementation of these measures would ensure that the project would not contribute to a significant cumulative impact to tribal cultural resources. (Draft PEIR, p. 7-6) S. UTILITIES AND SERVICE SYSTEMS
The study area for public utilities is the applicable provider’s service area. Future development at the Rezone Sites is located within existing developed areas with access to utility infrastructure. Significant utility extensions or improvements are not anticipated beyond local connections from adjacent roadways. Utility infrastructure improvements and relocations associated with the future Rezone Sites would be evaluated in their respective subsequent environmental documents for discretionary projects, or as part of the ministerial review that will be implemented through an overlay zone that includes objective standards and requirements to reduce physical impacts to the extent feasible.

Similarly, other projects in the City would be required to undergo a similar review to ensure the environmental impacts of utility and services improvements are minimized. A cumulative impact related to the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects, is not anticipated. Cumulative impacts related to utilities and service systems would be less than significant.

Storm Water System. Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing stormwater infrastructure. Although future Rezone Sites would require connection to these existing facilities, stormwater infrastructure improvements would be evaluated upon submittal of project-specific development plans. All future project applications, whether discretionary or ministerial would be required to adhere to the mitigation framework presented in this PEIR which would ensure that any physical impacts associated with construction of pipeline connections to existing water infrastructure would be addressed as part of the City review for each individual project. At this program-level of review, the project’s incremental contribution to storm water facility impacts would not be cumulatively considerable.

Wastewater. Development anticipated in the Rezone Sites would occur within areas of the City that are already served by existing wastewater utility infrastructure. Although future Rezone Sites would require connection to these existing facilities, wastewater utility infrastructure improvements and relocations would be evaluated upon submittal of project-specific development plans. All future project applications, whether discretionary or ministerial, would be required to adhere to the mitigation framework presented in this PEIR which would ensure that any physical impacts associated with construction of pipeline connections to wastewater infrastructure would be addressed as part of the City Findings

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review for each individual project. Thus, the project’s incremental contribution to wastewater impacts would not be cumulatively considerable.

Water System/Water Supply. Cumulative impacts related to the water system and water supply would be less than significant because future development within the City would require a project-by-project review to confirm the availability of adequate fire hydrant flow, and if necessary, determine the local water system improvements needed to achieve required fire hydrant flow. Buildout potential within the Rezone Sites could result in the construction of up to 1,945 residential dwelling units that have not all been accounted for within the latest Padre Dam Municipal Water District (PDMWD) planning documents.

Urban Water Management Plans (UWMPs) are required to be updated on a five-year cycle and the next update to the PDMWD UWMP is anticipated by 2025. Future UWMP updates would account for the anticipated water use associated with future development consistent with any adopted rezones. While the proposed rezones would add development potential within the City, they would primarily authorize higher density residential development which is more water efficient than single-family residential. Based on the water efficiency of multi-family development, water conservation requirements, along with existing regulations that require new construction to be water efficient, it is not anticipated that the project would affect the ability of PDMWD to plan for adequate water supplies within the City during normal, dry, and multiple dry years. Thus, the project’s incremental contribution to water system/water supply impacts would not be cumulatively considerable.

Solid Waste Disposal. Cumulative impacts related to solid waste disposal would be less than significant because an existing regulatory framework is in place that would apply to future development associated with the project in addition to cumulative development within the City. Future development at the Rezone Sites is located within existing developed areas with access to solid waste disposal services. No development is proposed as part of the project; however, it is anticipated that future projects would result in an increase in solid waste generation. Solid waste requirements associated with the future development of the Rezone Sites would be evaluated upon submittal of projectspecific development plans. All projects whether discretionary or ministerial would be reviewed for conformance with state and local regulations and adherence to General Plan policies. Thus, with implementation of the existing regulatory framework addressing solid waste disposal, the project’s incremental contribution to solid waste disposal impacts would not be cumulatively considerable. (Draft PEIR, pp. 7-12 through 7-13) T. WILDFIRE
The study area for the assessment of cumulative impacts related to wildfire is the City.

Development at the Rezone Sites would not physically interfere with any emergency response or evacuation plans because they would not include any features that would prevent continued implementation of these plans. Additionally, applicable General Plan Safety Element policies would continue to be implemented to ensure adequate citywide emergency response and preparedness. Development of the Rezone Sites, especially Findings

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within or adjacent to Very High Fire Hazard Severity Zone, could potentially result in impacts related to wildfire. However, future ministerial and discretionary development at Housing Sites would be required to adhere to all regulatory requirements in place to minimize wildfire hazards including applicable sections of the Municipal Code, fire and building codes, and requirements from the fire chief that would be identified during future building permit reviews. Additionally, implementation of the City’s General Plan policies support implementation of measures that will enhance wildfire safety. Future discretionary projects would require review by the Building Official/Fire Marshal. All impacts associated with infrastructure improvements including any required measures to address fire safety would be evaluated in their respective subsequent environmental documents for discretionary projects, or as part of the ministerial review for by-right sites. The City fire chief may also use their authority to require additional building, planning, or landscaping requirements that provide enhanced fire protection. Development of future Rezone Sites would be required to comply with applicable regulations and policies related to flooding, drainage patterns, and landslides, and thereby avoid significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Like the project, all future development in the City would be required to comply with applicable Municipal Code and building and fire code regulations that would reduce the potential for cumulative impacts. The project’s incremental contribution to impacts related to wildfire would not be cumulatively considerable. (Draft PEIR, pp. 7-13 through 7-14)
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SECTION VI.

FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL

CHANGES
Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any significant irreversible environmental changes that would occur should the project be implemented. Generally, a project would result in significant irreversible environmental changes if any of the following would occur:
• The project would involve a large commitment of non-renewable resources; • The primary and secondary impacts of the project would generally commit future generations to similar uses;
• The project involves uses in which irreversible damage could result from any potential environmental accidents; or
• The proposed consumption of resources is not justified.

Implementation of the 6th Cycle Housing Element Rezone Program (project) would result in significant, unavoidable impacts associated with the following issues: air quality (consistency with air quality plans, criteria pollutants), greenhouse gas emissions (emissions, policy consistency), noise (ambient noise), and transportation (vehicle miles traveled [VMT]).

These impacts would remain significant and unavoidable as a result of the project. All other significant impacts can be reduced to below a level of significance with implementation of the mitigation framework provided in Chapter 4.0 of the PEIR.

Non-renewable Resources. A majority of the 25 housing rezone sites and two Graves Avenue sites, collectively known as the Rezone Sites, are located within existing developed or disturbed areas; however, a few sites are located on vacant land with potentially sensitive resources present. While the potential for impacts to biological habitat and cultural resources is low, there is a potential for impacts to resources at certain sites.

Biological and cultural resource impacts associated with future development would be mitigated to a level less than significant. The potential for paleontological resources impacts to occur associated with future development at the Rezone Sites would be mitigated to less than significant with implementation of a mitigation framework that would ensure paleontological monitoring is required (where appropriate). Implementation of the project would result in less than significant impacts to water bodies (drainage and water quality).

The Farmland Mapping and Monitoring Program classifies the majority of the Rezone Sites as “Urban and Built Up Land,” “Other Land,” and “Grazing Land.” The areas classified as “Grazing Lands” are not considered a significant farmland resource under CEQA. A few Rezone Sites are classified as “Farmland of Local Importance”; however, there is no recent history of agricultural use at these sites. There are no lands protected Findings

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by a Williamson Act Contract within the City. There are no lands protected by a Williamson Act Contract within the City. Additionally, there is no forestland within the City, and the City does not possess any zoning classifications for forestland, timberland, or timberland production zones. Therefore, no impacts to agricultural and forestry resources would occur.

Although Rezone Sites 1-12, 18, 19, 24, 25, 29, and 30 and both Graves Avenue Sites are located within a Mineral Resource Zone (MRZ) 2 designated area, these areas are not zoned for mining operations and no mining operations existing within the sites While these lands may support mineral resources, mining operations at these sites would not be feasible considering the proximity to sensitive receptors and existing established neighborhoods. Furthermore, the Rezone Sites are not designated as locally important mineral resource recovery sites in the City’s General Plan. Therefore, the project would not result in the loss of availability of a known mineral resource or locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan, and impacts would be less than significant.

With regard to energy resources, actions related to future development would result in an irretrievable commitment of nonrenewable resources, including energy supplies and construction materials, such as lumber, steel and aggregate. Non-renewable energy resources (coal, natural gas, oil) would be used in construction, heating and refrigeration of food and water, transportation, lighting, and other associated energy needs.

Residential and mixed-use development anticipated within the Rezone Sites, together with other projects in the City, would require the commitment or destruction of other nonrenewable and slowly renewable resources. These resources include (but are not limited to) lumber and other forested products; sand and gravel; asphalt; petrochemical construction materials; steel, copper, lead, other metals; and water. However, the amount and rate of consumption of these resources would not result in significant environmental impacts because multi-family and mixed-use development are not uses that are associated with an unnecessary, inefficient, or wasteful use of resources.

The Rezone Sites are mainly developed with existing commercial uses or located on underutilized residential sites. Development at the Rezone Sites would reinvigorate underutilized areas by allowing new residential uses in close proximity to commercial services and community facilities, while preserving established residential neighborhoods. Most of the project areas are presently developed. Development on vacant parcels would, however, result in the long-term commitment to urbanization because reversion back to vacant land would be difficult and highly unlikely. However, the development of mid- to high-density residential units or mixed-uses would result in an efficient provision of housing and efficient land use pattern.

In summary, future construction and operation associated with implementation of the Rezone Program would result in the irretrievable commitment of limited, slowly renewable, and nonrenewable resources, which would limit the availability of these particular resource quantities for future generations or for other uses. Therefore, although Findings

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irreversible environmental changes would result from future development, such changes would not be considered significant.

Secondary Impacts. The Rezone Sites are accessible via major roadways (e.g., State Routes (SR) 52, 67, and 125, as well as numerous arterials and local streets) and are served by existing utilities, and other public services. As a result, secondary impacts are not anticipated from environmental changes resulting from the construction of new infrastructure.

Environmental Accidents. The CEQA Guidelines also require a discussion of the potential for irreversible environmental damage caused by an accident associated with the project. Implementation of the proposed project would allow for the development of residential and mixed-uses (including commercial uses) that commonly store, use, and dispose of hazardous materials. Likewise, industries and businesses using hazardous materials may expand or increase to accommodate the projected population growth under buildout of the project.

Due to the nature of past and current land uses, future development/redevelopment within the City has the potential to expose people and the environment to hazards through the routine transport, use, disposal, or accidental release of hazardous materials. Businesses that are likely to store hazardous substances and petroleum products or generate waste include the following: gasoline service stations, automobile repair facilities, dry cleaning facilities, photograph developing facilities, and medical and dental facilities.

All future projects would be subject to review to ensure conformance with the Municipal Code, General Plan policies, and regulations imposed by federal, state, and local agencies. Compliance with applicable federal, state, and local hazardous materials regulations such as the Chemical Accident Prevention Provision, Emergency Planning and Community Right-to-Know Act, the Robert T. Stafford Disaster Relief and Emergency Assistance Act, the California Health and Safety Code, California Code of Regulations Title 23, the Aboveground Petroleum Storage Act, California Accidental Release Prevention Program, and the California Emergency Services Act would ensure that buildout of the Rezone Sites would not result in irreversible environmental damage related to the accidental release of hazardous materials. (Draft PEIR, pp. 5-1 through 5-4) Findings

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SECTION VII.

GROWTH-INDUCING IMPACTS
Section 15126.2(e) of the State CEQA Guidelines requires a Draft EIR to discuss the ways the Project could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment. In accordance with State CEQA Guidelines Section 15126.2(e), a Project would be considered to have a growth-inducing effect if it would:
• Directly or indirectly foster economic or population growth, or the construction of additional housing in the surrounding environment;
• Remove obstacles to population growth (e.g., construction of an infrastructure expansion to allow for more construction in service areas); • Tax existing community service facilities, requiring the construction of new facilities that could cause significant environmental effects; or • Encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively.

In addition, CEQA Guidelines state that growth inducement must not be assumed.

Population and Housing Growth. The project would result in the adoption of rezones required to implement the 6thCycle Housing Element as described in Table 3-2. The rezoning of the 25 housing sites and the two sites located on Graves Avenue, collectively referred to as the Rezone Sites, would result in the potential future construction of up to 1,945 residential units which more than accommodates the Regional Housing Needs Assessment (RHNA) allocation of 1,219 units for the City’s share of statewide forecasted growth through April 15, 2029. Overall, the region needs to plan for an additional 171,685 units. The San Diego Association of Governments (SANDAG) has allocated the City its share of the regional housing need for the 2021-2029 RHNA period based on a number of factors, including recent growth trends, income distribution, and capacity for future growth. As the project would implement necessary rezones needed to facilitate construction of housing in the City to meet state housing mandates, it would support and encourage redevelopment of housing to support a range of income levels in the City. For projects that would be allowed to process ministerially, some obstacles to development would be removed, particularly the processing time and cost associated with a discretionary entitlement process. However, the project does not involve other changes in the environment (such as construction of a wastewater treatment plant or a road within an undeveloped area) that would allow for unplanned population growth. Therefore, while the project would result in growth, it would be growth that has been anticipated under the City’s Housing Element and would accommodate the City’s RHNA allocation associated with anticipated growth in the City.

Findings

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Removal of an Impediment to Growth. The project does not propose the construction or expansion of new housing, services, or other infrastructure development; rather it would adopt rezones that would facilitate future development consistent with state Housing Element Law. A vast majority of the permitted future residential units and mixeduse development would occur as infill development and redevelopment within urbanized areas already served by essential roads, utilities, and public services. Therefore, the project would not remove an impediment to growth.

Foster Economic or Employment Growth. The City is adding a new R-30 Mixed-Use Overlay Zone that would apply within the Town Center to allow mixed-use development and a residential density range of 30 to 36 dwelling units per acre. Specifically, Rezone Sites 16A and 20B would be designated with the new R-30 zone, potentially allowing a combined 633 residential units with mixed use commercial at these sites. New commercial uses permitted within the mixed-use overlay zone would generally be composed of local neighborhood-serving retail and office uses, intended to serve the residents of new and existing housing in the immediate area. The project additionally would rezone two Graves Avenue sites to General Commercial which would allow for a range of commercial uses. These rezones would allow for commercial development in new areas which would foster economic growth consistent with the City’s existing commercial growth projections based on the SANDAG modeling completed for the transportation analysis. The potential for new commercial land uses with the proposed rezones would therefore be consistent with existing projections for commercial development in the City and would not be considered growth inducing in regard to significant economic or employment growth for the City.

Conclusion. Overall, the project would facilitate growth through rezoning to allow more housing to meet RHNA allocations. However, the project would not induce unplanned growth. The project would serve to accommodate projected and planned growth under the City’s Housing Element and pursuant to the City’s RHNA allocation. The project would not remove an impediment to growth; nor does it propose to develop or permit the encroachment into an isolated area adjacent to open space, or foster economic and employment expansion. As discussed above, the project would accommodate projected population growth and would not be considered growth inducing because it would provide housing capacity for projected population growth. The opportunities to provide housing would be consistent with the City’s need to establish a resilient housing base for the community and comply with state law. (Draft PEIR, pp. 6-1 through 6-2) Findings

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SECTION VIII.

ALTERNATIVES
A. BACKGROUND
The Draft PEIR analyzed two alternatives to the Project as proposed and evaluated these alternatives for their ability to avoid or reduce the Project’s significant environmental effects while also meeting the majority of the Project’s objectives. The City finds that it has considered and rejected as infeasible the alternatives identified in the EIR and described below. This section sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light of the Project objectives, as required by CEQA.

Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions.

Subsection (a) states:
(a) An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Subsection 15126.6(b) states the purpose of the alternatives analysis:
(b) Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:
(c) The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives Findings

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that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice of alternatives may be included in the administrative record. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Project.

Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project.

B. PROJECT OBJECTIVES
The following objectives have been established for the Project (Draft PEIR, pp. 9- 1 through 9-2):
• Implement Program 9 of the 6th Cycle 2021-2029 Housing Element to provide for the opportunity for future residential development on various sites throughout the City as identified by the Sites Inventory, with a density range of 30 to 36 dwelling units per acre (du/ac) on selected sites.
• Also consistent with Program 9 and Program 10 of the 6thCycle 2021- 2029 Housing Element, provide a minimum of 25 acres to be rezoned (within 18 months of Housing Element adoption) to permit multi-family housing by right (without discretionary action) and to meet the requirements of Government Code 65583.2, including but not limited to a minimum density of 20 units per acre.
• Maintain adequate housing sites for all income groups throughout the eight-year planning period.
• Minimize potential land use compatibility conflicts associated with the proposed change to existing land use designations and zoning. • Increase the City of Santee’s (City) overall housing capacity and capability to accommodate housing as required per the adopted Housing Element for the 2021-2029 housing cycle.

C. ALTERNATIVES CONSIDERED BUT REJECTED FROM DETAILED

ANALYSIS
Findings

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Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency’s determination.

Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant environmental impacts.

Alternative rezone sites were considered but rejected as part of the environmental analysis for the Project.

Finding: The City Council rejects the alternative rezone sites, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative does not avoid any significant and unavoidable impacts, (2) the alternative would likely not further reduce any of the proposed project’s significant impacts; and (3) the alternative is technically, financially, and legally infeasible.

Therefore, this alternative is eliminated from further consideration.

D. EVALUATION OF ALTERNATIVES SELECTED FOR ANALYSIS
The alternatives selected for further detailed review within the EIR focus on alternatives that could the Project’s significant environmental impacts, while still meeting most of the basic Project objectives. Those alternatives include:
• Alternative 1: No Project (No Rezone Program) Alternative (Draft PEIR, pp. 9-3 through 9-8)
• Alternative 2: Reduced Project Alternative (Draft PEIR, pp. 9-9 through 9-16)

1. Alternative 1: No Project (No Rezone Program) Alternative Description: Under the No Project Alternative, development within the City would proceed pursuant to the adopted General Plan and zoning map, which would have lesser overall residential development potential and would not include implementation of the 6th Cycle Housing Element Programs 9 and 10. Zoning changes at the Rezone Sites would not be contemplated and existing zoning would remain in place. The No Project Alternative would not consider adoption of rezones necessary to achieve the City’s Regional Housing Needs Allocation (RHNA). (Draft PEIR, p. 9-3)
Impacts: Aesthetics. Under the No Project Alternative, development throughout the City would continue based on existing zoning. The No Project Alternative would not result in the increased residential density required to meet the City’s RNHA objectives. Although higher density development could not occur at these sites, development could proceed based on the existing land use designation and zoning. Development under the No Project Alternative would be subject to Findings

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Development Review consistent with Municipal Code Chapter 13.08 to ensure consistency with General Plan policies and applicable design and development review requirements including supplemental development regulations from the Town Center Specific Plan. The Development Review process would ensure that future development would not degrade scenic vistas, scenic resources, or visual quality. Compliance with Municipal Code standards related to light and glare (Chapter 13.08.070(G)), requiring that outdoor lighting be directed away from adjacent properties and set in a way to avoid any detriment to the surrounding area and lighting standards of the Community Enhancement Element would ensure that future development would not result in impacts related to light and glare. Therefore, impacts related to aesthetics under the No Project Alternative would be less than significant, and slightly reduced compared to the project due to decreased density associated with the retention of existing zoning.

Air Quality. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan, and therefore would be consistent with the existing growth projections for which regional air quality standards (RAQs) are based. Although development potential would be less compared to the project, construction time frames and equipment for site-specific development projects are not available at this time, and there is a potential for multiple development projects to be constructed at one time, resulting in significant construction-related emissions. While future development under this alternative would be required to implement mitigation measures documented in the City’s General Plan, mitigation for air quality impacts would remain significant and unavoidable. Therefore, impacts associated with air quality under the No Project Alternative would be significant and unavoidable, the same as the project.

Biological Resources. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project, which is consistent with the existing General Plan and zoning. Although this decreased density could reduce impacts to biological resources, development consistent with the existing zoning designations could still occur within areas that support sensitive resources.

Future development under the No Project Alternative would be subject to implementation of mitigation measures documented in the City’s General Plan for biological resources, which would reduce impacts related to sensitive species, sensitive habitats, and wetlands to a level less than significant. Therefore, impacts related to biological resources under the No Project Alternative would be less than significant, and slightly reduced compared to the project due to decreased density associated with the retention of existing zoning.

Cultural Resources and Tribal Cultural Resources. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan. The No Project Alternative would develop approximately 1,209 Findings

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fewer multi-family dwelling units compared to the project, which is consistent with the existing General Plan and zoning. Future development under this alternative would be required to implement mitigation measures documented in the City’s General Plan for cultural resources and conduct tribal consultation consistent with the requirements of Assembly Bill (AB) 52. However, the City’s General Plan EIR determined that some potential impacts associated with cultural resources may remain significant even with application of mitigation measures. Therefore, impacts related to cultural resources under the No Project Alternative would be significant and unavoidable, and greater than the project.

Geology/Soils. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan and would be subject to the same regulations as the project. The No Project Alternative would develop approximately 1,209 fewer multi-family dwelling units compared to the project, but would support development consistent with the existing General Plan and zoning which could be subject to potential geologic hazards. Adherence to Safety Element policies, the Municipal Code, and the California Building Code would ensure that future development under this alternative would not cause substantial adverse effects associated with fault rupture, ground shaking, liquefaction, landslide, or expansive soils, and impacts would be less than significant. Similarly, adherence to applicable Municipal Code requirements would ensure that future development under this alternative would not result in substantial soil erosion or the loss of topsoil, and impacts would be less than significant. Implementation of mitigation measures documented in the City’s General Plan for paleontological resources would reduce impacts related to paleontological resources to a level less than significant. Therefore, impacts related to geology and soils under the No Project Alternative would be mitigated to a level less than significant, the same as the project.

Greenhouse Gas Emissions. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan and would be subject to implementation of the City’s Sustainable Santee Plan (Climate Action Plan). However, development under the No Project Alternative could result in significant and unmitigated impacts related to GHG emissions due to VMT inefficiency. Therefore, impacts associated with GHG under the No Project Alternative would be significant and unavoidable, the same as the project.

Hazards and Hazardous Materials. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project, and thereby result in fewer residential units that may be affected by potential hazards and hazardous materials. Future development would be required to adhere to multiple regulations related to hazardous materials handling and transport, including applicable state and local regulatory measures. Citywide General Plan Safety Element policies would also support safe handling of hazardous materials. Future development under this alternative would be required to implement mitigation measures documented in the City’s General Plan for hazardous materials. Future Findings

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development under this alternative located within the Gillespie Field and MCAS Miramar Airport Land Use Compatibility Plans (ALUCPs) would be required to adhere to applicable City policies and regulations, as well as policies of the ALUCP. Furthermore, applications for all future projects under the No Project Alternative would be reviewed and approved by the Santee Fire Department prior to issuance of a building permit. Therefore, impacts associated with hazards and hazardous materials under the No Project Alternative would be mitigated to a level less than significant, the same as the project.

Hydrology and Water Quality. Future development under the No Project Alternative would be required to adhere to all applicable water quality standards as provided in various water quality regulations and plans including all pertinent requirements of the City’s Jurisdictional Runoff Management Plan, Best Management Practice (BMP) Design Manual, National Pollutant Discharge Elimination System (NPDES) General Construction Permit, as well as all regulations related to water quality. Both redevelopment and new development on vacant sites would be required to comply with applicable stormwater management requirements which focuses on retention and infiltration of waters on-site.

Additionally, development under this alternative would be required to comply with City General Plan policies and regulations that prioritize infiltration and treatment of stormwater. Future development would also be required to implement applicable stormwater BMPs and erosion control measures to retain flows on-site and minimize the velocity of stormwater runoff. Such BMPs could include on-site drainage swales, bioretention features, use of permeable pavers in parking areas and streets, or infiltration basins which also serve as a means for pollutant removal.

Development under this alternative would be required to adhere to all state and local development regulations including the Municipal Code (Chapter 11.36), which establishes Flood Damage Prevention standards. Therefore, impacts associated with hydrology and water quality under the No Project Alternative would be less than significant, and slightly reduced compared to the project due to decreased density associated with the retention of existing zoning.

Land Use and Planning. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan. All future development under this alternative would be subject to a site-specific review that considers consistency with all applicable plans, including the City’s General Plan. Therefore, impacts related to land use under the No Project Alternative would be less than significant, the same as the project.

Noise. Future development under the No Project Alternative would occur consistent with the City’s adopted General Plan land use plan and would be subject to implementation of mitigation measures documented in the City’s General Plan for noise to reduce potential impacts to a level less than significant. However, even with implementation of the mitigation measures, noise impacts could remain significant and unmitigated. Therefore, impacts associated with noise under the Findings

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No Project Alternative would be significant and unavoidable, the same as the project.

Population and Housing. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project, and thereby result in less population growth. Future development under the No Project Alternative would be located in areas that are already served by infrastructure, and therefore would not induce population growth. The No Project Alternative would not displace a substantial number of people or housing. Therefore, impacts associated with population and housing would be less than significant, the same as the project.

Public Services and Recreation. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project, and thereby result in fewer residential units that would require public services and recreation facilities. Future development under the No Project Alternative would not directly result in sufficient demand to require construction of new fire protection, police protection, school, library, or park and recreation facilities, since each incremental housing development would pay its fair share toward anticipated facility needs.

Construction of any future public service or recreation facilities would require a separate environmental review and approval. Therefore, impacts associated with public services and recreation would be less than significant, and slightly reduced compared to the project due to decreased density associated with the retention of existing zoning.

Transportation. Future development under the No Project Alternative would be subject to an engineering and policy review that would ensure consistency with applicable policies related to transit, roadway, bicycle, and pedestrian facilities.

The No Project Alternative does not propose any changes to the existing roadway network. The Transportation Impact Study prepared for the project determined that buildout of the No Project Alternative would generate an average resident VMT per capita of 18.7, which would be a reduction compared to 20.5 under the 2016 base year. However, the 18.7 VMT per capita under buildout of the No Project Alternative represents 98 percent of the base year regional average. Therefore, VMT per capita associated with the No Project Alternative would be greater than 85 percent of the regional average and would exceed the VMT threshold. Future development would be designed consistent with established roadway design standards, and access to the existing roadway network would be configured consistent with established roadway design standards that would allow for emergency access. Therefore, impacts associated with transportation would be significant and unavoidable, the same as the project.

Utilities and Service System. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project, and thereby result in fewer residential units that would require utility services. However, development under the existing General Plan would increase demand for utilities Findings

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and services. Utility infrastructure improvements and relocations under the No Project Alternative would be evaluated as part of a future review for site-specific projects. Should separate utility extensions be required outside of the footprints of future site-specific projects, they would require an environmental review and compliance with regulations in existence at that time would address potential environmental impacts. The No Project Alternative would likely result in less demand for water supply, wastewater treatment, and solid waste disposal compared to development proposed under the project. Therefore, impacts associated with utilities and service system would be less than significant, and slightly reduced compared to the project due to decreased density associated with the retention of existing zoning.

Wildfire. The No Project Alternative would develop approximately 1,209 fewer dwelling units compared to the project, and thereby result in fewer residential units that may be exposed to wildfire. This alternative does not propose any changes to the City’s existing circulation network, and no land uses are proposed that would impair implementation of or physically interfere with the City’s emergency response plan, evacuation routes, or conflict with any of the Multi-Jurisdictional Hazard Mitigation Plan specific hazard mitigation goals, objectives, and related actions.

Additionally, future development would be required to adhere to the City’s General Plan (Safety Element) policies including, 4.2, 4.3, 4.4, 4.11, and 4.12 which address emergency response and emergency evacuation. Future development located within the Very High Fire Hazard Severity Zone (VHFHSZ) would comply with applicable California Fire Code and City General Plan requirements, and include enhanced fire protection measures as detailed in the City’s building and fire codes. Future development under this alternative would also be required to comply with applicable regulations and policies related to flooding, drainage patterns, and landslides. Therefore, impacts associated with wildfire under the No Project Alternative would be less than significant, and slightly reduced compared to the project due to decreased density associated with the retention of existing zoning.

The No Project Alternative would result in similar impacts compared to the project, with only cultural and tribal cultural resources seeing an increase in the severity of impacts. The No Project Alternative would develop approximately 1,209 fewer dwelling units, resulting in less density throughout the City; however, future development would be required to adhere to existing state and local regulations and would be required to implement relevant mitigation measures set forth in the City’s General Plan EIR. Therefore, impacts associated with geology and soils, hazards and hazardous materials, land use, and population and housing would be the same compared to the project. Impacts associated with aesthetics, biological resources, hydrology and water quality, public services and recreation, utilities and service system, and wildfire would be slightly reduced under this alternative due to the retention of the existing zoning designations, which would decrease density at these sites. Impacts related to air quality, GHG, noise, and transportation would be significant and unavoidable, the same as the project. Impacts related to cultural Findings

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and tribal cultural resources would be significant and unavoidable, greater than the project. Furthermore, the No Project Alternative would not meet any of the project objectives.

Attainment of Project Objectives: This alternative would not satisfy any of the project objectives because buildout of the No Project (No Rezone) Alternative would not provide enough residential units to meet the City’s RHNA allocation; nor would it implement Housing Element programs.

Finding: The City Council rejects Alternative 1: No Project (No Rezone Program) Alternative, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative fails to meet any of the Project objectives; (2) the alternative fails to avoid or reduce the Project’s significant and unavoidable impacts relating to air quality, GHG, noise, and transportation; and (3) the alternative would result in increased impacts relating to cultural and tribal cultural resources.

2. Alternative 2: Reduced Project Alternative
Description: The Reduced Project Alternative would remove Rezone Sites 1 through 10 from consideration for future rezone actions and associated residential development. Rezone Sites 1 through 10 would retain the existing Low Density Residential (R-1A) zoning designation.

Removal of these 10 Rezone Sites would reduce the potential for development of approximately 124 residential units at these sites. However. the Reduced Project Alternative would still allow for adoption of rezones up to approximately 1,821 residential units, which would exceed the 1,209 units needed through rezones to accommodate the City’s RHNA allocation. Therefore, the Reduced Project Alternative would ultimately result in development of an adequate amount of new residential options; however, a subset of the rezone sites that could be developed would be eliminated. All other aspects of the project would remain the same, including adoption of Housing Element Program 9, Housing Element Program 10, and rezoning of the Graves Avenue Parcels.

Impacts: Aesthetics. The Reduced Project Alternative would remove Rezone Sites 1 through 10 located just north of the urbanized portion of the City. Future development of these sites would occur consistent with the existing R1-A (Low Density Residential) zoning designation, which would reduce alterations of scenic vistas, scenic resources, and visual quality in these locations compared to the project due to the decreased density. Potential impacts related to aesthetics would be the same for the remaining Rezone Sites. However, development under this alternative would be subject to Development Review consistent with Municipal Code Chapter 13.08 to ensure consistency with General Plan policies and applicable design and development review requirements including supplemental development regulations from the Town Center Specific Plan. The Development Findings

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Review process would ensure that future development would not degrade scenic vistas, scenic resources, or visual quality. Compliance with the Municipal Code standards related to light and glare (Chapter 13.08.070(G)), requiring that outdoor lighting be directed away from adjacent properties and set in a way to avoid any detriment to the surrounding area and lighting standards of the Community Enhancement Element would ensure that future development would not result in impacts related to light and glare. Therefore, impacts related to aesthetics under the Reduced Project Alternative would be less than significant, the same as the project, and incrementally reduced compared to the project due to the removal of Rezone Sites 1 through 10.

Air Quality. Although this alternative would reduce the potential for development of approximately 124 residential units compared to the project, the Reduced Project Alternative would still potentially allow for development of approximately 1,821 residential units through rezones. This remaining development potential through future rezones would exceed the 1,209 units that are needed through rezones to accommodate the City’s RHNA allocation. Therefore, while this alternative would provide less flexibility for potential rezone sites, the Reduced Project Alternative would ultimately result in development of the same number of residential units as the project since only a subset of the total sites will ultimately be selected for rezoning. As with the project, buildout of the Reduced Project Alternative would result in an increase in emissions compared to buildout of the adopted zoning and land use designations. Therefore, buildout of this alternative would exceed the assumptions used to develop the RAQS and would result in significant unavoidable impact associated with air quality plan consistency and operational criteria pollutants. Even with implementation of mitigation measure AQ-1, impacts associated with criteria pollutants during construction would remain significant and unavoidable. As with the project, buildout of the Reduced Project Alternative would not result in a carbon monoxide (CO) hot spot. Additionally, construction and operation of future development would not result in the exposure of sensitive receptors to toxic air contaminants (TACs) from construction activities, stationary sources, or mobile sources, and impacts would be less than significant.

Emissions from construction equipment, such as diesel exhaust, and volatile organic compounds (VOCs) from architectural coatings and paving activities may generate odors; however, these odors would be temporary, intermittent, and not expected to affect a substantial number of people. Once operational, future development implemented under this alternative would include residential and associated commercial uses that are generally not a source of objectionable odors.

Therefore, impacts associated with air quality under the Reduced Project Alternative would be significant and unavoidable, the same as the project.

Biological Resources. The Reduced Project Alternative would remove Rezone Sites 1 through 10 located just north of the urbanized portion of the City. Future development of these sites would occur consistent with the existing R1-A (Low Density Residential) zoning designation, which would potentially reduce impacts on sensitive plants, sensitive wildlife, including coastal California gnatcatcher Findings

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nesting birds or migratory birds, Diegan coastal sage scrub, valley, foothill grassland, and wetlands compared to the project due to the decreased density.

Potential impacts on biological resources would be the same for the remaining Rezone Sites. Implementation of mitigation measures BIO-1 through BIO-5 would reduce impacts to sensitive plants, sensitive wildlife, and sensitive vegetation communities to a level less than significant. Implementation of mitigation measure BIO-6 would reduce impacts to on-site jurisdictional waters and wetlands to a level less than significant. Implementation of mitigation measures BIO-1 through BIO-6 would ensure future development under this alternative would be consistent with the Draft Santee Subarea Plan by requiring site-specific surveys, determining the extent of any potential impacts, and providing mitigation to reduce impacts to a level less than significant. Therefore, impacts related to biological resources under the Reduced Project Alternative would be mitigated to a level less than significant, the same as the project, and incrementally reduced compared to the project due to the removal of Rezone Sites 1 through 10.

Cultural and Tribal Cultural Resources. Rezone Sites 1 through 10 that would be removed under the Reduced Project Alternative are not located adjacent to any known historic resources. Therefore, this alternative would not reduce potential impacts on historic resources compared to the project. Implementation of mitigation measure CUL-1 would reduce potential impacts associated with the remaining Rezone Site to a level less than significant. Rezone Sites 1 through 10 that would be removed under the Reduced Project Alternative are designated as having Moderate Potential for Register Eligible Buried Archaeological Sites.

Therefore, this alternative would slightly reduce potential impacts on archaeological resources, religious, and sacred uses or tribal cultural resources due to the decreased density of development at these sites. Potential impacts on archaeological resources, religious and sacred uses, or tribal cultural resources would be the same for the remaining Rezone Sites. Implementation of mitigation measures CUL-2 and CUL-3 would reduce potential impacts associated with the remaining Rezone Site to a level less than significant. This alternative would additionally implement Public Resources Code Section 5097.98 and California Health and Safety Code Section 7050.5 and comply with the California Native American Graves Protection and Repatriation Act (2001), the federal Native American Graves Protection and Repatriation Act (1990), as well as AB 52 to avoid adverse impacts to human remains. Therefore, impacts related to cultural resources under the Reduced Project Alternative would be mitigated to a level less than significant, and incrementally reduced compared to the project due to the removal of Rezone Sites 1 through 10 designated as having moderate potential for Register Eligible Buried Archaeological Sites.

Geology/Soils. Removal of Rezone Sites 1 through 10 from the Reduced Project Alternative would reduce the amount of land mapped with liquefaction potential.

However, all remaining Rezone Sites under this alternative are identified as having liquefaction potential. Adherence to Safety Element policies, the Municipal Code, and the Uniform Building Code would ensure that future development under this Findings

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alternative would not cause substantial adverse effects associated with fault rupture, ground shaking, liquefaction, landslide, or expansive soils, and impacts would be less than significant. Similarly, adherence to applicable Municipal Code requirements would ensure that future development under this alternative would not result in substantial soil erosion or the loss of topsoil, and impacts would be less than significant. Implementation of mitigation measure GEO-1 would reduce impacts related to paleontological resources to a level less than significant.

Therefore, impacts related to geology and soils under the Reduced Project Alternative would be mitigated to a level less than significant, the same as the project.

Greenhouse Gas Emissions. Although this alternative would reduce the potential for development of approximately 124 residential units, the Reduced Project Alternative would still potentially allow for development of approximately 1,821 residential units through rezones. This remaining development potential through future rezones would exceed the 1,209 units that are needed through rezones to accommodate the City’s RHNA allocation. Therefore, while this alternative would provide less flexibility for potential rezone sites, the Reduced Project Alternative would ultimately result in development of the same number of residential units as the project. Removal of Rezone Sites 1 through 10 located just north of the urbanized portion of the City would potentially have some incremental benefit in terms of GHG emission reductions since they are the furthest removed from activity centers and could generate more VMT per capita compared to other sites located within job centers and commercial areas. However, the degree of this VMT reduction is uncertain, and this alternative would still result in an increase in development not accounted for in the Sustainable Santee Plan. Both discretionary and by-right development implemented under the project would be required to incorporate each of the applicable measures identified in the Consistency Checklist to mitigate cumulative GHG emissions as well as applicable Transportation Demand Management measures listed in mitigation measure TRA-1. However, because the effectiveness of GHG and VMT reducing measures is context-sensitive and would vary depending on the site-specific project site, it is not guaranteed that each individual project would fully mitigate impacts at this program level of review. Therefore, impacts associated with GHG under the Reduced Project Alternative would be significant and unavoidable, the same as the project.

Hazards and Hazardous Materials. Future development would be required to adhere to extensive regulations related to hazardous materials handling and transport, including applicable state and local regulatory measures. Citywide General Plan Safety Element Policies would also supporting safe handling of hazardous materials. Implementation of mitigation measure HAZ-1 would reduce potential impacts associated with accidental release of unknown hazardous materials to a level less than significant. None of the Rezone Sites that would remain under this alternative are located within 0.25 mile of an existing school or adjacent to a known hazardous materials site. Rezone Sites that would remain Findings

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