Santee City Council
July 9, 2025

189

EXHIBIT B

MITIGATION MONITORING AND REPORTING PROGRAM
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10939 SUMMIT AVENUE

RESIDENTIAL PROJECT
AIR QUALITY and GREENHOUSE GAS STUDY
Prepared for:

Warmington Residential
3090 Pullman Street
Costa Mesa, California 92626
Prepared by:

October 2023
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
i
10939 SUMMIT AVENUE RESIDENTIAL PROJECT

SANTEE, CALIFORNIA
AIR QUALITY and GREENHOUSE GAS STUDY
Table of Contents
Page
PROJECT DESCRIPTION ..................................................................................................................... 1 REGULATORY SETTING..................................................................................................................... 4 Air Pollution Regulation.......................................................................................................... 4 California Air Resources Board .............................................................................................. 5 San Diego Air Polution Control District................................................................................ 8 Air Quality Management Plans .............................................................................................. 8 SDAPCD Rules and Regulations ............................................................................................10 Regional Climate and Local Air Quality ............................................................................... 11 Pollutants ................................................................................................................................... 11 Sensitive Receptors ................................................................................................................... 15 Monitored Air Quality ............................................................................................................. 15 AIR QUALITY IMPACT ANALYSIS .................................................................................................. 16 Methodology and Significance Thresholds........................................................................... 16 Construction Emissions............................................................................................................19 Operational Impacts ................................................................................................................. 21 GREENHOUSE GAS EMISSION DISCUSSION ...............................................................................25 CLIMATE CHANGE IMPACT ANALYSIS ....................................................................................... 36 Estimate of GHG Emissions .................................................................................................... 36 REFERENCES......................................................................................................................................... 54 List of Figures

Figure 1 Vicinity Map ............................................................................................................. 2 Figure 2 Site Plan ..................................................................................................................... 3 List of Tables
Table 1 Current Federal and State Ambient Air Quality Standards .............................. 5 Table 2 San Diego County Attainment Status ................................................................. 12 Table 3 Ambient Air Quality Data .................................................................................... 15 Table 4 SDAPCD Air Emission Significance Thresholds ............................................... 18 Table 5 Estimated Maximum Daily Construction Emissions With Dust Control Measures.................................................................................................................. 21 Table 6 Estimated Operational Emissions........................................................................ 23 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
ii
Table 7 Estimated Construction Greenhouse Gas Emissions........................................ 38 Table 8 Estimated Annual Energy-Related Greenhouse Gas
Emissions................................................................................................................. 39 Table 9 Estimated Annual Solid Waste and Water Use Greenhouse Gas Emissions . 39 Table 10 Estimated Annual Mobile Emissions of Greenhouse Gases ............................ 40 Table 11 Combined Annual Greenhouse Gas Emissions................................................. 40 Table 12 2017 Scoping Plan Consistency Analysis............................................................ 42 Table 13 San Diego Forward: The Regional Plan Consistency Analysis ....................... 48 Table 14 City of Santee General Plan Project Consistency Analysis .............................. 52 Appendices
Appendix A CalEEMod Air Quality and Greenhouse Gas Emissions Model Results – Summer/Annual Emissions
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
1 10939 SUMMIT AVENUE RESIDENTIAL PROJECT

SANTEE, CALIFORNIA
AIR QUALITY and GREENHOUSE GAS STUDY
This report is an analysis of the potential air quality and greenhouse gas impacts associated with the proposed 10939 Summit Avenue Residential Project, a multi-family residential development in the City of Santee, California. This study analyzes the potential for temporary air quality impacts associated with construction activity and impacts associated with project operation.

PROJECT DESCRIPTION
The proposed project site is 4.65 gross acres. The development footprint is approximately 2.42 acres in size (APN 378-190-01) and zoned Medium Density Residential (R-7). The project would construct a total of 50 multifamily units and related improvements including 100 garage parking spaces and 13 open surface spaces. The site is bordered by single-family residential development to the south and north, a church and vacant land to the west and single-family residences and vacant land to the east. Density would be 20.66 units per acre with a maximum building height of three stories and 35 feet.

Grading would require 17,500 cubic yards of soil export. Construction of the project is expected to begin in late-2024 and completed in early 2026. The project site is shown in Figure 1 - Vicinity Map). The preliminary site plan is shown on Figure 2 – Proposed Site Plan.

As part of the discretionary review process for the project, the applicant is required to prepare an Addendum to the previously certified Environmental Impact Report (EIR) for the City of Santee Housing Element. Information from the Air Quality/Greenhouse Gas Report will be used by a third-party consultant to prepare the Addendum.

The following measures are intended to demonstrate compliance with statewide regulations; and thus, have been incorporated into the air emissions modeling:
• The project will provide recycling bins in the trash enclosure areas; • The project will install drought-tolerant vegetation and water-efficient irrigation systems;
• The project will install low-water use appliances and fixtures; • The project will be compliant with SDAPCD Rule 67.0.1 which requires the use of low Volitile Organic Compound (VOC) paint (no greater than 100 grams/Liter) for use on buildng interior and exterior surface as well as traffic marking on paved/concrete surfaces and
• The project will install bicycle parking facilities.

Figure 1—Vicinity Map - Project Site
Figure 2— Site Plan
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
4 Dust Control Methods
The project would implement various construction dust control strategies as design features to be compliant with SDAPCD Rule 55. Compliance with these dust control measures are listed as follows and would be identified on grading plan approvals:
• During clearing, grading, earth-moving, excavation, or transportation of cut or fill materials, water trucks, sprinkler systems or hand watering shall be used to prevent dust from leaving the site and to create a crust after each day’s activities cease; • During construction, water trucks, sprinkler systems or hand watering shall be used to keep all areas of vehicle movement damp enough to prevent dust from leaving the site.

At a minimum, this would include wetting down such areas later in the morning, after work is completed for the day, and whenever winds exceed 15 mph during active operations. Watering of active disturbance areas, including active grading areas and unpaved roads, would occur approximately every 2 hours of active operations, approximately two times per work day (at a minimum);
• Speeds on unpaved roads shall be reduced to less than 10 miles per hour; • All grading and excavation operations shall be halted when wind speeds exceed 25 miles per hour;
• Dirt and debris spilled onto paved surfaces at the project site and on the adjacent roadways shall be swept, vacuumed, and/or washed at the end of each workday; and • All trucks hauling dirt, sand, soil, or other loose material to and from the construction site shall be covered and/or a minimum 2 feet of freeboard shall be maintained.

REGULATORY SETTING
Air Pollution Regulation
Air pollutants are regulated at the national, State, and air basin level; each agency has a different degree of control. The United States Environmental Protection Agency (USEPA) regulates at the national level; the California Air Resources Control Board (CARB) regulates at the State level; and the San Diego Air Pollution Control District (SDAPCD) regulates air quality in San Diego County.

The federal and state governments have been empowered by the federal and state Clean Air Acts to regulate the emission of airborne pollutants and have established ambient air quality standards for the protection of public health. The USEPA is the federal agency designated to administer national air quality regulations, while CARB is the state equivalent in the California Environmental Protection Agency. Local control over air quality management is provided by CARB through multi-county and county-level Air Pollution Control Districts (APCDs) (also 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
5 referred to as Air Quality Management Districts). CARB establishes statewide air quality standards and is responsible for the control of mobile emission sources, while the local APCDs are responsible for enforcing standards and regulating stationary sources. CARB has established 15 air basins statewide. The City of Santee is located in the San Diego Air Basin (SDAB), which is under the jurisdiction of the SDAPCD.

California Air Resources Board
CARB, which became part of the California EPA (CalEPA) in 1991, is responsible for ensuring implementation of the California Clean Air Act (CCAA), meeting state requirements of the federal Clean Air Act and establishing California Ambient Air Quality Standards (CAAQSs). It is also responsible for setting emission standards for vehicles sold in California and for other emission sources such as consumer products and certain off-road equipment. CARB also established passenger vehicle fuel specifications and oversees the functions of local air pollution control districts and air quality management districts, which in turn administer air quality activities at the regional and county level. The CCAA is administered by CARB at the state level and by the Air Quality Management Districts at the regional level. Both state and federal standards are summarized in Table 1. The federal "primary" standards have been established to protect the public health. The federal "secondary" standards are intended to protect the nation's welfare and account for air pollutant effects on soil, water, visibility, materials, vegetation, and other aspects of the general welfare.

Table 1
State and Federal Ambient Air Quality Standards

POLLUTANT AVERAGE
TIME
CALIFORNIA STANDARDS1 NATIONAL STANDARDS2
Concentration3 Method4 Primary3, 5 Secondary3, 6 Method7 Ozone8
(O3)
1 hour 0.09 ppm
(180 µg/m3) Ultraviolet
Photometry
__ Same as
Primary
Standard
Ultraviolet
Photometry
8 hours 0.070 ppm
(137µg/m3)

0.070 ppm
(137 µg/m3)
Carbon
Monoxide
(CO)
8 hours 9.0 ppm
(10 mg/m3)
Non-Dispersive
Infrared
Spectroscopy
(NDIR)
9 ppm
(10 mg/m3)
--
Non-Dispersive
Infrared
Spectroscopy
1 hour (NDIR) 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
Nitrogen
Dioxide
(NO2)10
Annual
Average

0.030 ppm
(57 µg/m3) Gas Phase
Chemiluminescence

0.053 ppm
(100 µg/m3)
Same as
Primary
Standard Gas Phase
Chemiluminescence
1 hour 0.18 ppm
(339 µg/m3)
100 ppb
(188 µg/m3) --
Sulfur Dioxide
(SO2)11
Annual
Average --
Ultraviolet
Fluorescence

0.03 ppm
(80 µg/m3) --
Pararosaniline
24 hours 0.04 ppm
(105 µg/m3)

0.14 ppm
(365 µg/m3) --
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
6 POLLUTANT AVERAGE
TIME
CALIFORNIA STANDARDS1 NATIONAL STANDARDS2
Concentration3 Method4 Primary3, 5 Secondary3, 6 Method7 3 hours -- -- 0.5 ppm
(1300 µg/m3)
1 hour 0.25 ppm
(655 µg/m3)
75 ppb (196
µg/m3) --
Respirable
Particulate
Matter
(PM10)9
24 hours 50 µg/m3
Gravimetric or Beta
Attenuation
150 µg/m3 150 µg/m3
Inertial Separation
and Gravimetric
Analysis
Annual
Arithmetic
Mean
20 µg/m3 -- --
Fine
Particulate
Matter
(PM2.5)9
Annual
Arithmetic
Mean
12 µg/m3
Gravimetric or Beta
Attenuation
12 µg/m3 15 µg/m3
Inertial Separation
and Gravimetric
Analysis
24 hours -- 35 µg/m3
Same as
Primary
Standard
Sulfates 24 hours 25 µg/m3 Ion
Chromatography -- -- --
Lead12, 13
(Pb)
30-day
Average 1.5 µg/m3
Atomic Absorption
-- --
High Volume
Sampler and Atomic
Absorption
Calendar
Quarter -- 1.5 µg/m3
Same as
Primary
Standard
3-month
Rolling
Average
-- 0.15 µg/m3
Hydrogen
Sulfide
(H2S)
1 hour 0.03 ppm
(42 µg/m3)
Ultraviolet
Fluorescence -- -- --
Vinyl
Chloride12 24 hours 0.010 ppm(26 µg/m3)
Gas
Chromatography -- -- --
Notes:
ppm = parts per million
µg/m3 = micrograms per cubic meter
mg/m3 = milligrams per cubic meter
Source: California Air Resources Board 2017

1. California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.

2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard.

For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
7 when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.

Contact the U.S. EPA for further clarification and current national policies.

3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

4. Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near the level of the air quality standard may be used.

5. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health.

6. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

7. Reference method as described by the U.S. EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the U.S. EPA.

8. On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to

0.070 ppm.

9. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/ m3 to 12.0 μg/ m3.

The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 μg/ m3, as was the annual secondary standard of 15 μg/ m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/ m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.

10. To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.

11. On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.

12. The CARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

13. The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead standard (1.5 μg/ m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

14. In 1989, the CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of

0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively. 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
8 San Diego Air Pollution Control District
The SDAPCD was created to protect the public from the harmful effects of air pollution, achieve and maintain air quality standards, foster community involvement and develop and implement cost-effective programs that meet state and federal mandates while considering environmental and economic impacts.

Specifically, the SDAPCD is responsible for monitoring air quality and planning, implementing, and enforcing programs designed to attain and maintain state and federal ambient air quality standards in the district. Programs developed include air quality rules and regulations that regulate stationary source emissions, including area sources, point sources, and certain mobile source emissions. The SDAPCD is also responsible for establishing permitting requirements for stationary sources and ensuring that new, modified or relocated stationary sources do not create net emissions increases; and thus, are consistent with the region's air quality goals. The SDAPCD provides significance thresholds in Regulation II, Rule 20.2, Table 20-2-1. “AQIA Trigger Levels.” These trigger levels were established for stationary sources of air pollution and are commonly used for environmental evaluations. The SDAPCD enforces air quality rules and regulations through a variety of means, including inspections, educational or training programs, or fines, when necessary. The project site is within the SDAB; and thus, is subject to SDAPCD rules and regulations.

State Implementation Plan/Air Quality Management Plan/Regional Air Quality Strategy The federal Clean Air Act Amendments (CAAA) mandate that states submit and implement a State Implementation Plan (SIP) for areas not meeting air quality standards. SIPs are comprehensive plans that describe how an area will attain national and state ambient air quality standards. SIPs are a compilation of new and previously submitted plans, programs (i.e., monitoring, modeling and permitting programs), district rules, state regulations and federal controls and include pollution control measures that demonstrate how the standards will be met through those measures.

State law makes CARB the lead agency for all purposes related to the SIP. Local air districts and other agencies prepare SIP elements and submit them to CARB for review and approval. CARB forwards SIP revisions to the USEPA for approval and publication in the Federal Register.

Thus, the Regional Air Quality Strategy (RAQS) and Air Quality Management Plan (AQMP) prepared by SDAPCD and referenced herein become part of the SIP as the material relates to efforts ongoing in San Diego County to achieve the national and state ambient air quality standards. The most recent SIP element for San Diego County was submitted in December 2016. The document identifies control measures and associated emission reductions necessary to demonstrate attainment of the 2008 Federal 8-hour ozone standard by July 20, 2018.

The San Diego RAQS was developed pursuant to California Clean Air Act (CCAA) requirements. The RAQS was initially adopted in 1991 and was updated in 1995, 1998, 2001, 2004, 2009 and 2016. The 2022 RAQS update is under development. Until it is adopted, the 2016 is applicable and can be found at the following:
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
9 https://www.sdapcd.org/content/dam/sdapcd/documents/grants/planning/2016%20RAQS%20(1 ).pdf
The RAQS identifies feasible emission control measures to provide progress in San Diego County toward attaining the State ozone standard. The pollutants addressed in the RAQS are volatile organic compounds (VOC) (also referred to as Reactive Organic Gases (ROG)) and oxides of nitrogen (NOx), precursors to the photochemical formation of ozone (the primary component of smog). The RAQS was initially adopted by the SDAPCD on June 30, 1992, and amended on March 2, 1993, in response to ARB comments. At present, no attainment plan for particulate matter less than 10 microns in diameter (PM10) or particulate matter less than 2.5 microns in diameter (PM2.5) is required by the state regulations; however, SDAPCD has adopted measures to reduce particulate matter in the SDAB. These measures range from regulation against open burning to incentive programs that introduce cleaner technology. These measures can be found in a report titled “Measures to Reduce Particulate Matter in San Diego County” December 2005:
https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/JVR/AdminRecord/IncorporatedB yReference/Appendices/Appendix-C---Air-Quality-Report/SDAPCD%202005.pdf The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in the County, to estimate future emissions and then determine strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population and vehicle trends as well as land use plans developed by the cities and the County as part of the development of the individual General Plans. As such, projects that propose development consistent with the growth anticipated by the general plans would be consistent with the RAQS. In the event that a project would propose development which is less dense than anticipated within the General Plan, the project would likewise be consistent with the RAQS. If a project proposes development that is greater than that anticipated in the General Plan and SANDAG’s growth projections, the project might conflict with the RAQS and SIP; and thus, have a potentially significant impact on air quality.

Under state law, the SDAPCD is required to prepare an AQMP for pollutants for which the SDAB is designated non-attainment. Each iteration of the SDAPCD’s AQMP is an update of the previous plan and has a 20-year horizon. Currently the SDAPCD has implemented the 2020 Plan for Attaining the National Ambient Air Quality Standard for Ozone in San Diego County (October 2020) and a 2004 Carbon Monoxide Plan. The 2020 ozone plan was submitted to CARB on October 20, 2020. It was adopted and submitted to the USEPA for review on December 28, 2020. Comments from the USEPA are pending. This plan is available for download on the ARB website located at the following URL:
https://www.sdapcd.org/content/dam/sdapcd/documents/grants/planning/Att%20A%20(Attain ment%20Plan)_ws.pdf
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
10 SDAPCD Rules and Regulations
As stated above, SDAPCD is responsible for planning, implementing, and enforcing federal and state ambient standards in the SDAB. The following rules and regulations apply to all sources in the jurisdiction of SDAPCD and would apply to the project.

SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than 3 minutes in any period of 60 consecutive minutes that is darker in shade than that designated as Number 1 on the Ringelmann Chart, as published by the United States Bureau of Mines, or of such opacity as to obscure an observer’s view to a degree greater than does smoke of a shade designated as Number 1 on the Ringelmann Chart (SDAPCD 1997).

SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property (SDAPCD 1976).

SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust emissions from any commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, as well as track-out and carry-out onto paved roads beyond a project site (SDAPCD 2009b).

SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015).

SDAPCD Regulation XII: Toxic Air Contaminates; Rule 1200: Toxic Air Contaminants – New Source Review. Requires new or modified stationary source units with the potential to emit TACs above rule threshold levels to either demonstrate that they will not increase the maximum incremental cancer risk above 1 in 1 million at every receptor location, or demonstrate that toxics best available control technology (T-BACT) will be employed if maximum incremental cancer risk is equal to or less than 10 in 1 million, or demonstrate compliance with SDAPCD’s protocol for those sources with an increase in maximum incremental cancer risk at any receptor location of greater than 10 in 1 million but less than 100 in 1 million (SDAPCD 2017b).

SDAPCD Regulation XII: Toxic Air Contaminates; Rule 1210: Toxic Air Contaminant Public Health Risks – Public Notification and Risk Reduction. Requires each stationary source that is required to prepare a public risk assessment to provide written public notice of risks at or above the following levels: maximum incremental cancer risks equal to or greater than 10 in 1 million, 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
11 or cancer burden equal to or greater than 1.0, or total acute noncancer health hazard index equal to or greater than 1.0, or total chronic non-cancer health hazard index equal to or greater than

1.0. Regional Climate and Local Air Quality
The weather of San Diego County is profoundly influenced by the Pacific Ocean and its semipermanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average minimum temperature for January ranges from the mid-40s to the high50s degrees Fahrenheit (4 to 15 degrees Celsius) across the county. July maximum temperatures average in the mid-80s to the high-90s degrees Fahrenheit (high-20s to the high-30s degrees Celsius). Most of the county’s precipitation falls from November to April, with infrequent (approximately 10 percent) precipitation during the summer. The average seasonal precipitation along the coast is approximately 10 inches (254 millimeters); the amount increases with elevations as moist air is lifted over the mountains.

The interaction of ocean, land, and the Pacific High-Pressure Zone maintains clear skies for much of the year and drives the prevailing winds. Local terrain is often the dominant factor inland and winds in inland mountainous areas tend to blow upwards in the valleys during the day and down the hills and valleys at night.

In conjunction with the onshore/offshore wind patterns, there are two types of temperature inversions (reversals of the normal decrease of temperature with height), which occur within the region that affect atmospheric dispersive capability and that act to degrade local air quality.

In the summer, an inversion at about 1,100 to 2,500 feet (335 to 765 meters) is formed over the entire coastal plain when the warm air mass over land is undercut by a shallow layer of cool marine air flowing onshore. The prevailing sunny days in this region further exacerbate the smog problem by inducing additional adverse photochemical reactions. During the winter, a nightly shallow inversion layer (usually at about 800 feet or 243 meters) forms between the cooled air at the ground and the warmer air above, which can trap vehicular pollutants. The days of highest Carbon Monoxide (CO) concentrations occur during the winter months.

The predominant onshore/offshore wind pattern is sometimes interrupted by so-called Santa Ana conditions, when high pressure over the Nevada-Utah region overcomes the prevailing westerly wind direction. This draws strong, steady, hot, and dry winds from the east over the mountains and out to sea. Strong Santa Ana winds tend to blow pollutants out over the ocean, producing clear days. However, at the onset or breakdown of these conditions or if the Santa Ana is weak, prevailing northwesterly winds are reestablished which send polluted air from the Los Angeles basin ashore in the SDAB. “Smog transport from the South Coast Air Basin (the metropolitan areas of Los Angeles, Orange, San Bernardino, and Riverside counties) is a key factor on more than half the days San Diego exceeds clean air standards” (San Diego Air Pollution Control District, 2010).
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
12 Pollutants
The SDAPCD is required to monitor air pollutant levels to ensure that air quality standards are met and, if they are not met, to develop strategies to meet the standards. Depending on whether the standards are met or exceeded, the local air basin is classified as being in “attainment” or “non-attainment.” San Diego County is listed as a federal non-attainment area for ozone (eight hour) and a state non-attainment area for ozone (one hour and eight-hour standards), PM10 and PM2.5. As shown in Table 2, the SDAB is in attainment for the state and federal standards for nitrogen dioxide, carbon monoxide, sulfur dioxide and lead. Characteristics of ozone, carbon monoxide, nitrogen dioxide, and suspended particulates are described below.

Table 2
San Diego County Attainment Status
Criteria Pollutant Federal Designation State Designation Ozone (one hour) Attainment* Non-Attainment
Ozone (eight hour) Moderate Non-Attainment Non-Attainment Carbon Monoxide Attainment Attainment
PM10 Unclassifiable** Non-Attainment
PM2.5 Attainment Non-Attainment
Nitrogen Dioxide Attainment Attainment
Sulfur Dioxide Attainment Attainment
Lead Attainment Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Visibility No Federal Standard Unclassified
* The federal 1-hour standard of 12 ppm was in effect from 1979 through June 1, 2005. The revoked standard is referenced here because it was used for such a long period and because this benchmark is addressed in State Implementation Plans (SIPs).
** At the time of designation, if the available data does not support a designation of attainment or non-attainment, the area is designated as unclassifiable.

Source: San Diego Air Pollution Control District. June 2016. http://www.sandiegocounty.gov/content/sdc/apcd/en/air-qualityplanning/attainment-status.html Ozone. Ozone is produced by a photochemical reaction (triggered by sunlight) between nitrogen oxides (NOX) and reactive organic gases (ROG)1. Nitrogen oxides are formed during the combustion of fuels, while reactive organic compounds are formed during combustion and evaporation of organic solvents. Because ozone requires sunlight to form, it mostly occurs in concentrations considered serious between the months of April and October. Ozone is a pungent, colorless, toxic gas with direct health effects on humans including respiratory and eye irritation and possible changes in lung functions. Groups most sensitive to ozone include 1 Organic compound precursors of ozone are routinely described by a number of variations of three terms: hydrocarbons (HC), organic gases (OG), and organic compounds (OC). These terms are often modified by adjectives such as total, reactive, or volatile, and result in a rather confusing array of acronyms: HC, THC (total hydrocarbons), RHC (reactive hydrocarbons), TOG (total organic gases), ROG (reactive organic gases), TOC (total organic compounds), ROC (reactive organic compounds), and VOC (volatile organic compounds). While most of these differ in some significant way from a chemical perspective, from an air quality perspective two groups are important: non-photochemically reactive in the lower atmosphere, or photochemically reactive in the lower atmosphere (HC, RHC, ROG, ROC, and VOC).
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
13 children, the elderly, people with respiratory disorders, and people who exercise strenuously outdoors.

Carbon Monoxide. Carbon monoxide (CO) is a local pollutant that is found in high concentrations only near the source. The major source of carbon monoxide, a colorless, odorless, poisonous gas, is automobile exhaust. Elevated CO concentrations; therefore, are usually only found near areas of high traffic volumes operating in congested conditions. Carbon monoxide health effects are related to blood hemoglobin. At high concentrations, carbon monoxide reduces the amount of oxygen in the blood, causing heart difficulties in people with chronic diseases, reduced lung capacity and impaired mental abilities.

Nitrogen Dioxide. Nitrogen dioxide (NO2) is a by-product of fuel combustion, with the primary source being motor vehicles and industrial boilers and furnaces. The principal form of nitrogen oxide produced by combustion is nitric oxide (NO), but NO reacts rapidly to form NO2, creating the mixture of NO and NO2 commonly called NOX. Nitrogen dioxide is an acute irritant. A relationship between NO2 and chronic pulmonary fibrosis may exist and an increase in bronchitis in young children at concentrations below 0.3 parts per million (ppm) may occur.

Nitrogen dioxide absorbs blue light and causes a reddish-brown cast to the atmosphere and reduced visibility. It can also contribute to the formation of PM10 and acid rain.

Suspended Particulates. PM10 is particulate matter measuring no more than 10 microns in diameter, while PM2.5 is fine particulate matter measuring no more than 2.5 microns in diameter. Suspended particulates are mostly dust particles, nitrates and sulfates. Both PM10 and PM2.5 are by-products of fuel combustion and wind erosion of soil and unpaved roads and are directly emitted into the atmosphere through these processes. Suspended particulates are also created in the atmosphere through chemical reactions. The characteristics, sources, and potential health effects associated with the small particulates (those between 2.5 and 10 microns in diameter) and fine particulates (PM2.5) can be very different. The small particulates generally come from windblown dust and dust kicked up from mobile sources. The fine particulates are generally associated with combustion processes as well as being formed in the atmosphere as a secondary pollutant through chemical reactions. Fine particulate matter is more likely to penetrate deeply into the lungs and poses a health threat to all groups, but particularly to the elderly, children, and those with respiratory problems. More than half of the small and fine particulate matter that is inhaled into the lungs remains there. These materials can damage health by interfering with the body’s mechanisms for clearing the respiratory tract or by acting as carriers of an absorbed toxic substance.

Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead.

Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of airborne lead by nearly 95%. With the phaseout of leaded gasoline, secondary lead smelters, battery recycling, and manufacturing facilities are becoming lead-emissions sources of 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
14 greater concern. Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and, in severe cases, neuromuscular and neurological dysfunction. Of particular concern are low-level lead exposures during infancy and childhood. Such exposures are associated with decrements in neurobehavioral performance, including intelligence quotient performance, psychomotor performance, reaction time, and growth. Children are highly susceptible to the effects of lead.

Sulfates. Sulfates are the fully oxidized form of sulfur, which typically occur in combination with metals or hydrogen ions. Sulfates are produced from reactions of SO2 in the atmosphere.

Sulfates can result in respiratory impairment, as well as reduced visibility.

Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor, which has been detected near landfills, sewage plants, and hazardous waste sites, due to the microbial breakdown of chlorinated solvents. Short-term exposure to high levels of vinyl chloride in air can cause nervous system effects, such as dizziness, drowsiness, and headaches. Long-term exposure through inhalation can cause liver damage, including liver cancer.

Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs. Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage treatment plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing difficulties at higher concentrations.

Visibility-Reducing Particles. Visibility-reducing particles are any particles in the air that obstruct the range of visibility. Effects of reduced visibility can include obscuring the viewshed of natural scenery, reducing airport safety, and discouraging tourism. Sources of visibilityreducing particles are the same as for PM2.5 described above.

Toxic Air Contaminants/Diesel Particulate Matter. Hazardous air pollutants, also known as toxic air pollutants (TACs) or air toxics, are those pollutants that are known or suspected to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental effects. Examples of toxic air pollutants include:

1. benzene, which is found in gasoline;

2. perchloroethylene, which is emitted from some dry-cleaning facilities; and

3. methylene chloride, which is used as a solvent.

Transportation related emissions are focused on particulate matter constituents within diesel exhaust and TAC constituents that comprise a portion of total organic gas (TOG) emissions from both diesel and gasoline fueled vehicles. Diesel engine emissions are comprised of exhaust particulate matter and TOGs which are collectively defined as Diesel Particulate Matter (DPM).

DPM and TOG emissions from both diesel and gasoline fueled vehicles is typically composed of carbon particles and carcinogenic substances including polycyclic aromatic (i.e., odorous) hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene. Diesel 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
15 exhaust also contains gaseous pollutants, including volatile organic compounds and oxides of nitrogen (NOx).

Sensitive Receptors
Land uses considered to be sensitive receptors include residential, school, childcare centers, acute care hospitals, and long-term health care facilities. Sensitive receptors are determined based upon special factors which may include the age of the users or occupants, the frequency and duration of the use or occupancy, continued exposure to hazardous substances as defined by federal and state regulations, and the user’s ability to evacuate a specific site in the event of a hazardous incident. Ambient air quality standards have been established to represent the levels of air quality considered sufficient, with an adequate margin of safety, to protect public health and welfare. They are designed to protect that segment of the public most susceptible to respiratory distress, such as children; the elderly; persons engaged in strenuous work or exercise and people with cardiovascular and chronic respiratory diseases. Recreational uses can be considered moderately sensitive to air pollution. Exercise can place a high demand on respiratory functions, which can be impaired by air pollution even though exposure periods during exercise are generally short. In addition, noticeable air pollution can detract from the enjoyment of recreation. Industrial and commercial areas are considered the least sensitive to air pollution. Exposure periods are relatively short and intermittent as the majority of the workers tend to stay indoors most of the time.

Nearby sensitive receptors are single-family residences located adjacent to and south of the site along the north side of Noble Drive and the single-family residence located at 11009 Summit Avenue north of the site Other single residences are located east, southeast and south of the site on the south side of Noble Avenue. The Calvary Chapel of Santee Church is located west of the site at 10920 Summit Avenue.

Monitored Air Quality
The SDAPCD and CARB monitors air quality conditions at locations throughout the SDAB. For this analysis, data from the El Cajon Lexington Elementary School (533 First Street) monitoring station were used to characterize existing pollutant conditions in the vicinity of the project site.

Table 3
Measured Air Quality Data
Averaging Time Unit
Agency/
Method
Ambient
Air
Quality
Standard
Measured Concentration by
Year
Exceedances by Year
2020 2021 2023 2020 2021 2022
Ozone (O3) – El Cajon – Lexington Elementary School, 533 First Street Maximum 1-hour
concentration
ppm State 0.09 0.094 0.088 0.100 0 0 1
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
16 Maximum 8-hour
concentration
ppm State 0.070 0.083 0.076 0.088 14 3 2
Federal 0.070 0.083 0.076 0.088 14 3 2
Nitrogen Dioxide (NO2) – El Cajon – Lexington Elementary School, 533 First Street Maximum 1-hour
concentration
ppm State 0.18 0.044 0.038 0.036 0 0 0
Federal 0.100 0.044 0.038 0.036 0 0 0
Coarse Particulate Matter (PM10) – El Cajon – Lexington Elementary School, 533 First Street2 Maximum 24-hour
concentration
µg/m3 State 50 — — — — — —
Federal 150 — — — — — —
Annual concentration µg/m3 State 20 — — — — — —
Fine Particulate Matter (PM2.5) – El Cajon – Lexington Elementary School, 533 First Street Maximum 24-hour
concentration
µg/m3 Federal 35 38.2 30.2 26.4 2 0 0
Annual concentration µg/m3 State 12 11.6 10.4 * 0 0 0
Federal 12 10.7 9.3 9.4 0 0 0
1 – Federal O3 standard reduced from 75 ppm to 70 ppm in October 2015 2 – No PM10 data collected by CARB in the San Diego Air Basin *Insufficient data to determine number of exceedances
Source: California Air Resources Board, 2020, 2021, 2022 Air Quality Data Summaries available at:
http://www.arb.ca.gov/adam/topfour/topfourdisplay.php Accessed October 24, 2023.

AIR QUALITY IMPACT ANALYSIS
Methodology and Significance Thresholds
Air quality modeling was performed in general accordance with the methodologies outlined in the SDAPCD 2016 RAQS to identify both construction and operational emissions associated with each phase and the cumulative total of all project phases at build out. All emissions were calculated using the California Emissions Estimator Model (CalEEMod) software version 2022.1 which incorporates current air emission data, planning methods and protocol approved by CARB.

Construction activities would include site preparation, grading, construction of the buildings/utilities and related improvements and painting the interior and exterior building surfaces and paving streets and parking areas. Construction activities would require the use of equipment that would generate criteria air pollutant emissions. For modeling purposes, it was assumed that all construction equipment used would be diesel-powered. Construction emissions associated with development of the proposed project were quantified by estimating the types of equipment, including the number of individual pieces of equipment, that would be used on-site during each of the construction phases as well as off-site haul trips to remove 17,500 cubic yards of excavation spoils. Construction emissions are analyzed using the regional 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
17 thresholds established by the SDAPCD and published under Rule 20-2. No fill import would be required.

Operational emissions include mobile source emissions, energy emissions, and area source emissions. Mobile source emissions are generated by motor vehicle trips associated with operation of the project. Emissions attributed to energy use include electricity and natural gas consumption for space and water heating. Area source emissions are generated by landscape maintenance equipment, refrigeration, consumer products and architectural coatings (i.e., paints). To determine whether a regional air quality impact would occur, the increase in emissions are compared with the SDAPCD recommended regional thresholds for operational emissions.

Regional Thresholds. Based on Appendix G of the CEQA Guidelines (2021), a project would have a significant air quality impact if it would:
a. Conflict with or obstruct implementation of the applicable air quality plan; b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard;
c. Expose sensitive receptors to substantial pollutant concentrations; d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) indicates that, where available, the significance criteria established by the applicable air quality management district or pollution control district may be relied upon to determine whether the project would have a significant impact on air quality. As part of its air quality permitting process, SDAPCD has established thresholds in Rule 20.2 requiring the preparation of Air Quality Impact Assessments for permitted stationary sources. SDAPCD sets forth quantitative emission thresholds for stationary sources. Although these trigger levels do not generally apply to mobile sources or general land development projects, for comparative purposes these levels may be used to evaluate the increased emissions that would be emitted into the SDAB from proposed land development projects. Project-related air quality impacts estimated in this environmental analysis would be considered significant if any of the applicable significance thresholds presented below in Table 4 are exceeded.

The thresholds listed in Table 4 are screening-level thresholds used to evaluate whether proposed-project-related emissions could cause a significant impact on air quality. Emissions below the screening-level thresholds would not cause a significant impact. The emissions-based thresholds for ozone precursors (ROG and NOx) are intended to serve as the threshold for ozone. This approach is used because ozone is not emitted directly; thus, ozone concentrations associated with individual projects precursors (VOC and NOx) emissions cannot be determined through air quality models or other quantitative methods. For nonattainment pollutants, if emissions exceed the thresholds shown in Table 4, the project has the potential to result in a 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
18 cumulatively considerable net increase in these pollutants; and thus, could have a significant impact on the ambient air quality.

Table 4
SDAPCD Air Emission Significance Thresholds
Daily Construction and Operational Emissions
Pollutant Total Emissions (pounds per day)
Reactive Organic Gas (ROG) 75
Nitrogen Oxides (NOx) 250
Carbon Monoxide (CO) 550
Sulfur Oxides (SOx) 250
Respirable Particulate Matter (PM10) 100
Fine Particulate Matter (PM2.5) 55
With respect to odors, SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material that causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person. A project that involves a use that would produce objectionable odors would be deemed to have a significant odor impact if it would affect a considerable number of off-site receptors.
a. Conflict with or obstruct implementation of the applicable air quality plan As stated, under state law, the SDAPCD is required to prepare an AQMP for pollutants for which the SDAB is designated non-attainment. Each iteration of the SDAPCD’s AQMP is an update of the previous plan and has a 20-year horizon. A project may be deemed inconsistent with the AQMP if it would generate population, housing, or employment growth exceeding forecasts used in the development of the AQMP. Currently the SDAPCD has implemented the 2020 Plan for Attaining the National Ambient Air Quality Standard for Ozone in San Diego County (October 2020) and a 2004 Carbon Monoxide Plan. The AQMP incorporates local city General Plans and the San Diego Association of Governments socioeconomic forecast projections of regional population, housing and employment growth.

The proposed project involves the construction of 50 multi-family residences and 13 open parking spaces. The project site is zoned Residential 7 (R-7). The project would be allowed by right on the project site per Chapter 13.10 of the Santee Municipal Code.

The San Diego APCD and San Diego Association of Governments are responsible for developing and implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the basin—specifically, the SIP and RAQS. The federal O3 maintenance plan, which is part of the SIP, was adopted in 2012. The most recent O3 attainment plan was adopted in 2016. The SIP includes a demonstration that current strategies and tactics will maintain acceptable air quality in the basin based on the NAAQS. The RAQS was initially adopted in 1991 and is updated on a triennial basis (most recently in 2016). The RAQS outlines SDAPCD’s plans and control measures designed to attain the state air quality standards for O3.

The SIP and RAQS rely on information from CARB and SANDAG, including mobile and area source emissions as well as information regarding projected growth in the County and the cities 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
19 in the County, to project future emissions and determine the strategies necessary for the reduction of emissions through regulatory controls.

CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends and land use plans developed by the County and the cities in the County as part of the General Plan development process. If a project proposes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might be in conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality.

As stated, the site is zoned R-7. The zoning designation is intended to support multifamily residential development consistent with what is proposed. The project is consistent with the zoning designation; and thus, was anticipated in the local plan and SANDAG’s growth projections. Further, the project will replace an existing single-family residence and outbuildings located on the site. The project would not cause or contribute to population or employment growth beyond what has been considered in SANDAG’s Regional Plan population and employee population estimates for the years 2020 and 2035.

The San Diego Association of Governments forecast population and employment through the year 2050 as part of the 2050 Regional Transportation Plan, Regional Growth Forecast.

The population of Santee was projected to be 57,501 in 2025 and 57,773 in 2035, or an increase of 272 residents over the period (SANDAG 2021). The project is anticipated to house 139 residents (CalEEMod 2022.1); therefore, the project would be within SANDAG’s population growth forecast, and would not conflict with the SIP and RAQS. The project would be consistent with the AQMP and not cause an adverse impact under threshold (a). b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard
Construction Emissions
Project construction would generate temporary air pollutant emissions. These impacts are associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles, work crew vehicle trips in addition to ROG that would be released during the drying phase upon application of paint and other architectural coatings. Construction would generally consist of demolition (debris removal), site preparation (clearing/grubbing), excavation/grading, construction of the proposed buildings, architectural coating (i.e., paint) application and paving.

Emissions from the construction phase of the project were estimated using CalEEMod 2022.1.

Construction scenario assumptions, including phasing, equipment mix, and vehicle trips, were based on information provided by the project applicant and CalEEMod default values when project specifics were not known. For purposes of estimating project emissions, and based on 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
20 information provided by the project applicant, it is assumed that construction of the project would occur five days per week and commence in October 2024 and would be completed January 2026. The schedule is an estimate calculated by CalEEMod 2022.1. The duration of phases are approximated:
• Demolition: 4 weeks
• Site Preparation: 1 week
• Grading: 22 weeks
• Building Construction: 46 weeks
• Paving: 2 weeks
• Architectural Coating: 8 weeks
Construction-worker and vendor trips estimates by construction phase were based on CalEEMod default data. Mass grading would include the entire project site. Approximately 17,500 cubic yards of debris would be removed during site preparation and grading. Based on a haul truck capacity of 16 cubic yards per truck, demolition and earth-moving activities would result in approximately 1,093 one-way trips (547 round trips) during the site preparation and grading phase. No fill import is anticipated during building construction. CalEEMod default trip length values were used for the distances for all construction-related trips. Defaults for the construction equipment mix and vehicle trips used for estimating the project-generated construction emissions were used and are provided in Appendix A.

As discussed, the project would implement dust control strategies as a project design feature.

To reflect implementation of proposed dust control strategies, the following was used in CalEEMod:
• Water exposed area two times per day (55% reduction in PM10 and PM2.5); and Table 5 summarizes the estimated maximum daily emissions of pollutants occurring during construction. As shown in Table 5, construction of the proposed project would not exceed the SDAPCD daily thresholds. This assumes the architectural coating phase would overlap with the building construction phase by approximately 42 workdays as a design feature to reflect actual construction phasing and reduce daily ROG (VOC) emissions. With SDAPCD Rule 55 compliance, no mitigation measures would be required to meet construction emission thresholds. Construction emissions would be less than significant per thresholds (b) and (c) referenced above.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
21 Table 5
Estimated Maximum Daily Construction Emissions with Dust Control Measures Construction
Phase
Maximum Emissions (lbs/day)
ROG NOx CO SOx PM10 PM2.5
2024 Maximum
lbs/day 4.0 58.3 41.4 0.15 13.7 6.8
2025 Maximum
lbs/day 1.8 17.2 18.9 0.03 3.8 2.1
2026 Maximum
lbs/day 0.7 6.2 9.6 0.01 0.4 0.3
SDAPCD Regional
Thresholds 75 100 550 150 150 55
Threshold
Exceeded 2022 No No No No No No
Construction‐Related Toxic Air Contaminant Impacts
Potential for toxic air contaminant emissions related to diesel particulate emissions associated with heavy equipment operations during construction. According to South Coast Air Quality Management District (SCAQMD) methodology, health effects from carcinogenic air toxics are usually described in terms of “individual cancer risk”. A cancer risk greater than 10 cases per 1,000,000 people exposed would be considered a significant impact. The California Office of Environmental Health Hazard Assessment (OEHHA) health risk guidance states that a residential receptor should be evaluated based on a 30-year exposure period. “Individual Cancer Risk” is the likelihood that a person exposed to concentrations of toxic air contaminants over a 70-year lifetime will contract cancer, based on the use of standard risk‐assessment methodology. The construction schedule duration would be approximately 17 months; however, only a portion of the overall construction work would require the use of dieselpowered equipment. The proposed project would not result in a long-term (i.e., 30 or 70 year) exposure to a substantial source of toxic air contaminant emissions; and thus, would not be exposed to the related individual cancer risk. Therefore, no significant toxic air contaminant impacts would occur during construction of the proposed project.

Operational Impacts
Regional Pollutant Emissions
Emissions from the operational phase of the project were estimated using CalEEMod version 2022.1. Operational year 2026 was assumed consistent with completion of project construction.

Area Sources. CalEEMod was used to estimate operational emissions from area sources, including emissions from consumer product use, architectural coatings, and landscape 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
22 maintenance equipment. Emissions associated with space heating and water heating are calculated in the building energy use module of CalEEMod.

Consumer products are chemically formulated products used by household and institutional consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. Other paint products, furniture coatings, or architectural coatings are not considered consumer products. Consumer product VOC emissions are estimated in CalEEMod based on the floor area of buildings and on the default factor of pounds of VOC per building square foot per day. The CalEEMod default values for consumer products were assumed.

VOC off-gassing emissions result from evaporation of solvents contained in surface coatings such as in paints and primers used during building maintenance. CalEEMod calculates the VOC evaporative emissions from application of surface coatings based on the VOC emission factor, the building square footage, the assumed fraction of surface area, and the reapplication rate.

VOC emissions were estimated based on compliance with SDAPCD Rule 67.0.1, which provides VOC content limits for various coatings. The three general coatings categories are 50 grams per liter (g/L) VOC for flat coatings, 100 g/L VOC for non-flat coatings, and 150 g/L VOC for non-flat high gloss coatings. Consistent with typical construction practices, it is anticipated that interior and exterior paint would not exceed non-flat coating limits, exterior paint would not exceed non-flat coating limits, and a small portion of exterior paint and finishes (trim and other minor finishes) would not exceed non-flat high-gloss coatings limits. It was conservatively assumed that all non-residential (interior and exterior) architectural coating would be 50 g/L VOC and parking lot coating would be 100 g/L.

Energy Sources. Energy sources include emissions associated with building electricity and natural gas use. Electricity use would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use are only quantified for GHGs in CalEEMod, since criteria pollutant emissions occur at the site of the power plant, which is typically off site.

Mobile Sources. To quantify emissions associated with project operational mobile sources, CalEEMod default data, including trip characteristics, trip lengths, variable start information and emissions factors were used for the model inputs. Project-related traffic includes the mixture of vehicles consistent with CalEEMod default vehicle fleet assumptions. Emission factors for 2026 (the first full year of project operation) were used to estimate emissions associated with full buildout of the project.

Table 6 summarizes area, energy and mobile source emissions associated with operation of the proposed project. As shown in Table 6, daily emissions would not exceed the SDAPCD thresholds for ROG, NOX, CO, SOX, PM10 or PM2.5. Therefore, the project’s air quality impacts (including impacts related to criteria pollutants, sensitive receptors and violations of air quality standards) would be less than significant per threshold b. Further, the project would not contribute to a cumulatively considerable impact. Impacts relative to threshold b and c would be less than significant.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
23 Table 6
Estimated Operational Emissions
Estimated Emissions (lbs/day)
ROG NOX CO SOX PM10 PM2.5
Proposed Project
Area 1.4 0.02 2.8 0.0001 0.0010 0.0010
Energy 0.01 0.17 0.07 0.001 0.0138 0.0138
Mobile 1.6 1.2 12.5 0.03 2.6 0.6
Maximum lbs/day 3.1 1.4 15.5 0.03 2.7 0.7
SDAPCD Thresholds 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
See Appendix for CalEEMod version. 2022.1 computer model output - summer emissions shown c. Expose sensitive receptors to substantial pollutant concentrations; Carbon Monoxide Hotspots. As discussed, carbon monoxide is a colorless, odorless, poisonous gas that may be found in high concentrations near areas of high traffic volumes. CO emissions are a function of vehicle idling time, meteorological conditions, and traffic flow. The SDAB is in attainment of state and federal CO standards; thus, CO data is no longer collected and not all monitoring stations have CO data available. The 1110 Beardsley Street monitoring station in the Barrio Logan community is the closest monitoring station to the site that provides CO data. The maximum 8-hour average CO level recorded in 2012 (the last year data were recorded) was 1.81 parts per million (ppm). Concentrations are below the 9-ppm state and federal 8-hour standard.

Numerous factors are related to the formation of CO hotspots. The potential for CO hotspots in the SDAB is steadily decreasing because of the continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion and the already very low ambient CO concentrations. Furthermore, CO transport is extremely limited and disperses rapidly with distance from the source. Under certain extreme meteorological conditions, however, CO concentrations near a congested roadway or intersection may reach unhealthy levels.

Typically, high CO concentrations are associated with roadways or intersections operating under congested conditions. Projects contributing to adverse traffic conditions may contribute to the formation of CO hotspots. Because the City of Santee does not have CO hotspot guidance, the guidance recommended by the County of San Diego was applied to evaluate the potential for CO hotspots to occur as a result of the project. As indicated in the County of San Diego Guidelines for Determining Significance and Report Format and Content Requirements Air Quality (County of San Diego 2007), a site-specific CO hotspot analysis should be performed if a proposed development would cause road intersections to operate at or below a LOS E with intersection peak-hour trips exceeding 3,000.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
24 The proposed project was evaluated for CO hotspots under 2026 build out conditions. Trip Generation and Vehicle Miles Traveled Memorandum was prepared for the proposed project (TJW Engineering, Inc. October 2023). The memorandum was prepared consistent with Guidelines for Transportation Impact Studies in the San Diego Region (May 2019). The guidelines state that projects will not require a transportation impact study if they generate less than 1,000 trips and less than 110 peak-hour trips. Further, the County guidelines state that projects consistent with the General Plan and that generate less than 1,000 daily trips are not required to complete a VMT assessment. The proposed project will generate 300 daily trips and 27 peak hour trips. Thus, based on the Guidelines for Transportation Impact Studies in the San Diego Region, the proposed project would not generate enough traffic to require further traffic or VMT analysis.

Because no project specific traffic analysis is required, the project’s contribution to baseline traffic conditions would be less than significant and would not contribute to a traffic conditional that could create a CO hotspot. Impacts would be less than significant (threshold c). No further evaluation with respect to CO hotspots is required.
d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

The State of California Health and Safety Code, Division 26, Part 4, Chapter 3, Section 41700, SDAPCD Rule 51 prohibits emissions from any source whatsoever in such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to the public health or damage to property. Projects required to obtain permits from SDAPCD are evaluated by SDAPCD staff for potential odor nuisance, and conditions may be applied (or control equipment required) where necessary to prevent occurrence of public nuisance.

SDAPCD Rule 51 (Public Nuisance) also prohibits emission of any material that causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person.

A project that involves a use that would produce objectionable odors would be deemed to have a significant odor impact if it would affect a considerable number of off-site receptors. Odor issues are very subjective by the nature of odors themselves and due to the fact that their measurements are difficult to quantify. As a result, this guideline is qualitative and will focus on the existing and potential surrounding uses and location of sensitive receptors.

The occurrence and severity of potential odor impacts depends on numerous factors. The nature, frequency, and intensity of the source; the wind speeds and direction; and the sensitivity of receiving location each contribute to the intensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying and cause distress among the public and generate citizen complaints. Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the project. Potential odors produced during construction would be attributable to exhaust emissions, architectural coatings, and asphalt pavement application. Such odors would disperse rapidly from the project site and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
25 impacts associated with other emissions (such as those leading to odors) during construction would be less than significant.

Land uses and industrial operations that are associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding facilities. The project would construct 50 new multifamily residences with associated parking and infrastructure improvements. These uses are not associated with odors that could rise to the level of significance. Therefore, impacts would be less than significant per threshold (d).

GREENHOUSE GAS EMISSION DISCUSSION
Gases that absorb and re-emit infrared radiation in the atmosphere are called greenhouse gases (GHGs). GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O), fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation.

GHGs are emitted by both natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are largely by-products of fossil fuel combustion, whereas CH4 results from off-gassing associated with agricultural practices and landfills. Man-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and sulfur hexafluoride (SF6) (California Environmental Protection Agency [CalEPA], 2006). Different types of GHGs have varying global warming potentials (GWPs). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emissions, referred to as “carbon dioxide equivalent” (CO2E), and is the amount of a GHG emitted multiplied by its GWP. Carbon dioxide has a GWP of one. By contrast, methane (CH4) has a GWP of 28, meaning its global warming effect is 28 times greater than carbon dioxide on a molecule per molecule basis (IPCC, 2014).

The largest source of GHG in California is transportation, contributing 39.9 percent of the state’s total GHG emissions. The industrial sector is the second largest source, contributing 21 percent of the state’s GHG emissions. California emissions result in part to its geographic size and large population compared to other states. However, a factor that reduces California’s per capita fuel use and GHG emissions, as compared to other states, is its relatively mild climate. In July 2017, California’s state legislature passed Assembly Bill (AB) 398 to reauthorize and extend until 2030 the state’s economy-wide greenhouse gas (GHG) reduction program. The bill sets a new GHG target of at least 40% below the 1990 level of emissions by 2030. 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
26 California Regulations
In 2005, former Governor Schwarzenegger issued Executive Order (EO) S-3-05, establishing statewide GHG emissions reduction targets. EO S-3-05 states that by 2020, emissions shall be reduced to 1990 levels; and by 2050, emissions shall be reduced to 80 percent of 1990 levels (CalEPA, 2006). In response to EO S-3-05, CalEPA created the Climate Action Team (CAT), which in March 2006 published the Climate Action Team Report (the “2006 CAT Report”) (CalEPA, 2006). The 2006 CAT Report recommended various strategies that the state could pursue to reduce GHG emissions. These strategies could be implemented by various state agencies to ensure that the emission reduction targets in EO S-3-05 are met and can be met with existing authority of the state agencies. The strategies include the reduction of passenger and light duty truck emissions, the reduction of idling times for diesel trucks, an overhaul of shipping technology/infrastructure, increased use of alternative fuels, increased recycling, and landfill methane capture.

Assembly Bill 32 and CARB’s Scoping Plan
To further the goals established in EO S-3-05, the Legislature passed Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. Under AB 32, CARB is responsible for and is recognized as having the expertise to carry out and develop the programs and requirements necessary to achieve the GHG emissions reduction mandate of AB 32. Under AB 32, CARB must adopt regulations requiring the reporting and verification of statewide GHG emissions from specified sources. This program is used to monitor and enforce compliance with established standards.

CARB also is required to adopt rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. AB 32 authorized CARB to adopt marketbased compliance mechanisms to meet the specified requirements. Finally, CARB is ultimately responsible for monitoring compliance and enforcing any rule, regulation, order, emission limitation, emission reduction measure, or market-based compliance mechanism adopted.

In 2007, CARB approved a limit on the statewide GHG emissions level for year 2020 consistent with the determined 1990 baseline (427 MMT CO2E). CARB’s adoption of this limit is in accordance with Health and Safety Code, Section 38550.

Further, in 2008, CARB adopted the Scoping Plan in accordance with Health and Safety Code, Section 38561. The Scoping Plan establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions for various emission sources/sectors to 1990 levels by 2020. The Scoping Plan evaluates opportunities for sector-specific reductions, integrates all CARB and Climate Action Team early actions and additional GHG reduction features by both entities, identifies additional measures to be pursued as regulations, and outlines the role of a cap-and-trade program. The key elements of the Scoping Plan include the following (CARB 2008):

1. Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards;
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
27 2. Achieving a statewide renewable energy mix of 33%;

3. Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85% of California’s GHG emissions;

4. Establishing targets for transportation-related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets;

5. Adopting and implementing measures pursuant to existing state laws and policies, including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard; and

6. Creating targeted fees, including a public goods charge on water use, fees on high GWP gases, and a fee to fund the administrative costs of the State of California’s long-term commitment to AB 32 implementation.

In the Scoping Plan (CARB 2008), CARB determined that achieving the 1990 emissions level in 2020 would require a reduction in GHG emissions of approximately 28.5% from the otherwise projected 2020 emissions level (i.e., those emissions that would occur in 2020) absent GHG reducing laws and regulations (referred to as Business-As-Usual (BAU)). To calculate this percentage reduction, CARB assumed that all new electricity generation would be supplied by natural gas plants, no further regulatory action would impact vehicle fuel efficiency, and building energy efficiency codes would be held at 2005 standards.

In the 2011 Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document (CARB 2011a), CARB revised its estimates of the projected 2020 emissions level in light of the economic recession and the availability of updated information about GHG reduction regulations. Based on the new economic data, CARB determined that achieving the 1990 emissions level by 2020 would require a reduction in GHG emissions of 21.7% (down from

28.5%) from the BAU conditions. When the 2020 emissions level projection was updated to account for newly implemented regulatory measures, including Pavley I (model years 2009– 2016) and the Renewables Portfolio Standard (RPS) (12% to 20%), CARB determined that achieving the 1990 emissions level in 2020 would require a reduction in GHG emissions of 16% (down from 28.5%) from the BAU conditions.

In 2014, CARB adopted the First Update to the Climate Change Scoping Plan: Building on the Framework (First Update; CARB 2014). The stated purpose of the First Update is to “highlight California’s success to date in reducing its GHG emissions and lay the foundation for establishing a broad framework for continued emission reductions beyond 2020, on the path to 80% below 1990 levels by 2050” (CARB 2014). The First Update found that California is on track to meet the 2020 emissions reduction mandate established by AB 32 and noted that California could reduce emissions further by 2030 to levels needed to stay on track to reduce emissions to 80% below 1990 levels by 2050 if the state realizes the expected benefits of existing policy goals.

In conjunction with the First Update, CARB identified “six key focus areas comprising major components of the state’s economy to evaluate and describe the larger transformative actions that will be needed to meet the state’s more expansive emission reduction needs by 2050” 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
28 (CARB 2014). Those six areas are (1) energy, (2) transportation (vehicles/equipment, sustainable communities, housing, fuels, and infrastructure), (3) agriculture, (4) water, (5) waste management, and (6) natural and working lands. The First Update identifies key recommended actions for each sector that will facilitate achievement of EO S-3-05’s 2050 reduction goal (CARB 2014).

Based on CARB’s research efforts presented in the First Update, it has a “strong sense of the mix of technologies needed to reduce emissions through 2050” (CARB 2014). Those technologies include energy demand reduction through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies.

As part of the First Update, CARB recalculated the state’s 1990 emissions level using more recent GWPs identified by the IPCC. Using the recalculated 1990 emissions level (431 MMT CO2E) and the revised 2020-emissions-level projection identified in the 2011 Final Supplement, CARB determined that achieving the 1990 emissions level by 2020 would require a reduction in GHG emissions of approximately 15% (instead of 28.5% or 16%) from the BAU conditions (CARB 2014).

In January 2017, CARB released, The 2017 Climate Change Scoping Plan Update (Second Update), for public review and comment. This update proposes CARB’s strategy for achieving the state’s 2030 GHG target as established in Senate Bill (SB) 32 (discussed below), including continuing the Cap-and-Trade Program through 2030, and includes a new approach to reduce GHGs from refineries by 20%. The Second Update incorporates approaches to cutting shortlived climate pollutants (SLCPs) under the Short-Lived Climate Pollutant Reduction Strategy (a planning document that was adopted by CARB in March 2017), acknowledges the need for reducing emissions in agriculture, and highlights the work underway to ensure that California’s natural and working lands increasingly sequester carbon. During development of the Second Update, CARB held a number of public workshops in the Natural and Working Lands, Agriculture, Energy, and Transportation sectors to inform development of the 2030 Scoping Plan Update (CARB 2016). The Second Update has not been considered by CARB’s Governing Board at the time this analysis was prepared.

Executive Order S-01-07 was enacted on January 18, 2007. The order mandates that a Low Carbon Fuel Standard (“LCFS”) for transportation fuels be established for California to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020.

Other regulations affecting state and local GHG planning and policy development are summarized as follows:

Assembly Bill 939 and Senate Bill 1374
Assembly Bill 939 (AB 939) requires that each jurisdiction in California to divert at least 50 percent of its waste away from landfills, whether through waste reduction, recycling or other means. Senate Bill 1374 (SB 1374) requires the California Integrated Waste Management Board 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
29 to adopt a model ordinance by March 1, 2004 suitable for adoption by any local agency to require 50 to 75 percent diversion of construction and demolition of waste materials from landfills.

Senate Bill 1368
Senate Bill 1368 (SB 1368) is the companion Bill of AB 32 and was adopted September, 2006. SB 1368 required the California Public Utilities Commission (CPUC) to establish a performance standard for baseload generation of GHG emissions by investor‐owned utilities by February 1, 2007 and for local publicly owned utilities by June 30, 2007. These standards could not exceed the GHG emissions rate from a baseload combined‐cycle, natural gas‐fired plant. Furthermore, the legislation states that all electricity provided to the State, including imported electricity, must be generated by plants that meet the standards set by California Public Utilities Commission (CPUC) and California Energy Commission (CEC).

Senate Bill 97
Senate Bill 97 (SB 97) was adopted August 2007 and acknowledges that climate change is an environmental issue that requires analysis under CEQA. SB 97 directed the Governor’s Office of Planning and Research (OPR), which is part of the State Natural Resources Agency, to prepare, develop, and transmit to CARB guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, by July 1, 2009. The Natural Resources Agency was required to certify and adopt those guidelines by January 1, 2010. Pursuant to the requirements of SB 97 as stated above, on December 30, 2009 the Natural Resources Agency adopted amendments to the state CEQA guidelines that address GHG emissions. The CEQA Guidelines Amendments changed sections of the CEQA Guidelines and incorporated GHG language throughout the Guidelines. However, no GHG emissions thresholds of significance were provided and no specific mitigation measures were identified. The GHG emission reduction amendments went into effect on March 18, 2010 and are summarized below:

1. Climate action plans and other greenhouse gas reduction plans can be used to determine whether a project has significant impacts, based upon its compliance with the plan.

2. Local governments are encouraged to quantify the greenhouse gas emissions of proposed projects, noting that they have the freedom to select the models and methodologies that best meet their needs and circumstances. The section also recommends consideration of several qualitative factors that may be used in the determination of significance, such as the extent to which the given project complies with state, regional, or local GHG reduction plans and policies. OPR does not set or dictate specific thresholds of significance. Consistent with existing CEQA Guidelines, OPR encourages local governments to develop and publish their own thresholds of significance for GHG impacts assessment.

3. When creating their own thresholds of significance, local governments may consider the thresholds of significance adopted or recommended by other public agencies, or recommended by experts.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
30 4. New amendments include guidelines for determining methods to mitigate the effects of greenhouse gas emissions in Appendix F of the CEQA Guidelines.

5. OPR is clear to state that “to qualify as mitigation, specific measures from an existing plan must be identified and incorporated into the project; general compliance with a plan, by itself, is not mitigation.”

6. OPR’s emphasizes the advantages of analyzing GHG impacts on an institutional, programmatic level. OPR therefore approves tiering of environmental analyses and highlights some benefits of such an approach.

7. Environmental impact reports (EIRs) must specifically consider a project's energy use and energy efficiency potential.

Senate Bills 1078, 107, and X1‐2 and Executive Orders S‐14‐08 and S‐21‐09 Senate Bill 1078 (SB 1078) requires retail sellers of electricity, including investor-owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. Senate Bill 107 (SB 107) changed the target date to 2010. Executive Order S‐14‐08 was signed on November 2008 and expands the State’s Renewable Energy Standard to 33 percent renewable energy by 2020. Executive Order S‐21‐09 directed CARB to adopt regulations by July 31, 2010 to enforce S‐14‐08. Senate Bill X1‐2 codifies the 33 percent renewable energy requirement by 2020.

California Code of Regulations (CCR) Title 24, Part 6
CCR Title 24, Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24) were first established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. Although it was not originally intended to reduce GHG emissions, electricity production by fossil fuels results in GHG emissions and energy efficient buildings require less electricity. Therefore, increased energy efficiency results in decreased GHG emissions.

The Energy Commission adopted 2008 Standards on April 23, 2008 and Building Standards Commission approved them for publication on September 11, 2008. These updates became effective on August 1, 2009. All buildings for which an application for a building permit is submitted on or after July 1, 2014 must follow the 2013 standards. The 2013 commercial standards are estimated to be 30 percent more efficient than the 2008 standards; 2013 residential standards are at least 25 percent more efficient. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases greenhouse gas emissions.

Senate Bill 375
Senate Bill 375 (SB 375) was adopted in September 2008 and aligns regional transportation planning efforts, regional GHG emission reduction targets, and land use and housing allocation.

SB 375 requires Metropolitan Planning Organizations (MPO) to adopt a sustainable 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
31 communities strategy (SCS) or alternate planning strategy (APS) that will prescribe land use allocation in that MPOs Regional Transportation Plan (RTP). CARB, in consultation with each MPO, will provide each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. These reduction targets will be updated every eight years but can be updated every four years if advancements in emissions technologies affect the reduction strategies to achieve the targets. CARB is also charged with reviewing each MPO’s sustainable community’s strategy or alternate planning strategy for consistency with its assigned targets.

The proposed project is located within the Southern California Association of Governments (SCAG) jurisdiction, which has authority to develop the SCS or APS. For the SCAG region, beginning October 2018, the targets set by CARB are at eight percent below 2005 per capita GHG emissions levels by 2020 and 19 percent below 2005 per capita GHG emissions levels by 2035. On September 3, 2020, SCAG adopted the 2020-2045 Regional Transportation Plan / Sustainable Communities Strategy (RTP/SCS), Connect SoCal. which meets the CARB emission reduction requirements. The Housing Element Update is required by the State to be completed within 18 months after RTP/SCS adoption. The Santee Housing Element 2021-2029 (6th Cycle) was adopted July 24, 2021 and includes housing-related goals, policies, and programs to address the existing and projected future housing needs of the City.

City and County land use policies, including General Plans, are not required to be consistent with the RTP and associated SCS or APS. However, CEQA incentivizes, through streamlining and other provisions, qualified projects that are consistent with an approved SCS or APS and categorized as “transit priority projects.”
Senate Bill X7‐7
Senate Bill X7‐7 (SB X7‐7), enacted on November 9, 2009, mandates water conservation targets and efficiency improvements for urban and agricultural water suppliers. SB X7‐7 requires the Department of Water Resources (DWR) to develop a task force and technical panel to develop alternative best management practices for the water sector. Additionally, SB X7‐7 required the DWR to develop criteria for baseline uses for residential, commercial, and industrial uses for both indoor and landscaped area uses. The DWR was also required to develop targets and regulations that achieve a statewide 20 percent reduction in water usage.

Title 24 Building Energy Efficiency Standards
California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (CCR Title 24, Part 6) was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficient technologies and methods.

Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions. On August 11, 2021, the CEC adopted the 2022 Energy Code. In December 2021, it was approved by the California Building Standards Commission for inclusion into the California Building Standards Code. Among other updates like strengthened ventilation standards for gas cooking appliances, the 2022 Energy Code 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
32 includes updated standards such as new electric heat pump requirements for residential uses, schools, offices, banks, libraries, retail, and grocery stores; the promotion of electric-ready requirements for new homes including the addition of circuitry for electric appliances, battery storage panels and dedicated infrastructure to allow for the conversion from natural gas to electricity; and the expansion of solar photovoltaic and battery storage standards to additional land uses including high-rise multi-family residences, hotels and motels, tenant spaces, offices (including medical offices and clinics), retail and grocery stores, restaurants, schools, and civic uses (including theaters auditoriums, and convention centers). Newly constructed commercial buildings would also be required to have a solar photovoltaic (PV) array and an energy storage system (ESS) installed. Projects whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 Energy Code.

Title 24 California Green Building Standards Code
The California Green Building Standards Code (CCR Title 24, Part 11 code) commonly referred to as the CALGreen Code, is a statewide mandatory construction code developed and adopted by the California Building Standards Commission and the Department of Housing and Community Development. The CALGreen standards require new residential and commercial buildings to comply with mandatory measures under the topics of planning and design, energy efficiency, water efficiency/conservation, material conservation and resource efficiency, and environmental quality. CALGreen also provides voluntary tiers and measures that local governments may adopt that encourage or require additional measures in the five green building topics: planning and design; energy efficiency; water efficiency and conservation; material conservation and resource efficiency; and environmental quality. The CALGreen Code also provides voluntary measures (CALGreen Tier 1 and Tier 2) that local governments may adopt which encourage or require additional measures in the five green building topics.

CALGreen’s Tier 1 standards call for a 15% improvement in energy requirements, stricter water conservation, 65% diversion of construction and demolition waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar-reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30% improvement in energy requirements, stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs.

The CEC adopted the 2022 CALGreen Code in December 2021, went into effect on January 1, 2023. The 2022 CALGreen code focuses on battery storage system controls, demand management, heat pump space and water heating, and building electrification.

Title 20
Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to demonstrate compliance with standards. New appliances regulated under Title 20 include refrigerators, refrigerator-freezers, and freezers; room air conditioners and room air-conditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
33 fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low voltage dry-type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing for each type of appliance covered under the regulations and appliances must meet the standards for energy performance, energy design, water performance, and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regulated appliances, state standards for federally regulated appliances, and state standards for non-federally regulated appliances.

Executive Order B-30-15
EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing statewide GHG emissions to 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long-term goal of reducing statewide GHG emissions to 80% below 1990 levels by 2050 as set forth in EO S-3-05. To facilitate achievement of this goal, EO B30-15 calls for an update to CARB’s Scoping Plan to express the 2030 target in terms of MMT CO2E. EO B-30-15 also calls for state agencies to continue to develop and implement GHG emission reduction programs in support of the reduction targets. EO B-30-15 does not require local agencies to take any action to meet the new interim GHG reduction target.

Senate Bill 32 and Assembly Bill 197
SB 32 and AB 197 (enacted in 2016) are companion bills that set new statewide GHG reduction targets, make changes to CARB’s membership, increase legislative oversight of CARB’s climate change–based activities, and expand dissemination of GHG and other air quality–related emissions data to enhance transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly, in order to provide ongoing oversight over implementation of the state’s climate policies. AB 197 added two members of the Legislature to CARB as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.

SB 350— Clean Energy and Pollution Reduction Act of 2015 In October 2015, the legislature approved and the Governor signed SB 350, which reaffirms California’s commitment to reducing its GHG emissions and addressing climate change. Key provisions include an increase in the renewables portfolio standard (RPS), higher energy efficiency requirements for buildings, initial strategies towards a regional electricity grid, and improved infrastructure for electric vehicle charging stations. Provisions for a 50 percent reduction in the use of petroleum statewide were removed from the Bill because of opposition and concern that it would prevent the Bill’s passage. Specifically, SB 350 requires the following to reduce statewide GHG emissions:
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
34 1. Increase the amount of electricity procured from renewable energy sources from 33 percent to 50 percent by 2030, with interim targets of 40 percent by 2024, and 25 percent by 2027.

2. Double the energy efficiency in existing buildings by 2030. This target will be achieved through the California Public Utility Commission (CPUC), the California Energy Commission (CEC), and local publicly-owned utilities.

3. Reorganize the Independent System Operator (ISO) to develop more regional electrify transmission markets and to improve accessibility in these markets, which will facilitate the growth of renewable energy markets in the western United States (California Leginfo 2015).

SB 100
On September 10, 2018, Governor Brown signed SB 100, which raises California’s RPS requirements to 60 percent by 2030, with interim targets, and 100 percent by 2045. The bill also establishes a state policy that eligible renewable energy resources and zero-carbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all state agencies by December 31, 2045. Under the bill, the state cannot increase carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target.

Executive Order B-55-18
On September 10, 2018, Governor Brown signed Executive Order B-55-2018 which established a new statewide goal to achieve carbon neutrality as soon as possible and no later than 2045. The executive order also states that California will achieve and maintain net negative emissions thereafter.

AB 2127
AB 2127 promotes better planning for EV infrastructure build-out across all vehicle classes. AB 2127 would help the state meet the goal of 5 million zero-emission vehicles (ZEV) on the road by 2030.

Local Regulations and CEQA Requirements
As referenced, pursuant to the requirements of SB 97, the Resources Agency has adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted CEQA Guidelines provide general regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents, but contain no suggested thresholds of significance for GHG emissions. Instead, lead agencies are given the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs and climate change impacts. The general approach to developing a Threshold of Significance for GHG emissions is to identify the emissions level for which a project would not be expected to substantially conflict with existing California legislation adopted to reduce statewide GHG emissions needed to move the state towards climate stabilization. If a project would generate GHG 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
35 emissions above the threshold level, its contribution to cumulative impacts would be considered significant.

The California Supreme Court addressed the issue of GHG emissions and the evaluation of potential impacts in CEQA documents, in the Center for Biological Diversity v. California Department of Fish and Wildlife and Newhall Land and Farming case, 2015) 224 Cal.App.4th 1105 (CBD vs. CDFW), also known as the “Newhall Ranch” case. The justices examined one of the most common approaches to GHG analyses for development projects which was evaluating the efficiency of a project’s emissions reduction in the context of the AB 32’s 2020 reduction goal, as presented in the statewide CARB Scoping Plan, using a comparison to an unregulated, “business as usual (BAU)” emissions scenario. As discussed in the Newhall Ranch decision, determining consistency with local GHG reduction plans or Climate Action Plans that qualify under Section 15183.5 of the CEQA Guidelines may be the most effective strategy for local governments to assess the significance of GHG emissions from proposed land use developments. Qualified CAPs also provide a workable option for addressing post-2020 GHG emissions and resolving issues that arise out of project-level GHG analyses raised in the Court’s decision."
Sustainable Santee Plan
The City of Santee approved a qualified GHG reduction plan under CEQA called the Sustainable Santee Plan: The City’s Roadmap to Greenhouse Gas Reductions, in December 2019. The Sustainable Santee Plan (Plan) is a long-range plan to reduce GHG emissions from community activities and municipal operations within the City of Santee to support the State’s efforts under Executive Order S3-05, SB 32, and AB 32 and to mitigate climate-related impacts. The Sustainable Santee Plan describes the GHG emissions baseline and forecasted emissions for 2020, 2030 and 2035, and identifies the achievable, measurable strategies and actions that the City of Santee will implement to reduce emissions. The City developed an interim goal for 2030 which is to reduce emissions to 40 percent below 2005 levels and a longer-term goal for 2035 which is to reduce emissions to 49 percent below 2005 levels. The interim and longer-term goals would put the City on a path consistent with the State’s long-term goal to achieve Statewide carbon neutrality (zero net emissions) by 2045.

The Plan contains implementation strategies that are consistent with the City’s goals, values, and priorities and that also support the State’s broad climate protection efforts. The Plan also contains local initiatives intended to improve community health and safety, reduce transportation and utility related emissions, facilitate locally beneficial development projects and enhance collaboration on regional planning strategies.

With respect to evaluating project consistency with the Plan, projects that are consistent with the General Plan growth projections and land uses upon which the GHG modeling performed for the Plan was based, and that incorporate applicable GHG reduction measures, can be found consistent with the Plan and related statewide programs to reduce GHG emissions. 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
36 CLIMATE CHANGE IMPACT ANALYSIS
Thresholds of Significance
Pursuant to the requirements of SB 97, the Resources Agency adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions in March 2010. These guidelines are used in evaluating the cumulative significance of GHG emissions from the proposed project. According to the adopted CEQA Guidelines, impacts related to GHG emissions from the proposed project would be significant if the project would:
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and/or
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The vast majority of individual projects do not generate sufficient GHG emissions to create a project-specific impact through a direct influence to climate change; therefore, the issue of climate change typically involves an analysis of whether a project’s contribution towards an impact is cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines, Section 15355).

The significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds, or consistency with a regional GHG reduction plan (such as a Climate Action Plan or Sustainable Community Plan).

Neither the City nor the County of San Diego have established a CEQA threshold of significance for GHG emissions. The State CEQA Guidelines Section 15064.4 does not establish a threshold of significance but states that Lead Agencies may appropriately look to thresholds developed by other public agencies or suggested by other experts, as long as any threshold chosen is supported by substantial evidence (State CEQA Guidelines Section 16064.7(c)).

Various threshold approaches have been recommended, drafted, or adopted by other public agencies. The County of San Diego uses a screening threshold of 900 metric tons of carbon dioxide (MT CO2e) annually. For the purpose of this evaluation, if the CO2e emissions generated by the proposed project are less than 900 MT CO2e annually, the project would have a less than significant GHG impact.

Methodology
GHG emissions associated with construction and operation of the proposed project and existing development have been estimated using California Emissions Estimator Model (CalEEMod) version 2022.1.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
37 Construction Emissions
Construction of the proposed project would generate temporary GHG emissions primarily associated with the operation of construction equipment, worker trips and truck trips required for hauling excavation spoils, materials and equipment. Site preparation and grading typically generate the greatest emission quantities because the use of heavy equipment is greatest during this phase of construction. Emissions associated with the construction period were estimated based on the projected maximum amount of equipment that would be used on-site at one time.

Air districts such as the SDAPCD have recommended amortizing construction-related emissions over a 30-year period to calculate annual emissions. Complete CalEEMod results and assumptions can be viewed in the Appendix.

Operational Emissions
Default values used in CalEEMod version 2022.1 are based on the California Energy Commission (CEC) sponsored California Commercial End Use Survey (CEUS) and Residential Appliance Saturation Survey (RASS) studies. CalEEMod provides operational emissions of CO2, N2O and CH4. This methodology has been subjected to peer review by numerous public and private stakeholders, and in particular by the CEC; and therefore, is considered reasonable and reliable for use in GHG impact analysis pursuant to CEQA. It is also recommended by CAPCOA (January 2008).

Emissions associated with area sources (i.e., consumer products, landscape maintenance, and architectural coating) were calculated in CalEEMod based on standard emission rates from CARB, USEPA, and district supplied emission factor values (CalEEMod User Guide, May 2021).

Emissions from waste generation were also calculated in CalEEMod and are based on the IPCC’s methods for quantifying GHG emissions from solid waste using the degradable organic content of waste (CalEEMod User Guide, May 2021). Waste disposal rates by land use and overall composition of municipal solid waste in California was primarily based on data provided by the California Department of Resources Recycling and Recovery (CalRecycle).

Emissions from water and wastewater usage calculated in CalEEMod were based on the default electricity intensity from the CEC’s 2006 Refining Estimates of Water-Related Energy Use in California using the average values for Northern and Southern California. Emissions from mobile sources were quantified based on trip generation estimates provided by the applicant. 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
38 a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment
Estimate of Emissions
Construction Emissions
Construction activity is assumed to occur over a period of approximately 17 months beginning in October 2024 and concluding in March 2026. Based on CalEEMod results, construction activity for the project would generate an estimated 451 metric tons of carbon dioxide equivalent (CO2E), as shown in Table 7. Amortized over a 30-year period (the assumed life of the project), construction of the proposed project would generate 20 metric tons of CO2E per year.

Table 7
Estimated Construction Related Greenhouse Gas
Emissions
Year Annual Emissions
(metric tons CO2E)
2024 118
2025 380
2026 87
Total 585
Amortized over 30 years 20
See Appendix for CalEEMod software program output
Operational Indirect and Stationary Direct Emissions
Long-term emissions relate to energy use, solid waste, water use, and transportation. Each source is discussed below and includes the emissions associated with existing development and the anticipated emissions that would result from the proposed project.

Energy Use. Operation of onsite development would consume both electricity and natural gas (see Appendix for CalEEMod results). The generation of electricity through combustion of fossil fuels typically yields CO2, and to a smaller extent, N2O and CH4. Natural gas emissions can be calculated using default values from the CEC sponsored CEUS and RASS studies which are built into CalEEMod. As shown in Table 8, the overall net increase in energy use at the project site would result in approximately 84 metric tons of CO2E per year.

Water Use Emissions. The CalEEMod results indicate that the project would use approximately 1,800,000 gallons of water per year. Based on the amount of electricity generated to supply and convey this amount of water, as shown in Table 9, the project would generate approximately 5 metric tons of CO2E per year. Emissions related to water consumption would be reduced by 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
39 20% per Senate Bill X7-7, by implementing measures that include the installation of low flow plumbing fixtures (i.e., faucets, toilets, show heads) and water efficient irrigation systems.

Solid Waste Emissions. Implementation of a municipal recycling program that would achieve a 75% diversion rate statewide is required for residential uses per the California Integrated Waste Management Act of 1989 (AB 939). The CalEEMod results indicate that the project would result in approximately 3 metric tons of CO2E per year associated with solid waste disposed within landfills provided 75% of solid waste is recycled (Table 9).

Table 8
Estimated Annual Energy-Related Greenhouse Gas Emissions Emission Source Annual Emissions
(CO2E)
Proposed Project
Electricity 48 metric tons
Natural Gas 36 metric tons
Total 84 metric tons
See Appendix for CalEEMod software program output.

Table 9
Estimated Annual
Solid Waste and Water Use Greenhouse Gas Emissions
Emission Source Annual Emissions
(CO2E)
Water 5 metric tons
Solid Waste 3 metric tons
Total Water and Solid Waste 8 metric tons
See Appendix for CalEEMod software program output.
.

Transportation Emissions. Mobile source GHG emissions were estimated using the trip generation rates provided in CalEEMod which utilizes the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition. Table 10 shows the estimated mobile emissions of GHGs for the project based on the estimated annual VMT of 1,233.854. As shown in Table 10, the project would generate approximately 451 metric tons of CO2E associated with new vehicle trips.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
40 Table 10
Estimated Annual Mobile Emissions of Greenhouse Gases
Emission Source Annual Emissions
(CO2E)
Proposed Project
Mobile Emissions (CO2 & CH4) 451 metric tons
Total 451 metric tons
See Appendix for CalEEMod software program output.

Combined Construction, Stationary and Mobile Source Emissions Table 11 combines the net new construction, operational, and mobile GHG emissions associated with the proposed project. As discussed above, temporary emissions associated with construction activity (approximately 585 metric tons CO2E) are amortized over 30 years (the anticipated life of the project).

For the proposed project, the combined annual emissions would total approximately 563 metric tons per year in CO2E. The proposed project is evaluated based on the threshold of 900 MT CO2E annually. Project-related annual GHG emissions would not exceed the 900 metric ton screening threshold; thus, annual emissions would be less than significant per threshold a.

Table 11
Combined Annual Greenhouse Gas Emissions
Emission Source Annual Emissions
(CO2E)
Construction 20 metric tons
Operational
Energy
Solid Waste
Water
84 metric tons
5 metric tons
3 metric tons
Mobile 451 metric tons
Total 563 metric tons
See Appendix for CalEEMod software program output.
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

As discussed above, operation of the proposed project would result in an estimated total of 563 CO2e (MT/year). The GHG emissions from the proposed project would not exceed the County f San Diego screening criteria. Further, the project would be consistent with the following goals of the draft Sustainable Santee Plan approved in December 2019:
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
41 • Goal 2: Increase energy efficiency in new residential units; and • Goal 9: Decrease GHG emissions through reducing solid waste generation.

The project would comply with current Energy Code (California Code of Regulations, Title 24, Part 6) and the 2019 CALGreen standards, which require energy-efficient measures including increased lighting efficiency and the installation of Energy Star® appliances. As required by the 2020 CALGreen standards, the project would reduce indoor water consumption by 20 percent and would implement outdoor water use reduction measures outlined in the Model Water Efficient Landscape Ordinance. The project would also comply with the Santee Water Efficient Landscape Ordinance which promotes water conservation and efficiency by imposing various requirements related to evapotranspiration rates, irrigation efficiency and plant factors. The project would comply with the City’s construction and demolition recycling ordinance (Santee Municipal Code Section 13.38.060) and Solid Waste Ordinance, which follow state regulations for solid waste and recycling intended to result in a 75% reduction in the volumes of waste disposed of in landfills.

Therefore, the project would not conflict with the goals and objectives of the Sustainable Santee Plan. Likewise, the proposed project would not conflict with the provisions of AB 32, or any other State or regional plan, policy, or regulation of an agency adopted for the purpose of reducing greenhouse gas emissions. Impacts would be less than significant.

Consistency with EO S-3-05 and SB 32
EO S-3-05. This EO establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80% below 1990 levels by 2050.

SB 32. This bill establishes a statewide GHG emissions reduction target whereby CARB, in adopting rules and regulations to achieve the maximum technologically feasible and costeffective GHG emissions reductions, shall ensure that statewide GHG emissions are reduced to at least 40% below 1990 levels by December 31, 2030.

As stated, the Sustainable Santee Plan describes the GHG emissions baseline and forecasted emissions for 2020, 2030 and 2035, and identifies the achievable, measurable strategies and actions that the City of Santee will implement to reduce emissions. The City developed an interim goal for 2030, which was to reduce emissions to 40 percent below 2005 levels and a longer-term goal for 2035, which is to reduce emissions to 49 percent below 2005 levels. The interim and longer-term goals would put the City on a path consistent with SB 32 and the State’s long-term goal to achieve Statewide carbon neutrality (zero net emissions) by 2045.

Statewide, CARB has indicated that California is on track to achieve both the 2030 and 2050 goals. This is confirmed in the 2017 Scoping Plan, which states that the Scoping Plan builds upon the successful framework established by the Initial Scoping Plan and First Update, while identifying new, technologically feasible and cost-effective strategies to ensure that California meets its GHG reduction targets. Table 12 summarizes the Project's consistency with applicable action elements of the 2017 Scoping Plan.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
42 Table 12
2017 Scoping Plan Consistency Summary

ACTION RESPONSIBLE PARTIES CONSISTENCY
Implement SB 350 by 2030
Increase the Renewables Portfolio
Standard to 50% of retail sales by
2030 and ensure grid reliability.

California Public Utility
Commission (CPUC),
California Energy
Commission (CEC) and
California Air Resources
Board (CARB)
No Conflict. The Project would use
energy from San Diego Gas and
Electric (SDG&E). SDG&E has
committed to diversify their
portfolio of energy sources by
increasing energy from wind and
solar sources. The Project would
not interfere with or obstruct
SDG&E’s energy source
diversification efforts.

Establish annual targets for
statewide energy efficiency
savings and demand reduction
that will achieve a cumulative
doubling of statewide energy
efficiency savings in electricity and
natural gas end uses by 2030.

No Conflict. The Project would be
constructed in compliance with
current CBC requirements
including the 2022 Building and
Energy Efficiency Standards and
the 2021 California Green Building
Standard requirements.

Reduce GHG emissions in the
electricity sector through the
implementation of the above
measures and other actions as
modeled in Integrated Resource
Planning (IRP) to meet GHG
emissions reductions planning
targets in the IRP process. Loadserving entities and publiclyowned utilities meet GHG emissions reductions planning
targets through a combination of
measures as described in IRPs.

Implement Mobile Source Strategy (Cleaner Technology and Fuels) At least 1.5 million zero emission
and plugin hybrid light-duty EVs by
2025.

CARB, California State
Transportation Agency
(CalSTA), Strategic Growth
Council (SGC), California
Department of
Transportation (Caltrans),
CEC, Office of Planning and
Research (OPR), Local
Agencies
No Conflict. This is a CARB Mobile
Source Strategy. The Project
would not obstruct or interfere with
CARB zero emission and plug-in
hybrid light-duty EV 2025 targets.

As this is a CARB enforced
standard, vehicles that access the
Project must comply with the
standards as applicable; and thus,
would comply with the strategy.

At least 4.2 million zero emission
and plugin hybrid light-duty EVs by
2030.

No Conflict. This is a CARB Mobile
Source Strategy. The Project
would not obstruct or interfere with
CARB zero emission and plug-in
hybrid light-duty EV 2030 targets.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
43 ACTION RESPONSIBLE PARTIES CONSISTENCY
Further increase GHG stringency
on all light-duty vehicles beyond
existing Advanced Clean cars
regulations.

CARB, California State
Transportation Agency
(CalSTA), Strategic Growth
Council (SGC), California
Department of
Transportation (Caltrans),
CEC, Office of Planning and
Research (OPR), Local
Agencies
No Conflict. This is a CARB Mobile
Source Strategy. The Project
would not obstruct or interfere with
CARB efforts to further increase
GHG stringency on all light-duty
vehicles beyond existing
Advanced Clean cars regulations.

Medium- and Heavy-Duty GHG
Phase 2.

No Conflict. This is a CARB Mobile
Source Strategy. The Project
would not obstruct or interfere with
CARB efforts to implement
Medium- and Heavy-Duty GHG
Phase 2.

Innovative Clean Transit:

Transition to a suite of to-bedetermined innovative clean transit options. Assumed 20% of new
urban buses purchased beginning
in 2018 will be zero emission
buses with the penetration of zeroemission technology ramped up to 100% of new sales in 2030. Also,
new natural gas buses, starting in
2018, and diesel buses, starting in
2020, meet the optional heavyduty low-NOX standard.

Not Applicable. This measure is
not related to the project scope.

Last Mile Delivery: New regulation
that would result in the use of low
NOX or cleaner engines and the
deployment of increasing numbers
of zero-emission trucks primarily
for class 3-7 last mile delivery
trucks in California. This measure
assumes ZEVs comprise 2.5% of
new Class 3–7 truck sales in local
fleets starting in 2020, increasing
to 10% in 2025 and remaining flat
through 2030.

No Conflict. This is a CARB Mobile
Source Strategy. The Project
would not obstruct or interfere with
CARB efforts to improve last mile
delivery emissions.

Further reduce VMT through
continued implementation of SB
375 and regional Sustainable
Communities Strategies; statewide
implementation of SB 743; and
potential additional VMT reduction
strategies not specified in the
Mobile Source Strategy but
included in the document
"Potential VMT Reduction
Strategies for Discussion."
No Conflict. As stated in the Traffic
Study, the Project’s VMT impact
would be considered less than
significant.

Increase stringency of SB 375
Sustainable Communities Strategy
(2035 targets).

CARB No Conflict. The project would not
exceed the City’s GHG emission
thresholds for retail sources or
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
44 ACTION RESPONSIBLE PARTIES CONSISTENCY
otherwise conflict with GHG
reduction efforts.

Harmonize project performance
with emissions reductions and
increase competitiveness of transit
and active transportation modes
(e.g., via guideline documents,
funding programs, project
selection, etc.).

CalSTA, SGC, OPR, CARB,
Governor's Office of
Business and Economic
Development (GOBiz),
California Infrastructure and
Economic Development
Bank (IBank), Department
of Finance (DOF), California
Transportation Commission
(CTC), Caltrans
No Conflict. The project would not
conflict with use of adjacent
streets by pedestrians or bicycles.

Further, transit service provided by
Metropolitan Transit System
(MTS) would not be affected by
the project.

By 2019, develop pricing policies
to support low-GHG transportation
(e.g., low emission vehicle zones
for heavy duty, road user, parking
pricing, transit discounts).

CalSTA, Caltrans, California
Transportation Commission
(CTC), OPR, SGC, CARB
Not Applicable. This measure is
not related to the project scope.

Implement California Sustainable Freight Action Plan
Improve freight system efficiency. CalSTA, CalEPA, California Natural Resource Agency
(CNRA), CARB, Caltrans,
CEC, GO-Biz
No Conflict. This measure would
apply to all trucks accessing the
project site. It is presumed that
these vehicles would primarily be
delivery vans and tanker trucks
operated as part of the statewide
goods movement sector. Access
to the Project site would be
provided from Summit Avenue.

Deploy over 100,000 freight
vehicles and equipment capable of
zero emission operation and
maximize both zero and near zero
emission freight vehicles and
equipment powered by renewable
energy by 2030.

Not applicable. This measure is
unrelated to the project scope.

Adopt a Low Carbon Fuel
Standard with a Carbon Intensity
reduction of 18%.

CARB No Conflict. When adopted, this
measure would apply to all fuel
sold on-site or purchased for use
in vehicles accessing the project
site. The Project would not
obstruct or interfere with agency
efforts to adopt a Low Carbon Fuel
Standard with a Carbon Intensity
reduction of 18%.

Implement the Short-Lived Climate Pollutant Strategy (SLPS) by 2030 40% reduction in methane and
hydrofluorocarbon emissions
below 2013 levels.

CARB, CalRecycle,
California Department of
Food and Agriculture
(CDFA), California State
Water Resource Control
No Conflict. The Project would be
required to comply with this
measure and reduce any Projectsource SLPS emissions
accordingly. The Project would not
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
45 ACTION RESPONSIBLE PARTIES CONSISTENCY
Board (SWRCB), Local Air
Districts
obstruct or interfere with agency
efforts to reduce SLPS emissions.

Implement the post-2020 Capand-Trade Program with declining annual caps.

CARB No Conflict. The Project would be
required to comply with applicable
Cap-and-Trade Program
provisions. The Project would not
obstruct or interfere with agency
efforts to implement the post-2020
Cap-and-Trade Program.

By 2018, develop Integrated Natural and Working Lands Implementation Plan to secure California's land base as a net carbon sink:

Protect land from conversion
through conservation easements
and other incentives.

CNRA, Departments
Within CDFA, CalEPA,
CARB
Not applicable. The Project site is
not an identified property that
needs to be conserved.

Increase the long-term resilience
of carbon storage in the land base
and enhance sequestration
capacity.

Not applicable. The entire site is
planned for development.

Utilize wood and agricultural
products to increase the amount of
carbon stored in the natural and
built environments.

No Conflict. To the extent
appropriate for the proposed
residences, wood products would
be used in construction, including
roof structure. Additionally, the
Project includes landscaping.

Establish scenario projections to
serve as the foundation for the
Implementation Plan.

Not applicable. This measure is
unrelated to the project scope.

Implement Forest Carbon Plan. CNRA, California
Department of Forestry and
Fire Protection (CAL FIRE),
CalEPA and Departments
Within
Not applicable. This measure is
unrelated to the project scope.

Identify and expand funding and
financing mechanisms to support
GHG reductions across all sectors.

State Agencies & Local
Agencies
Not applicable. This measure is
unrelated to the project scope.

As stated, the project would not generate enough GHG emissions to cumulatively contribute to global climate change; and thus, would not adversely impact the attainment of statewide reductions in GHG emissions referenced above. However, the measures implemented by the project to reduce overall GHG emissions would contribute to GHG reduction goals mandated by AB 32 and further address in EO S-3-05 and SB 32.
2022 Scoping Plan Consistency
CARB’s 2022 Scoping Plan sets a path to achieve targets for carbon neutrality and reduce anthropogenic GHG emissions by 85 percent below 1990 levels by 2045 in accordance with AB 1279. The 2022 Scoping Plan focuses on zero-emission transportation; phasing out use of fossil 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
46 gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines); and scaling up new options such as green hydrogen. Unlike the 2017 Scoping Plan, CARB no longer includes a numeric per capita threshold and instead advocates for compliance with a local GHG reduction strategy (i.e., Climate Action Plan) consistent with CEQA Guidelines Section 15183.5. Statewide strategies to reduce GHG emissions in the latest 2022 Scoping Plan include implementing SB 100, which would achieve 100 percent clean electricity by 2045; achieving 100 percent zero emission vehicle sales in 2035 through Advanced Clean Cars II; and implementing the Advanced Clean Fleets regulation to deploy ZEV buses and trucks. Additional transportation policies include the OffRoad Zero Emission Targeted Manufacturer rule, Clean Off-Road Fleet Recognition Program, In-use Off-Road Diesel Fueled Fleets Regulation, Clean Off-Road Fleet Recognition Program, and Amendments to the In-use Off-Road Diesel-Fueled Fleets Regulation.

The 2022 Scoping Plan would continue to implement SB 375. GHGs would be further reduced through the Cap-and-Trade Program carbon pricing and SB 905. SB 905 requires CARB to create the Carbon Capture, Removal, Utilization, and Storage Program to evaluate, demonstrate, and regulate carbon dioxide removal projects and technology. As indicated above, GHG reductions are also achieved as a result of State of California energy and water efficiency requirements for new residential development. These efficiency improvements correspond to reductions in secondary GHG emissions. For example, in California, most of the electricity that powers homes is derived from natural gas combustion. Therefore, energy saving measures, such as Title 24, reduces GHG emissions from the power generation facilities by reducing load demand. The 2022 Scoping Plan Appendix D provides local jurisdictions with tools to reduce GHGs and assist the state in meeting the ambitious targets set forth in the 2022 Scoping Plan. The 2022 Scoping Plan Appendix D focuses on Residential and Mixed-Use Projects. The 2022 Scoping Plan Appendix D lists potential actions that support the State’s climate goals. However, the 2022 Scoping Plan notes that the applicability and performance of the actions may vary across the regions. The document is organized into two categories (A) examples of plan-level GHG reduction actions that could be implemented by local governments and (B) examples of on-site project design features, mitigation measures, that could be required of individual projects under CEQA, if feasible, when the local jurisdiction is the lead agency.

The Project would include a number of the Standard Conditions for construction and operation.

For example, the 2022 Scoping Plan’s construction actions include enforcing idling time restrictions on construction vehicles and requiring construction vehicles to operate highest tier engines commercially available. The Project would include a majority of the feasible operational mitigation measures listed in the 2022 Scoping Plan Appendix D as design features. Some of the recommended operational measures would include providing bicycle parking, creating on- and off-site safety improvements for bike, pedestrian, and transit connections, requiring solar panels, drought-tolerant landscaping, and energy conserving appliances. As discussed above, the Project would be consistent with all applicable plan goals and applicable regulatory programs designed to reduce GHG emissions generated by land use projects. The Project would be subject to compliance with all building codes in effect at the time of construction, which 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
47 include energy conservation measures mandated by California Building Standards Code Title 24 – Energy Efficiency Standards. Because Title 24 standards require energy conservation features in new construction (e.g., high- efficiency lighting, high-efficiency heating, ventilating, and air-conditioning (HVAC) systems, thermal insulation, double-glazed windows, water conserving plumbing fixtures), they indirectly regulate and reduce GHG emissions.

California's Building Energy Efficiency Standards are updated on an approximately three-year cycle. As shown above, the majority of the Project’s emissions are from energy and mobile sources, which would be further reduced by the 2022 Scoping Plan actions described above. The City has no control over vehicle emissions; however, these emissions would decline in the future because of Statewide measures as well as cleaner technology and fleet turnover. Many State plans and policies would contribute to a reduction in the Project’s mobile source emissions, including the following:

CARB’s Advanced Clean Truck Regulation: Adopted in June 2020, CARB’s Advanced Clean Truck Regulation requires truck manufacturers to transition from diesel trucks and vans to electric zero-emission trucks beginning in 2024. By 2045, every new truck sold in California is required to be zero-emission. The Advanced Clean Truck Regulation accelerates the transition of zeroemission medium-and heavy-duty vehicles from Class 2b to Class 8.

Executive Order N-79-20: Executive Order N-79-20 establishes the goal for all new passenger cars and trucks, as well as all drayage/cargo trucks and off-road vehicles and equipment, sold in California, to be zero-emission by 2035 and all medium and heavy-duty vehicles to be zeroemission by 2045. It also directs CARB to develop and propose rulemaking for passenger vehicles and trucks, medium-and heavy-duty fleets where feasible, drayage trucks, and off-road vehicles and equipment “requiring increasing volumes” of new ZEVs “towards the target of 100 percent.”
CARB’s Mobile Source Strategy: CARB’s Mobile Source Strategy takes an integrated planning approach to identify the level of transition to cleaner mobile source technologies needed to achieve all of California’s targets by increasing the adoption of ZEV buses and trucks.

CARB’s Sustainable Freight Action Plan: The Sustainable Freight Action Plan which improves freight system efficiency, utilizes near-zero emissions technology, and deployment of ZEV trucks. This Plan applies to all trucks accessing the Project site and may include existing trucks or new trucks that are part of the Statewide goods movement sector.

CARB’s Emissions Reduction Plan for Ports and Goods Movement: CARB’s Emissions Reduction Plan for Ports and Goods Movement identifies measures to improve goods movement efficiencies such as advanced combustion strategies, friction reduction, waste heat recovery, and electrification of accessories. While these measures are not directly applicable to the Project, any commercial activity associated with goods movement would be required to comply with these measures as adopted.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
48 The Project would not obstruct or interfere with efforts to increase ZEVs or State efforts to improve system efficiency. Compliance with applicable State standards (e.g., continuation of the Cap-and-Trade regulation; CARB’s Mobile Source Strategy, Sustainable Freight Action Plan, and Advanced Clean Truck Regulation; Executive Order N-79-20; SB 100/renewable electricity portfolio improvements that require 60 percent renewable electricity by 2030 and 100 percent renewable by 2045, etc.) would ensure consistency with State and regional GHG reduction planning efforts, including the 2022 Scoping Plan. It is also noted that the Project would not convert any Natural and Working Lands (NWL) and/or decrease the State’s urban forest carbon stock, which are areas of emphasis in the 2022 Scoping Plan.

Regarding goals for 2050 under Executive Order S-3-05, at this time it is not possible to quantify the emissions savings from future regulatory measures, as they have not yet been developed; nevertheless, it can be anticipated that Project operations would benefit from applicable measures enacted to meet State GHG reduction goals. The Project would not impede the State’s progress towards carbon neutrality by 2045 under the 2022 Scoping Plan. The Project would be required to comply with applicable current and future regulatory requirements promulgated through the 2022 Scoping Plan. Thus, impacts related to consistency with the 2022 Scoping Plan would be less than significant. The Project would not conflict with the applicable plans and regulatory programs that are discussed above; and therefore, with respect to this particular threshold, the Project does not have a significant impact.

San Diego Association of Governments: San Diego Forward Regarding consistency with SANDAG’s Regional Plan, the project would not conflict with the recently adopted RTP Implementation Actions (December 2021) and objectives of SB 375. Table 13 illustrates the project’s consistency with applicable goals of San Diego Forward: The Regional Plan (SANDAG December 2021).

Table 13
San Diego Forward: The Regional Plan Consistency Analysis Category Policy Objective or Strategy Consistency Analysis The Regional Plan –Implementation Actions
Land Use and Habitat The 2021 Regional Plan vision for
land use focuses on development
and growth in Mobility Hub areas
to preserve the region’s habitat
and open space while supporting
transportation investments and
reducing vehicle miles traveled
(VMT).

Consistent. The project would be consistent with
planned land use for the site and would not
adversely impact habitat.

Housing The 2021 Regional Plan
addresses the housing crisis
through Mobility Hubs, bringing
locations where people live and
work closer together and
Not applicable. The proposed project would
provide housing within an R-7 zone. The site is
not within a mobility hub.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
49 providing more housing options
for more San Diegans through
increased density.

Climate Action Planning To help reach regional and state greenhouse gas (GHG) emission
reduction targets, the 2021
Regional Plan focuses heavily on
the conversion to clean
transportation and a shift from
personal vehicle dependency.

Consistent. The project would not impact
regional initiatives to reduce GHG emissions.

The project would be consistent with the City of
Sustainable Santee Plan and screening
threshold for GHG emissions.

Climate Adaptation and
Resilience
The 2021 Regional Plan aims to
better prepare San Diego
communities and habitats for
climate change impacts by
considering evacuation and rapid
mobility needs in our transit
corridors, evaluating and
considering climate vulnerabilities
to the region’s transportation
infrastructure, and using natural
lands and conservation to absorb
and protect against climate
change impacts.

Consistent. The project would not impact
regional efforts to implement actions related to
climate adaptation.

Electric Vehicles 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
Consistent. The project would provide EV
charging stations.

Parking and Curb
Management
The 2021 Regional Plan
addresses curb management by
proposing strategies to help
balance competing and changing
travel needs at the curb while
remaining flexible to resident,
employee, business, and visitor
needs.

Not Applicable. The project would provide on-site
parking; however, it would not participate in
regional parking and curb management
strategies.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
50 Transportation Demand
Management
SANDAG will continue to
administer and monitor the
iCommute program by providing
regional rideshare, employer
outreach, and bike education and
secure parking services to help
reduce commute-related traffic
congestion and vehicle miles
traveled.

Not Applicable. The project would not affect
implementation of SANDAG’s ongoing TDM
programs.

Vision Zero Vision Zero is a national campaign
to eliminate all traffic-related
deaths and serious injuries by
focusing on policies and the
redesign of streets to create a
transportation system that is safe
for everyone.

Not Applicable. The project would not affect
SANDAG’s initiative to redesign streets and
modify the transportation system.

Fix It First 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.

Not applicable. The project would not affect
SANDAG’s goal related to the fix it first program.

Transportation System
Management and
Operations
TSMO 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.

Not Applicable. The project would not affect
SANDAGs ability to create and manage a TSMO
program.

Value Pricing and User
Fees
The 2021 Regional Plan explores
a network of Managed Lanes, a
mileage-based road usage
charge, a fee on the fares charged
for rides provided by
transportation network companies,
and further subsidization of transit
fares.

Not Applicable. The project would not affect
SANDAGs ability to create and manage a value
pricing and user fee program.

Sustainable Communities Strategy (SCS) – Strategies Related to Reimagined Transportation System Complete Corridors Focuses on regional
transportation system including
managed lanes, rural corridors,
regional arterial network and other
improvements.

Not applicable. The project would have no effect
on the regional transportation system or
SANDAGs efforts to improve the system.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
51 Transit Leap Provide new and expanded
transit services including
commuter rail, light rail, high
speed rail, local buses and microtransit.

Not applicable. The project would have no effect
on the provision of regional transit services.

Mobility Hubs Invest in a transportation mobility
network that focus on micromobility, rideshare and microtransit and other features that promote the development of
mobility hubs.

Not Applicable. The project would not impair
SANDAG’s ability to invest in the development
of mobility hubs.

Next OS Next OS is the digital network that
maximizes the efficiency and
effectiveness of the other Big
Moves—Complete Corridors,
Transit Leap, Mobility Hubs, and
Flexible Fleets—to make the
entire transportation system work
at its peak potential.

Not Applicable. The project would not impair
SANDAG’s ability to develop and/or expand the
Next OS infrastructure.

Active Transportation This strategy would develop a
network to make critical
connections along Complete
Corridors and other streets,
providing people with safe and
convenient ways to connect to
and from Transit Leap services
and many other destinations
within and between Mobility
Hubs.

Not Applicable. The project would not impair the
ability of SANDAG to implement the active
transportation system.

Climate Strategies This strategy focuses on
measures to mitigate climate
change and adapt to inevitable
impacts will make our region
more resilient. Resilience is
defined as “the ability to prepare
for changing conditions and
withstand, respond to, and
recover rapidly from disruptions.

Consistent. The project would not impact
regional efforts to implement actions related to
climate adaptation.

Innovative Demand
and System
Management
Innovative demand and system
management strategies are
programs that encourage and
support a choice of alternatives to
driving alone. These alternatives
include working remotely,
carpooling, vanpooling, and
choosing transit or active
transportation.

Not Applicable. The project would not impair the
ability of SANDAG to implement an innovative
demand and system management program.

Source: SANDAG 2021.

As shown in Table 13, the project is consistent with applicable Policy Objectives and Strategies from the Regional Plan.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
52 Consistency Analysis with City of Santee General Plan The project also would be consistent with the goals set forth in the City’s General Plan Land Use Element, and Circulation Element that are designed to reduce the emissions of GHGs, reduce energy use in buildings and infrastructure, and promote the use of renewable energy sources, conservation, and other methods of efficiency. Table 14 outlines the project’s consistency with applicable General Plan goals.

As shown in Table 14, the project would be consistent with applicable and goals and policies of the City’s General Plan to the extent feasible.

Table 14
City of Santee General Plan – Project Consistency Analysis Goal Consistency Analysis
Land Use and Urban Design Element
Objective 2: Allow for the development of
a wide range of housing types in the City.

Consistent. The project would meet applicable zoning and design standards as required by the City of Santee.

Policy 2.1 The City should promote the
use of innovative site planning techniques
that contribute towards provision of a
variety of residential product styles and
designs.

Consistent. The project incorporates unique design standards and site planning to maximize density while creating a visually compatible project. The project would integrate landscaping to create a visual buffer between the site and residences located to the south.

Policy 2.3 The City should encourage
planned residential and/or planned unit
developments that provide adequate open
space, recreational facilities, off-street
parking, interior circulation patterns and
other amenities and facilities.

Consistent. The project would provide on-site open space for the community and each unit, garage parking and efficient interior circulation and frontage improvements along Summit Avenue.

Conclusion
The proposed project site is 4.65 gross/2.42 net acres in size (APN 378-190-01) and zoned Medium Density Residential (R-7). The project would construct a total of 50 multifamily units and related improvements including 100 garage parking spaces and 13 open surface spaces.

Air Quality Management Plan Consistency. The project site is zoned R-7. The project is consistent with the R-7 zoning designation and is anticipated in the local plans and SANDAG’s 10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
53 population and employment growth projections. Thus, the project would be within SANDAG’s population growth forecast and would not conflict with the SIP and RAQS.

Construction and Operational Emissions. Project construction and operational emissions would not exceed the San Diego APCD thresholds. Thus, the project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard.

Expose Sensitive Receptors to Substantial Pollutant Concentrations. The project would not cause or contribute to CO hot spots or otherwise expose receptors to substantial pollutant concentrations from operation of the adjacent rail corridor.

Odors. The project would provide new residences and related infrastructure improvements.

These uses would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Greenhouse Gas Emissions. The proposed project would not generate annual GHG emissions that would exceed the 900 MT CO2e threshold. Further, the project would be consistent with the City of Sustainable Santee Plan, 2017 and 2022 CARB Scoping Plans, the City of Santee General Plan Land Use Element and the SANDAG Regional Plan; San Diego Forward, adopted in December 2021. Impacts related to air quality and greenhouse gas emissions would be less than significant.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
54 REFERENCES
California Natural Resources Agency. 2023 California Environmental Quality Act (CEQA) Statute and Guidelines. Association of Environmental Professionals. 2023 California Air Pollution Control Officers Association. CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA). January 2008.

California Air Pollution Control Officers Association. California Emission Estimator Model version 2022.1.1.16, May 2022.

California Air Resources Board. Ambient Air Quality Standards. Updated February, 2016. http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-managementplans/naaqs-caaqs-feb2016.pdf California Air Resources Board, Maps of State and Federal Area Designations, https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-areadesignations?corr California Air Resources Board. 2020, 2021, & 2022 Annual Air Quality Data Summaries. http://www.arb.ca.gov/adam/topfour/topfour1.php. Accessed October 2023.

California Air Resources Board, California Greenhouse Gas Emissions for 2000 to 2018, 2020 Edition.
https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2018/ghg_inventory_trends_00-

18.pdf
California Air Resources Board. June 2017. Greenhouse Gas Inventory Data Inventory Program.

Available: https://www.arb.ca.gov/cc/inventory/inventory.htm California Air Resources Board. April 2012. Greenhouse Gas Inventory Data – 2020 Emissions Forecast. Available: http://www.arb.ca.gov/cc/inventory/data/forecast.htm California Air Resources Board. May 2014. 2020 Business As Usual Emission Projection, 2014 Edition. Available:
http://www.arb.ca.gov/cc/inventory/data/tables/2020_bau_forecast_by_scoping_categor y_2014-05-22.pdf
California Air Resources Board. June 2015. Greenhouse Gas Emissions Inventory– 2015 Edition Available: http://www.arb.ca.gov/cc/inventory/data/data.htm California Climate Action Registry General Reporting Protocol, Reporting Entity-Wide Greenhouse Gas Emissions, Version 3.1, January 2009.
10939 Summit Avenue Residential Project Air Quality and Greenhouse Gas Study City of Santee
55 California Environmental Protection Agency, March 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature.
http://www.climatechange.ca.gov/climate_action_team/reports/2006-04- 03_FINAL_CAT_REPORT_EXECSUMMARY.PDF
City of Santee. Sustainable Santee Plan, LSA, December 2019.

City of Santee. General Plan Land Use Element. 2004
Intergovernmental Panel on Climate Change [IPCC]. Revised 1996 IPCC Guidelines for National Greenhouse Gas Inventories. [Kroeze, C.; Mosier, A.; Nevison, C.; Oenema, O.; Seitzinger, S.; Cleemput, O. van; Conrad, R.; Mitra, A.P.; H.U., Neue; Sass, R.]. Paris: OECD, 1997.

Intergovernmental Panel on Climate Change [IPCC]. Climate Change 2014 Synthesis Report, 2014.

Office of the California Attorney General. The California Environmental Quality Act, Addressing Global Warming Impacts at the Local Agency Level. Updated May 21, 2008. http://ag.ca.gov/globalwarming/pdf/GW_mitigation_measures.pdf San Diego Association of Governments, 2021 Regional Plan; San Diego Forward (December 2021) https://sdforward.com/mobility-planning/2021-regional-plan San Diego Association of Governments, 2021 Regional Plan; San Diego Forward (December 2021) Appendix F: Regional Growth Forecast and Sustainable Communities Strategy Land Use Pattern https://www.sandag.org/-/media/SANDAG/Documents/PDF/regional-plan/2021- regional-plan/final-2021-regional-plan/2021-regional-plan-appendix-f-2021-12-01.pdf TJW Engineering, Inc. Summit Avenue Trip Generation Analysis and VMT Screening, City of Santee, October 13, 2023
United States Environmental Protection Agency (U.S. EPA). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2010. U. S. EPA #430-R-11-005. April 2012. http://www.epa.gov/climatechange/emissions/usinventoryreport.html United States Environmental Protection Agency (U.S. EPA). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2018. U. S. EPA #430-R-20-002. April 2020. https://www.epa.gov/sites/production/files/2020-04/documents/us-ghg-inventory-2020- main-text.pdf
Appendix A
CalEEMod Air Quality and Greenhouse Gas Emissions Model Results – Summer/Annual
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10939 Summit Avenue Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.3. Construction Emissions by Year, Mitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

2.6. Operations Emissions by Sector, Mitigated

3. Construction Emissions Details

3.1. Demolition (2024) - Unmitigated

3.2. Demolition (2024) - Mitigated
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3.3. Site Preparation (2024) - Unmitigated

3.4. Site Preparation (2024) - Mitigated

3.5. Grading (2024) - Unmitigated

3.6. Grading (2024) - Mitigated

3.7. Grading (2025) - Unmitigated

3.8. Grading (2025) - Mitigated

3.9. Building Construction (2025) - Unmitigated

3.10. Building Construction (2025) - Mitigated

3.11. Building Construction (2026) - Unmitigated

3.12. Building Construction (2026) - Mitigated

3.13. Paving (2026) - Unmitigated

3.14. Paving (2026) - Mitigated

3.15. Architectural Coating (2026) - Unmitigated

3.16. Architectural Coating (2026) - Mitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
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4.1.2. Mitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.2. Electricity Emissions By Land Use - Mitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.2.4. Natural Gas Emissions By Land Use - Mitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.3.2. Mitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.4.2. Mitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.5.2. Mitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
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4.6.2. Mitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.7.2. Mitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.8.2. Mitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.9.2. Mitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated

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5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources
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5.9.1. Unmitigated

5.9.2. Mitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.1.2. Mitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.10.4. Landscape Equipment - Mitigated

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.11.2. Mitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.12.2. Mitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated
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5.13.2. Mitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.14.2. Mitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.15.2. Mitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
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5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 10939 Summit Avenue
Construction Start Date 10/28/2024
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.60
Precipitation (days) 13.8
Location 32.87597002566757, -116.9750646515862
County San Diego
City Santee
Air District San Diego County APCD
Air Basin San Diego
TAZ 6536
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility San Diego Gas & Electric
App Version 2022.1.1.20

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
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Apartments Low
Rise

50.0 Dwelling Unit 3.13 53,000 2,000 — 139 —
Parking Lot 13.0 Space 0.12 0.00 100 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-11 Limit Vehicle Speeds on Unpaved Roads Construction C-12 Sweep Paved Roads
Water W-7 Adopt a Water Conservation Strategy
Waste S-1/S-2 Implement Waste Reduction Plan

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.20 1.82 17.3 19.0 0.03 0.74 3.08 3.81 0.68 1.42 2.09 — 3,823 3,823 0.17 0.14 2.10 3,872 Mit. 2.20 1.82 17.3 19.0 0.03 0.74 3.08 3.81 0.68 1.42 2.09 — 3,823 3,823 0.17 0.14 2.10 3,872 %
Reduced
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 5.63 9.28 58.4 41.5 0.15 1.89 11.9 13.8 1.76 5.09 6.85 — 21,510 21,510 1.09 2.62 0.91 22,319 Mit. 5.63 9.28 58.4 41.5 0.15 1.89 11.9 13.8 1.76 5.09 6.85 — 21,510 21,510 1.09 2.62 0.91 22,319 10939 Summit Avenue Detailed Report, 10/25/2023
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% — — — — — — — — — — — — — — — — — —
Reduced
Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.25 1.14 9.28 11.5 0.02 0.38 0.91 1.29 0.35 0.38 0.74 — 2,275 2,275 0.10 0.06 0.55 2,296 Mit. 1.25 1.14 9.28 11.5 0.02 0.38 0.91 1.29 0.35 0.38 0.74 — 2,275 2,275 0.10 0.06 0.55 2,296 %
Reduced
— — — — — — — — — — — — — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.23 0.21 1.69 2.10 < 0.005 0.07 0.17 0.24 0.06 0.07 0.13 — 377 377 0.02 0.01 0.09 380 Mit. 0.23 0.21 1.69 2.10 < 0.005 0.07 0.17 0.24 0.06 0.07 0.13 — 377 377 0.02 0.01 0.09 380 %
Reduced
— — — — — — — — — — — — — — — — — —

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 2.20 1.82 17.3 19.0 0.03 0.74 3.08 3.81 0.68 1.42 2.09 — 3,823 3,823 0.17 0.14 2.10 3,872 2026 0.90 0.79 6.29 9.68 0.01 0.26 0.17 0.43 0.24 0.04 0.28 — 1,536 1,536 0.06 0.02 0.65 1,543 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2024 5.63 4.05 58.4 41.5 0.15 1.89 11.9 13.8 1.76 5.09 6.85 — 21,510 21,510 1.09 2.62 0.91 22,319 2025 2.19 1.82 17.3 18.9 0.03 0.74 3.08 3.81 0.68 1.42 2.09 — 3,815 3,815 0.17 0.14 0.05 3,862 2026 1.61 9.28 11.0 15.8 0.03 0.40 0.40 0.80 0.37 0.10 0.47 — 3,041 3,041 0.13 0.05 0.04 3,061 10939 Summit Avenue Detailed Report, 10/25/2023
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Average — — — — — — — — — — — — — — — — — —
Daily
2024 0.38 0.31 3.22 2.88 0.01 0.13 0.34 0.47 0.12 0.15 0.27 — 700 700 0.03 0.05 0.27 715 2025 1.25 1.04 9.28 11.5 0.02 0.38 0.91 1.29 0.35 0.38 0.74 — 2,275 2,275 0.10 0.06 0.55 2,296 2026 0.27 1.14 1.90 2.74 < 0.005 0.07 0.07 0.14 0.07 0.02 0.08 — 521 521 0.02 0.01 0.12 525 Annual — — — — — — — — — — — — — — — — — —
2024 0.07 0.06 0.59 0.53 < 0.005 0.02 0.06 0.09 0.02 0.03 0.05 — 116 116 0.01 0.01 0.05 118 2025 0.23 0.19 1.69 2.10 < 0.005 0.07 0.17 0.24 0.06 0.07 0.13 — 377 377 0.02 0.01 0.09 380 2026 0.05 0.21 0.35 0.50 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 86.3 86.3 < 0.005 < 0.005 0.02 86.9

2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 2.20 1.82 17.3 19.0 0.03 0.74 3.08 3.81 0.68 1.42 2.09 — 3,823 3,823 0.17 0.14 2.10 3,872 2026 0.90 0.79 6.29 9.68 0.01 0.26 0.17 0.43 0.24 0.04 0.28 — 1,536 1,536 0.06 0.02 0.65 1,543 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2024 5.63 4.05 58.4 41.5 0.15 1.89 11.9 13.8 1.76 5.09 6.85 — 21,510 21,510 1.09 2.62 0.91 22,319 2025 2.19 1.82 17.3 18.9 0.03 0.74 3.08 3.81 0.68 1.42 2.09 — 3,815 3,815 0.17 0.14 0.05 3,862 2026 1.61 9.28 11.0 15.8 0.03 0.40 0.40 0.80 0.37 0.10 0.47 — 3,041 3,041 0.13 0.05 0.04 3,061 Average
Daily
— — — — — — — — — — — — — — — — — —
2024 0.38 0.31 3.22 2.88 0.01 0.13 0.34 0.47 0.12 0.15 0.27 — 700 700 0.03 0.05 0.27 715 2025 1.25 1.04 9.28 11.5 0.02 0.38 0.91 1.29 0.35 0.38 0.74 — 2,275 2,275 0.10 0.06 0.55 2,296 2026 0.27 1.14 1.90 2.74 < 0.005 0.07 0.07 0.14 0.07 0.02 0.08 — 521 521 0.02 0.01 0.12 525 10939 Summit Avenue Detailed Report, 10/25/2023
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Annual — — — — — — — — — — — — — — — — — —
2024 0.07 0.06 0.59 0.53 < 0.005 0.02 0.06 0.09 0.02 0.03 0.05 — 116 116 0.01 0.01 0.05 118 2025 0.23 0.19 1.69 2.10 < 0.005 0.07 0.17 0.24 0.06 0.07 0.13 — 377 377 0.02 0.01 0.09 380 2026 0.05 0.21 0.35 0.50 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 86.3 86.3 < 0.005 < 0.005 0.02 86.9

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.11 3.16 1.41 15.5 0.03 0.04 2.67 2.70 0.04 0.68 0.71 23.2 3,651 3,675 2.51 0.13 10.8 3,786 Mit. 2.11 3.16 1.41 15.5 0.03 0.04 2.67 2.70 0.04 0.68 0.71 7.66 3,648 3,655 0.95 0.13 10.8 3,727 %
Reduced
— — — — — — — — — — — 67% < 0.5% 1% 62% 1% — 2%
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.81 2.87 1.50 11.9 0.03 0.04 2.67 2.70 0.04 0.68 0.71 23.2 3,505 3,528 2.52 0.13 0.65 3,632 Mit. 1.81 2.87 1.50 11.9 0.03 0.04 2.67 2.70 0.04 0.68 0.71 7.66 3,501 3,509 0.96 0.13 0.65 3,573 %
Reduced
— — — — — — — — — — — 67% < 0.5% 1% 62% 1% — 2%
Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.73 2.80 1.36 12.1 0.03 0.04 2.37 2.40 0.03 0.60 0.63 23.2 3,216 3,239 2.50 0.12 4.43 3,342 Mit. 1.73 2.80 1.36 12.1 0.03 0.04 2.37 2.40 0.03 0.60 0.63 7.66 3,212 3,220 0.94 0.12 4.43 3,283 %
Reduced
— — — — — — — — — — — 67% < 0.5% 1% 62% 1% — 2%
Annual
(Max)
— — — — — — — — — — — — — — — — — —
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Unmit. 0.32 0.51 0.25 2.20 0.01 0.01 0.43 0.44 0.01 0.11 0.12 3.84 532 536 0.41 0.02 0.73 553 Mit. 0.32 0.51 0.25 2.20 0.01 0.01 0.43 0.44 0.01 0.11 0.12 1.27 532 533 0.16 0.02 0.73 544 %
Reduced
— — — — — — — — — — — 67% < 0.5% 1% 62% 1% — 2%

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.82 1.67 1.21 12.6 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 3,118 3,118 0.14 0.12 10.5 3,167 Area 0.27 1.48 0.03 2.84 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 7.58 7.58 < 0.005 < 0.005 — 7.61 Energy 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 506 506 0.04 < 0.005 — 508 Water — — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1 Waste — — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5 Refrig. — — — — — — — — — — — — — — — — 0.38 0.38
Total 2.11 3.16 1.41 15.5 0.03 0.04 2.67 2.70 0.04 0.68 0.71 23.2 3,651 3,675 2.51 0.13 10.8 3,786 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.79 1.63 1.33 11.8 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 2,979 2,979 0.15 0.12 0.27 3,020 Area 0.00 1.23 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Energy 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 506 506 0.04 < 0.005 — 508 Water — — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1 Waste — — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5 Refrig. — — — — — — — — — — — — — — — — 0.38 0.38
Total 1.81 2.87 1.50 11.9 0.03 0.04 2.67 2.70 0.04 0.68 0.71 23.2 3,505 3,528 2.52 0.13 0.65 3,632 10939 Summit Avenue Detailed Report, 10/25/2023
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Average — — — — — — — — — — — — — — — — — —
Daily
Mobile 1.58 1.44 1.17 10.6 0.03 0.02 2.37 2.39 0.02 0.60 0.62 — 2,686 2,686 0.13 0.11 4.05 2,726 Area 0.13 1.35 0.01 1.40 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 3.74 3.74 < 0.005 < 0.005 — 3.75 Energy 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 506 506 0.04 < 0.005 — 508 Water — — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1 Waste — — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5 Refrig. — — — — — — — — — — — — — — — — 0.38 0.38
Total 1.73 2.80 1.36 12.1 0.03 0.04 2.37 2.40 0.03 0.60 0.63 23.2 3,216 3,239 2.50 0.12 4.43 3,342 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.29 0.26 0.21 1.93 < 0.005 < 0.005 0.43 0.44 < 0.005 0.11 0.11 — 445 445 0.02 0.02 0.67 451 Area 0.02 0.25 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.62 0.62 < 0.005 < 0.005 — 0.62 Energy < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 83.8 83.8 0.01 < 0.005 — 84.1 Water — — — — — — — — — — — 0.56 3.25 3.81 0.06 < 0.005 — 5.65 Waste — — — — — — — — — — — 3.29 0.00 3.29 0.33 0.00 — 11.5 Refrig. — — — — — — — — — — — — — — — — 0.06 0.06
Total 0.32 0.51 0.25 2.20 0.01 0.01 0.43 0.44 0.01 0.11 0.12 3.84 532 536 0.41 0.02 0.73 553

2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.82 1.67 1.21 12.6 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 3,118 3,118 0.14 0.12 10.5 3,167 Area 0.27 1.48 0.03 2.84 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 7.58 7.58 < 0.005 < 0.005 — 7.61 Energy 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 506 506 0.04 < 0.005 — 508 Water — — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3 10939 Summit Avenue Detailed Report, 10/25/2023
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Waste — — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4 Refrig. — — — — — — — — — — — — — — — — 0.38 0.38
Total 2.11 3.16 1.41 15.5 0.03 0.04 2.67 2.70 0.04 0.68 0.71 7.66 3,648 3,655 0.95 0.13 10.8 3,727 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.79 1.63 1.33 11.8 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 2,979 2,979 0.15 0.12 0.27 3,020 Area 0.00 1.23 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Energy 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 506 506 0.04 < 0.005 — 508 Water — — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3 Waste — — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4 Refrig. — — — — — — — — — — — — — — — — 0.38 0.38
Total 1.81 2.87 1.50 11.9 0.03 0.04 2.67 2.70 0.04 0.68 0.71 7.66 3,501 3,509 0.96 0.13 0.65 3,573 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 1.58 1.44 1.17 10.6 0.03 0.02 2.37 2.39 0.02 0.60 0.62 — 2,686 2,686 0.13 0.11 4.05 2,726 Area 0.13 1.35 0.01 1.40 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 3.74 3.74 < 0.005 < 0.005 — 3.75 Energy 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 506 506 0.04 < 0.005 — 508 Water — — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3 Waste — — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4 Refrig. — — — — — — — — — — — — — — — — 0.38 0.38
Total 1.73 2.80 1.36 12.1 0.03 0.04 2.37 2.40 0.03 0.60 0.63 7.66 3,212 3,220 0.94 0.12 4.43 3,283 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.29 0.26 0.21 1.93 < 0.005 < 0.005 0.43 0.44 < 0.005 0.11 0.11 — 445 445 0.02 0.02 0.67 451 Area 0.02 0.25 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.62 0.62 < 0.005 < 0.005 — 0.62 Energy < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 83.8 83.8 0.01 < 0.005 — 84.1 Water — — — — — — — — — — — 0.45 2.60 3.04 0.05 < 0.005 — 4.52 Waste — — — — — — — — — — — 0.82 0.00 0.82 0.08 0.00 — 2.88 Refrig. — — — — — — — — — — — — — — — — 0.06 0.06
10939 Summit Avenue Detailed Report, 10/25/2023
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Total 0.32 0.51 0.25 2.20 0.01 0.01 0.43 0.44 0.01 0.11 0.12 1.27 532 533 0.16 0.02 0.73 544

3. Construction Emissions Details

3.1. Demolition (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

3.12 2.62 24.9 21.7 0.03 1.06 — 1.06 0.98 — 0.98 — 3,425 3,425 0.14 0.03 — 3,437 Demolitio
n
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.17 0.14 1.36 1.19 < 0.005 0.06 — 0.06 0.05 — 0.05 — 188 188 0.01 < 0.005 — 188 Demolitio
n
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.03 0.25 0.22 < 0.005 0.01 — 0.01 0.01 — 0.01 — 31.1 31.1 < 0.005 < 0.005 — 31.2 10939 Summit Avenue Detailed Report, 10/25/2023
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Demolitio — — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — — n
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.06 0.65 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 137 137 0.01 0.01 0.02 139 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.58 7.58 < 0.005 < 0.005 0.01 7.69 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.25 1.25 < 0.005 < 0.005 < 0.005 1.27 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.2. Demolition (2024) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
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Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

3.12 2.62 24.9 21.7 0.03 1.06 — 1.06 0.98 — 0.98 — 3,425 3,425 0.14 0.03 — 3,437 Demolitio
n
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.17 0.14 1.36 1.19 < 0.005 0.06 — 0.06 0.05 — 0.05 — 188 188 0.01 < 0.005 — 188 Demolitio
n
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.03 0.25 0.22 < 0.005 0.01 — 0.01 0.01 — 0.01 — 31.1 31.1 < 0.005 < 0.005 — 31.2 Demolitio
n
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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Worker 0.07 0.06 0.06 0.65 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 137 137 0.01 0.01 0.02 139 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.58 7.58 < 0.005 < 0.005 0.01 7.69 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.25 1.25 < 0.005 < 0.005 < 0.005 1.27 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Site Preparation (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

4.34 3.65 36.0 32.9 0.05 1.60 — 1.60 1.47 — 1.47 — 5,296 5,296 0.21 0.04 — 5,314 Dust
From
Material
Movement
— — — — — — 7.70 7.70 — 3.95 3.95 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 10939 Summit Avenue Detailed Report, 10/25/2023
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Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.06 0.05 0.49 0.45 < 0.005 0.02 — 0.02 0.02 — 0.02 — 72.5 72.5 < 0.005 < 0.005 — 72.8 Dust
From
Material
Movement
— — — — — — 0.11 0.11 — 0.05 0.05 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.09 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 12.0 12.0 < 0.005 < 0.005 — 12.1 Dust
From
Material
Movement
— — — — — — 0.02 0.02 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.07 0.76 0.00 0.00 0.15 0.15 0.00 0.03 0.03 — 160 160 0.01 0.01 0.02 162 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 1.21 0.33 22.4 7.78 0.10 0.29 4.06 4.35 0.29 1.11 1.40 — 16,055 16,055 0.87 2.57 0.89 16,843 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.21 2.21 < 0.005 < 0.005 < 0.005 2.24 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 10939 Summit Avenue Detailed Report, 10/25/2023
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Hauling 0.02 < 0.005 0.31 0.11 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 — 220 220 0.01 0.04 0.20 231 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.37 0.37 < 0.005 < 0.005 < 0.005 0.37 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 36.4 36.4 < 0.005 0.01 0.03 38.2

3.4. Site Preparation (2024) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

4.34 3.65 36.0 32.9 0.05 1.60 — 1.60 1.47 — 1.47 — 5,296 5,296 0.21 0.04 — 5,314 Dust
From
Material
Movement
— — — — — — 7.70 7.70 — 3.95 3.95 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.06 0.05 0.49 0.45 < 0.005 0.02 — 0.02 0.02 — 0.02 — 72.5 72.5 < 0.005 < 0.005 — 72.8 Dust
From
Material
Movement
— — — — — — 0.11 0.11 — 0.05 0.05 — — — — — — —
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Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.09 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 12.0 12.0 < 0.005 < 0.005 — 12.1 Dust
From
Material
Movement
— — — — — — 0.02 0.02 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.07 0.76 0.00 0.00 0.15 0.15 0.00 0.03 0.03 — 160 160 0.01 0.01 0.02 162 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 1.21 0.33 22.4 7.78 0.10 0.29 4.06 4.35 0.29 1.11 1.40 — 16,055 16,055 0.87 2.57 0.89 16,843 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.21 2.21 < 0.005 < 0.005 < 0.005 2.24 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 < 0.005 0.31 0.11 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 — 220 220 0.01 0.04 0.20 231 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.37 0.37 < 0.005 < 0.005 < 0.005 0.37 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 36.4 36.4 < 0.005 0.01 0.03 38.2 10939 Summit Avenue Detailed Report, 10/25/2023
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3.5. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

2.26 1.90 18.2 18.8 0.03 0.84 — 0.84 0.77 — 0.77 — 2,958 2,958 0.12 0.02 — 2,969 Dust
From
Material
Movement
— — — — — — 2.76 2.76 — 1.34 1.34 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.12 0.10 1.00 1.03 < 0.005 0.05 — 0.05 0.04 — 0.04 — 162 162 0.01 < 0.005 — 163 Dust
From
Material
Movement
— — — — — — 0.15 0.15 — 0.07 0.07 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.02 0.18 0.19 < 0.005 0.01 — 0.01 0.01 — 0.01 — 26.8 26.8 < 0.005 < 0.005 — 26.9 10939 Summit Avenue Detailed Report, 10/25/2023
25 / 85
Dust — — — — — — 0.03 0.03 — 0.01 0.01 — — — — — — —
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.06 0.65 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 137 137 0.01 0.01 0.02 139 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.06 0.02 1.03 0.36 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 — 736 736 0.04 0.12 0.04 773 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.58 7.58 < 0.005 < 0.005 0.01 7.69 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 40.3 40.3 < 0.005 0.01 0.04 42.4 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.25 1.25 < 0.005 < 0.005 < 0.005 1.27 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.68 6.68 < 0.005 < 0.005 0.01 7.01

3.6. Grading (2024) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
10939 Summit Avenue Detailed Report, 10/25/2023
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Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment

2.26 1.90 18.2 18.8 0.03 0.84— 0.84 0.77— 0.77— 2,958 2,958 0.12 0.02— 2,969 Dust
From
Material
Movement
—————— 2.76 2.76— 1.34 1.34———————
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
——————————————————
Off-Road
Equipment

0.12 0.10 1.00 1.03 < 0.005 0.05— 0.05 0.04— 0.04— 162 162 0.01 < 0.005— 163 Dust
From
Material
Movement
—————— 0.15 0.15— 0.07 0.07———————
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————————————————
Off-Road
Equipment

0.02 0.02 0.18 0.19 < 0.005 0.01— 0.01 0.01— 0.01— 26.8 26.8 < 0.005 < 0.005— 26.9 Dust
From
Material
Movement
—————— 0.03 0.03— 0.01 0.01———————
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Offsite——————————————————
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Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.06 0.65 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 137 137 0.01 0.01 0.02 139 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.06 0.02 1.03 0.36 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 — 736 736 0.04 0.12 0.04 773 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.58 7.58 < 0.005 < 0.005 0.01 7.69 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 40.3 40.3 < 0.005 0.01 0.04 42.4 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.25 1.25 < 0.005 < 0.005 < 0.005 1.27 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.68 6.68 < 0.005 < 0.005 0.01 7.01

3.7. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

2.07 1.74 16.3 17.9 0.03 0.72 — 0.72 0.66 — 0.66 — 2,959 2,959 0.12 0.02 — 2,970 10939 Summit Avenue Detailed Report, 10/25/2023
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Dust — — — — — — 2.76 2.76 — 1.34 1.34 — — — — — — —
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

2.07 1.74 16.3 17.9 0.03 0.72 — 0.72 0.66 — 0.66 — 2,959 2,959 0.12 0.02 — 2,970 Dust
From
Material
Movement
— — — — — — 2.76 2.76 — 1.34 1.34 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.51 0.43 3.98 4.38 0.01 0.18 — 0.18 0.16 — 0.16 — 724 724 0.03 0.01 — 726 Dust
From
Material
Movement
— — — — — — 0.68 0.68 — 0.33 0.33 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.09 0.08 0.73 0.80 < 0.005 0.03 — 0.03 0.03 — 0.03 — 120 120 < 0.005 < 0.005 — 120 Dust
From
Material
Movement
— — — — — — 0.12 0.12 — 0.06 0.06 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 10939 Summit Avenue Detailed Report, 10/25/2023
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.05 0.69 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 142 142 0.01 < 0.005 0.53 144 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.06 0.02 0.95 0.35 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 — 721 721 0.04 0.11 1.57 758 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.05 0.61 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 134 134 0.01 0.01 0.01 136 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.06 0.01 0.98 0.36 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 — 721 721 0.04 0.11 0.04 756 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.01 0.15 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 33.2 33.2 < 0.005 < 0.005 0.06 33.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.24 0.09 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 176 176 0.01 0.03 0.17 185 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.49 5.49 < 0.005 < 0.005 0.01 5.57 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 29.2 29.2 < 0.005 < 0.005 0.03 30.6

3.8. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
10939 Summit Avenue Detailed Report, 10/25/2023
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Off-Road
Equipment

2.07 1.74 16.3 17.9 0.03 0.72— 0.72 0.66— 0.66— 2,959 2,959 0.12 0.02— 2,970 Dust
From
Material
Movement
—————— 2.76 2.76— 1.34 1.34———————
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment

2.07 1.74 16.3 17.9 0.03 0.72— 0.72 0.66— 0.66— 2,959 2,959 0.12 0.02— 2,970 Dust
From
Material
Movement
—————— 2.76 2.76— 1.34 1.34———————
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
——————————————————
Off-Road
Equipment

0.51 0.43 3.98 4.38 0.01 0.18— 0.18 0.16— 0.16— 724 724 0.03 0.01— 726 Dust
From
Material
Movement
—————— 0.68 0.68— 0.33 0.33———————
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————————————————
Off-Road
Equipment

0.09 0.08 0.73 0.80 < 0.005 0.03— 0.03 0.03— 0.03— 120 120 < 0.005 < 0.005— 120 Dust
From
Material
Movement
—————— 0.12 0.12— 0.06 0.06———————
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Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.05 0.69 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 142 142 0.01 < 0.005 0.53 144 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.06 0.02 0.95 0.35 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 — 721 721 0.04 0.11 1.57 758 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.05 0.61 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 134 134 0.01 0.01 0.01 136 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.06 0.01 0.98 0.36 < 0.005 0.01 0.19 0.20 0.01 0.05 0.06 — 721 721 0.04 0.11 0.04 756 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.01 0.15 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 33.2 33.2 < 0.005 < 0.005 0.06 33.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.24 0.09 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 176 176 0.01 0.03 0.17 185 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.49 5.49 < 0.005 < 0.005 0.01 5.57 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 29.2 29.2 < 0.005 < 0.005 0.03 30.6

3.9. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
10939 Summit Avenue Detailed Report, 10/25/2023
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.63 0.53 4.91 6.12 0.01 0.20 — 0.20 0.19 — 0.19 — 1,126 1,126 0.05 0.01 — 1,130 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.12 0.10 0.90 1.12 < 0.005 0.04 — 0.04 0.03 — 0.03 — 186 186 0.01 < 0.005 — 187 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.16 0.15 0.11 1.67 0.00 0.00 0.30 0.30 0.00 0.07 0.07 — 342 342 0.02 0.01 1.28 347 Vendor 0.01 0.01 0.18 0.08 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 134 134 0.01 0.02 0.35 140 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 10939 Summit Avenue Detailed Report, 10/25/2023
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Worker 0.16 0.14 0.12 1.46 0.00 0.00 0.30 0.30 0.00 0.07 0.07 — 323 323 0.02 0.01 0.03 327 Vendor 0.01 0.01 0.18 0.09 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 134 134 0.01 0.02 0.01 140 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.07 0.06 0.70 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 153 153 0.01 0.01 0.26 155 Vendor 0.01 < 0.005 0.09 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 — 62.8 62.8 < 0.005 0.01 0.07 65.6 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 25.3 25.3 < 0.005 < 0.005 0.04 25.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 10.4 10.4 < 0.005 < 0.005 0.01 10.9 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
10939 Summit Avenue Detailed Report, 10/25/2023
34 / 85
Off-Road
Equipment

1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.63 0.53 4.91 6.12 0.01 0.20 — 0.20 0.19 — 0.19 — 1,126 1,126 0.05 0.01 — 1,130 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.12 0.10 0.90 1.12 < 0.005 0.04 — 0.04 0.03 — 0.03 — 186 186 0.01 < 0.005 — 187 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.16 0.15 0.11 1.67 0.00 0.00 0.30 0.30 0.00 0.07 0.07 — 342 342 0.02 0.01 1.28 347 Vendor 0.01 0.01 0.18 0.08 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 134 134 0.01 0.02 0.35 140 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.16 0.14 0.12 1.46 0.00 0.00 0.30 0.30 0.00 0.07 0.07 — 323 323 0.02 0.01 0.03 327 Vendor 0.01 0.01 0.18 0.09 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 134 134 0.01 0.02 0.01 140 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.07 0.06 0.70 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 153 153 0.01 0.01 0.26 155 Vendor 0.01 < 0.005 0.09 0.04 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 — 62.8 62.8 < 0.005 0.01 0.07 65.6 10939 Summit Avenue Detailed Report, 10/25/2023
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 25.3 25.3 < 0.005 < 0.005 0.04 25.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 10.4 10.4 < 0.005 < 0.005 0.01 10.9 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.28 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.21 0.17 1.58 2.08 < 0.005 0.06 — 0.06 0.06 — 0.06 — 385 385 0.02 < 0.005 — 386 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.04 0.03 0.29 0.38 < 0.005 0.01 — 0.01 0.01 — 0.01 — 63.7 63.7 < 0.005 < 0.005 — 63.9 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 10939 Summit Avenue Detailed Report, 10/25/2023
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.14 0.13 0.11 1.37 0.00 0.00 0.30 0.30 0.00 0.07 0.07 — 316 316 0.02 0.01 0.03 320 Vendor 0.01 < 0.005 0.18 0.08 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 131 131 0.01 0.02 0.01 137 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.22 0.00 0.00 0.05 0.05 0.00 0.01 0.01 — 51.2 51.2 < 0.005 < 0.005 0.08 51.9 Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.1 21.1 < 0.005 < 0.005 0.02 22.0 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 8.47 8.47 < 0.005 < 0.005 0.01 8.60 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.49 3.49 < 0.005 < 0.005 < 0.005 3.65 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.12. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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Off-Road
Equipment

1.28 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.21 0.17 1.58 2.08 < 0.005 0.06 — 0.06 0.06 — 0.06 — 385 385 0.02 < 0.005 — 386 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.04 0.03 0.29 0.38 < 0.005 0.01 — 0.01 0.01 — 0.01 — 63.7 63.7 < 0.005 < 0.005 — 63.9 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.14 0.13 0.11 1.37 0.00 0.00 0.30 0.30 0.00 0.07 0.07 — 316 316 0.02 0.01 0.03 320 Vendor 0.01 < 0.005 0.18 0.08 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 131 131 0.01 0.02 0.01 137 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.22 0.00 0.00 0.05 0.05 0.00 0.01 0.01 — 51.2 51.2 < 0.005 < 0.005 0.08 51.9 Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.1 21.1 < 0.005 < 0.005 0.02 22.0 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 8.47 8.47 < 0.005 < 0.005 0.01 8.60 10939 Summit Avenue Detailed Report, 10/25/2023
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Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.49 3.49 < 0.005 < 0.005 < 0.005 3.65 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.81 0.68 6.23 8.81 0.01 0.26 — 0.26 0.24 — 0.24 — 1,350 1,350 0.05 0.01 — 1,355 Paving — 0.03 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.81 0.68 6.23 8.81 0.01 0.26 — 0.26 0.24 — 0.24 — 1,350 1,350 0.05 0.01 — 1,355 Paving — 0.03 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.02 0.17 0.24 < 0.005 0.01 — 0.01 0.01 — 0.01 — 37.0 37.0 < 0.005 < 0.005 — 37.1 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
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Off-Road
Equipment
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 6.12 6.12 < 0.005 < 0.005 — 6.14 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.06 0.86 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 186 186 0.01 0.01 0.65 189 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.06 0.76 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 176 176 0.01 0.01 0.02 178 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.85 4.85 < 0.005 < 0.005 0.01 4.92 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.80 0.80 < 0.005 < 0.005 < 0.005 0.82 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.14. Paving (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 10939 Summit Avenue Detailed Report, 10/25/2023
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Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.81 0.68 6.23 8.81 0.01 0.26 — 0.26 0.24 — 0.24 — 1,350 1,350 0.05 0.01 — 1,355 Paving — 0.03 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.81 0.68 6.23 8.81 0.01 0.26 — 0.26 0.24 — 0.24 — 1,350 1,350 0.05 0.01 — 1,355 Paving — 0.03 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.02 0.17 0.24 < 0.005 0.01 — 0.01 0.01 — 0.01 — 37.0 37.0 < 0.005 < 0.005 — 37.1 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 6.12 6.12 < 0.005 < 0.005 — 6.14 Paving — < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.06 0.86 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 186 186 0.01 0.01 0.65 189 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.06 0.76 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 176 176 0.01 0.01 0.02 178 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.85 4.85 < 0.005 < 0.005 0.01 4.92 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.80 0.80 < 0.005 < 0.005 < 0.005 0.82 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.15. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Off-Road
Equipment

0.15 0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coatings
— 7.93 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.01 0.10 0.13 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.4 15.4 < 0.005 < 0.005 — 15.4 Architect
ural
Coatings
— 0.91 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.54 2.54 < 0.005 < 0.005 — 2.55 Architect
ural
Coatings
— 0.17 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.02 0.27 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 63.2 63.2 < 0.005 < 0.005 0.01 64.0 10939 Summit Avenue Detailed Report, 10/25/2023
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.34 7.34 < 0.005 < 0.005 0.01 7.45 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.21 1.21 < 0.005 < 0.005 < 0.005 1.23 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.16. Architectural Coating (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.15 0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coatings
— 7.93 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
10939 Summit Avenue Detailed Report, 10/25/2023
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Off-Road
Equipment

0.02 0.01 0.10 0.13 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.4 15.4 < 0.005 < 0.005 — 15.4 Architect
ural
Coatings
— 0.91 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.54 2.54 < 0.005 < 0.005 — 2.55 Architect
ural
Coatings
— 0.17 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.02 0.27 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 63.2 63.2 < 0.005 < 0.005 0.01 64.0 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 7.34 7.34 < 0.005 < 0.005 0.01 7.45 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.21 1.21 < 0.005 < 0.005 < 0.005 1.23 10939 Summit Avenue Detailed Report, 10/25/2023
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

1.82 1.67 1.21 12.6 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 3,118 3,118 0.14 0.12 10.5 3,167 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.82 1.67 1.21 12.6 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 3,118 3,118 0.14 0.12 10.5 3,167 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

1.79 1.63 1.33 11.8 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 2,979 2,979 0.15 0.12 0.27 3,020 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.79 1.63 1.33 11.8 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 2,979 2,979 0.15 0.12 0.27 3,020 Annual — — — — — — — — — — — — — — — — — —
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Apartme 0.29 0.26 0.21 1.93 < 0.005 < 0.005 0.43 0.44 < 0.005 0.11 0.11 — 445 445 0.02 0.02 0.67 451 nts
Low Rise
Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.29 0.26 0.21 1.93 < 0.005 < 0.005 0.43 0.44 < 0.005 0.11 0.11 — 445 445 0.02 0.02 0.67 451

4.1.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

1.82 1.67 1.21 12.6 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 3,118 3,118 0.14 0.12 10.5 3,167 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.82 1.67 1.21 12.6 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 3,118 3,118 0.14 0.12 10.5 3,167 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

1.79 1.63 1.33 11.8 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 2,979 2,979 0.15 0.12 0.27 3,020 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.79 1.63 1.33 11.8 0.03 0.02 2.67 2.69 0.02 0.68 0.70 — 2,979 2,979 0.15 0.12 0.27 3,020 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

0.29 0.26 0.21 1.93 < 0.005 < 0.005 0.43 0.44 < 0.005 0.11 0.11 — 445 445 0.02 0.02 0.67 451 10939 Summit Avenue Detailed Report, 10/25/2023
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Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.29 0.26 0.21 1.93 < 0.005 < 0.005 0.43 0.44 < 0.005 0.11 0.11 — 445 445 0.02 0.02 0.67 451

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — 282 282 0.02 < 0.005 — 283
Parking
Lot
— — — — — — — — — — — — 7.20 7.20 < 0.005 < 0.005 — 7.23 Total — — — — — — — — — — — — 289 289 0.02 < 0.005 — 290 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — 282 282 0.02 < 0.005 — 283
Parking
Lot
— — — — — — — — — — — — 7.20 7.20 < 0.005 < 0.005 — 7.23 Total — — — — — — — — — — — — 289 289 0.02 < 0.005 — 290 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — 46.7 46.7 < 0.005 < 0.005 — 46.8 10939 Summit Avenue Detailed Report, 10/25/2023
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Parking — — — — — — — — — — — — 1.19 1.19 < 0.005 < 0.005 — 1.20 Lot
Total — — — — — — — — — — — — 47.9 47.9 < 0.005 < 0.005 — 48.0

4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — 282 282 0.02 < 0.005 — 283
Parking
Lot
— — — — — — — — — — — — 7.20 7.20 < 0.005 < 0.005 — 7.23 Total — — — — — — — — — — — — 289 289 0.02 < 0.005 — 290 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — 282 282 0.02 < 0.005 — 283
Parking
Lot
— — — — — — — — — — — — 7.20 7.20 < 0.005 < 0.005 — 7.23 Total — — — — — — — — — — — — 289 289 0.02 < 0.005 — 290 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — 46.7 46.7 < 0.005 < 0.005 — 46.8 Parking
Lot
— — — — — — — — — — — — 1.19 1.19 < 0.005 < 0.005 — 1.20 Total — — — — — — — — — — — — 47.9 47.9 < 0.005 < 0.005 — 48.0 10939 Summit Avenue Detailed Report, 10/25/2023
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4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
< 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 36.0 36.0 < 0.005 < 0.005 — 36.1 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 36.0 36.0 < 0.005 < 0.005 — 36.1

4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 10939 Summit Avenue Detailed Report, 10/25/2023
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Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise

0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 217 217 0.02 < 0.005 — 218 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
< 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 36.0 36.0 < 0.005 < 0.005 — 36.1 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 36.0 36.0 < 0.005 < 0.005 — 36.1

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e 10939 Summit Avenue Detailed Report, 10/25/2023
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Products
— 1.13 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
— 0.09 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.27 0.25 0.03 2.84 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.58 7.58 < 0.005 < 0.005 — 7.61 Total 0.27 1.48 0.03 2.84 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 7.58 7.58 < 0.005 < 0.005 — 7.61 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Products
— 1.13 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
— 0.09 — — — — — — — — — — — — — — — —
Total 0.00 1.23 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Products
— 0.21 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
— 0.02 — — — — — — — — — — — — — — — —
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Landsca 0.02 0.02 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.62 0.62 < 0.005 < 0.005 — 0.62 pe
Total 0.02 0.25 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.62 0.62 < 0.005 < 0.005 — 0.62

4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Products
— 1.13 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
— 0.09 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.27 0.25 0.03 2.84 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.58 7.58 < 0.005 < 0.005 — 7.61 Total 0.27 1.48 0.03 2.84 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 7.58 7.58 < 0.005 < 0.005 — 7.61 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Products
— 1.13 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
— 0.09 — — — — — — — — — — — — — — — —
Total 0.00 1.23 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 10939 Summit Avenue Detailed Report, 10/25/2023
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Annual — — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Products
— 0.21 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
— 0.02 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.02 0.02 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.62 0.62 < 0.005 < 0.005 — 0.62 Total 0.02 0.25 < 0.005 0.26 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 0.62 0.62 < 0.005 < 0.005 — 0.62

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1
Parking
Lot
— — — — — — — — — — — 0.00 0.01 0.01 < 0.005 < 0.005 — 0.01 Total — — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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Apartme — — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1 nts
Parking
Lot
— — — — — — — — — — — 0.00 0.01 0.01 < 0.005 < 0.005 — 0.01 Total — — — — — — — — — — — 3.37 19.6 23.0 0.35 0.01 — 34.1 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 0.56 3.25 3.80 0.06 < 0.005 — 5.65 Parking
Lot
— — — — — — — — — — — 0.00 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total — — — — — — — — — — — 0.56 3.25 3.81 0.06 < 0.005 — 5.65

4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3
Parking
Lot
— — — — — — — — — — — 0.00 0.01 0.01 < 0.005 < 0.005 — 0.01 Total — — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3
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Parking — — — — — — — — — — — 0.00 0.01 0.01 < 0.005 < 0.005 — 0.01 Lot
Total — — — — — — — — — — — 2.69 15.7 18.4 0.28 0.01 — 27.3 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 0.45 2.60 3.04 0.05 < 0.005 — 4.52 Parking
Lot
— — — — — — — — — — — 0.00 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total — — — — — — — — — — — 0.45 2.60 3.04 0.05 < 0.005 — 4.52

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5
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Parking — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Lot
Total — — — — — — — — — — — 19.9 0.00 19.9 1.98 0.00 — 69.5 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 3.29 0.00 3.29 0.33 0.00 — 11.5
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 3.29 0.00 3.29 0.33 0.00 — 11.5

4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 4.96 0.00 4.96 0.50 0.00 — 17.4 10939 Summit Avenue Detailed Report, 10/25/2023
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Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — 0.82 0.00 0.82 0.08 0.00 — 2.88
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.82 0.00 0.82 0.08 0.00 — 2.88

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — — — — — 0.38 0.38
Total — — — — — — — — — — — — — — — — 0.38 0.38
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — — — — — 0.38 0.38
Total — — — — — — — — — — — — — — — — 0.38 0.38
Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — — — — — 0.06 0.06
Total — — — — — — — — — — — — — — — — 0.06 0.06
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4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — — — — — 0.38 0.38
Total — — — — — — — — — — — — — — — — 0.38 0.38
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — — — — — 0.38 0.38
Total — — — — — — — — — — — — — — — — 0.38 0.38
Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Low Rise
— — — — — — — — — — — — — — — — 0.06 0.06
Total — — — — — — — — — — — — — — — — 0.06 0.06

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e 10939 Summit Avenue Detailed Report, 10/25/2023
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Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 10939 Summit Avenue Detailed Report, 10/25/2023
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Equipme
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type
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4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
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4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
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4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
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Sequest — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
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Remove — — — — — — — — — — — — — — — — — —
d
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 10/28/2024 11/25/2024 5.00 20.0 — Site Preparation Site Preparation 11/26/2024 12/3/2024 5.00 5.00 — Grading Grading 12/4/2024 5/5/2025 5.00 109 —
Building Construction Building Construction 5/6/2025 3/23/2026 5.00 230 — Paving Paving 3/24/2026 4/6/2026 5.00 10.0 —
Architectural Coating Architectural Coating 1/23/2026 3/23/2026 5.00 42.0 —

5.2. Off-Road Equipment
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5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Backh
oes
Diesel Average 3.00 8.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Cement and Mortar
Mixers
Diesel Average 2.00 6.00 10.0 0.56
Paving Pavers Diesel Average 1.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Paving Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 10939 Summit Avenue Detailed Report, 10/25/2023
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5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Backh
oes
Diesel Average 3.00 8.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Cement and Mortar
Mixers
Diesel Average 2.00 6.00 10.0 0.56
Paving Pavers Diesel Average 1.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Paving Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 10939 Summit Avenue Detailed Report, 10/25/2023
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5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 15.0 12.0 LDA,LDT1,LDT2
Demolition Vendor — 7.63 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 12.0 LDA,LDT1,LDT2
Site Preparation Vendor — 7.63 HHDT,MHDT
Site Preparation Hauling 219 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 12.0 LDA,LDT1,LDT2
Grading Vendor — 7.63 HHDT,MHDT
Grading Hauling 10.0 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 36.0 12.0 LDA,LDT1,LDT2
Building Construction Vendor 5.34 7.63 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 20.0 12.0 LDA,LDT1,LDT2
Paving Vendor — 7.63 HHDT,MHDT
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Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 7.20 12.0 LDA,LDT1,LDT2
Architectural Coating Vendor — 7.63 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 15.0 12.0 LDA,LDT1,LDT2
Demolition Vendor — 7.63 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 12.0 LDA,LDT1,LDT2
Site Preparation Vendor — 7.63 HHDT,MHDT
Site Preparation Hauling 219 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 12.0 LDA,LDT1,LDT2
Grading Vendor — 7.63 HHDT,MHDT
Grading Hauling 10.0 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 36.0 12.0 LDA,LDT1,LDT2
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Building Construction Vendor 5.34 7.63 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 20.0 12.0 LDA,LDT1,LDT2
Paving Vendor — 7.63 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 7.20 12.0 LDA,LDT1,LDT2
Architectural Coating Vendor — 7.63 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 107,325 35,775 0.00 0.00 306

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic Yards) Material Exported (Cubic Yards) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) 10939 Summit Avenue Detailed Report, 10/25/2023
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Demolition 0.00 0.00 0.00 — —
Site Preparation — 8,750 7.50 0.00 —
Grading — 8,750 109 0.00 —
Paving 0.00 0.00 0.00 0.00 0.12

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Low Rise — 0%
Parking Lot 0.12 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2024 0.00 589 0.03 < 0.005
2025 0.00 589 0.03 < 0.005
2026 0.00 589 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year 10939 Summit Avenue Detailed Report, 10/25/2023
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Apartments Low 366 407 314 133,016 3,395 3,775 2,913 1,233,854 Rise
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Apartments Low
Rise
366 407 314 133,016 3,395 3,775 2,913 1,233,854
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Low Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.1.2. Mitigated
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Hearth Type Unmitigated (number)
Apartments Low Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft)
Non-Residential Exterior Area Coated
(sq ft)
Parking Area Coated (sq ft)
107325 35,775 0.00 0.00 306

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180

5.10.4. Landscape Equipment - Mitigated
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180
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5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Low Rise 174,662 589 0.0330 0.0040 678,271
Parking Lot 4,465 589 0.0330 0.0040 0.00

5.11.2. Mitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Low Rise 174,662 589 0.0330 0.0040 678,271
Parking Lot 4,465 589 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Low Rise 1,756,654 36,530
Parking Lot 0.00 1,494

5.12.2. Mitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Low Rise 1,405,323 29,224
Parking Lot 0.00 1,196
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5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Low Rise 36.8 —
Parking Lot 0.00 —

5.13.2. Mitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Low Rise 9.21 —
Parking Lot 0.00 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Low Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Apartments Low Rise Household refrigerators
and/or freezers
R-134a 1,430 0.12 0.60 0.00 1.00

5.14.2. Mitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Low Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
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Apartments Low Rise Household refrigerators R-134a 1,430 0.12 0.60 0.00 1.00 and/or freezers

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.15.2. Mitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
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Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100. 10939 Summit Avenue Detailed Report, 10/25/2023
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Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 18.7 annual days of extreme heat Extreme Precipitation 4.80 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 30.4 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events.

Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding 0 0 0 N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures. 10939 Summit Avenue Detailed Report, 10/25/2023
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6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding 1 1 1 2
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 65.7
AQ-PM 41.2
AQ-DPM 11.4
Drinking Water 10.9
Lead Risk Housing 19.9
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Pesticides 0.00
Toxic Releases 24.0
Traffic 15.8
Effect Indicators —
CleanUp Sites 2.59
Groundwater 0.00
Haz Waste Facilities/Generators 3.64
Impaired Water Bodies 0.00
Solid Waste 0.00
Sensitive Population —
Asthma 35.6
Cardio-vascular 30.2
Low Birth Weights 36.7
Socioeconomic Factor Indicators —
Education 20.9
Housing 14.7
Linguistic 33.3
Poverty 20.1
Unemployment 17.1

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 77.23598101
Employed 52.68831002
Median HI 74.72090337
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Education —
Bachelor's or higher 44.59129988
High school enrollment 100
Preschool enrollment 75.7602977
Transportation —
Auto Access 88.68215065
Active commuting 2.194276915
Social —
2-parent households 23.81624535
Voting 90.17066598
Neighborhood —
Alcohol availability 97.0101373
Park access 46.54176825
Retail density 9.662517644
Supermarket access 20.89054279
Tree canopy 9.303220839
Housing —
Homeownership 77.53111767
Housing habitability 89.43924034
Low-inc homeowner severe housing cost burden 48.33825228 Low-inc renter severe housing cost burden 84.83254202
Uncrowded housing 96.93314513
Health Outcomes —
Insured adults 79.94353907
Arthritis 0.0
Asthma ER Admissions 64.2
High Blood Pressure 0.0
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Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 27.9
Cognitively Disabled 54.2
Physically Disabled 49.3
Heart Attack ER Admissions 57.0
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 19.6
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors—
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures—
Wildfire Risk 40.5
SLR Inundation Area 0.0
Children 69.7
Elderly 66.3
English Speaking 85.1
Foreign-born 4.9
Outdoor Workers 52.4
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Climate Change Adaptive Capacity —
Impervious Surface Cover 37.5
Traffic Density 0.0
Traffic Access 23.0
Other Indices —
Hardship 27.4
Other Decision Support —
2016 Voting 85.4

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 4.00 Healthy Places Index Score for Project Location (b) 71.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
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Screen Justification
Construction: Construction Phases Schedule adjusted to reflect soil export and architectural coating overlap with building construction.

Operations: Hearths No fireplaces or hearths
600 B Street, Suite 2000, San Diego, CA 92101  p: 619.236.1778  f: 866.785.0180  WeAreHarris.com November 8, 2023
Matthew Esquivel, Senior Project Manager
Warmington Residential
3090 Pullman Street
Costa Mesa, California 92626
Subject: Biological Resources Letter Report for the Warmington Santee Residential Project Dear Mr. Esquivel:

The purpose of this document is to identify the presence of existing vegetation and wildlife species to identify potential biological constraints, including any potential impacts to aquatic resources, and to assist in early planning of the proposed Warmington Santee Residential Project (project), The project lies in the City of Santee, California (Attachment 1, Figures; Figure 1, Regional Location, and Figure 2, Project Site). This letter report documents the results of a database review and biological field reconnaissance survey for the project. Harris & Associates (Harris) conducted a biological resources field reconnaissance survey of the approximately 4.93-acre project site and a 100-foot buffer (approximately 9.69 acres in total) (survey area). In addition to the results from the field survey conducted, a review of biological databases is provided in this analysis to aid in the constraints evaluation of the project to its current immediate and surrounding environment.

Project Description and Location
The project proposes new residential development within a partially developed parcel in a rural–suburban area in the City of Santee (City), California (Figure 1). The development will consist of a 50-unit multi-family development within 10 buildings. The project will include the removal of an existing single-family residential home, auxiliary structures, and trees and consist of moderate grading operations, retaining wall installation, wet/dry utilities, street work, landscaping, and flatwork. Additionally, the project will involve the creation of an underground detention system and installation of an outlet, curb, gutter, and sidewalk along Summit Avenue. The project has been designed to avoid impacts to sensitive resources within the survey area, including sensitive vegetation communities and potential jurisdictional aquatic resources.

The project site is located at 10939 Summit Avenue (Assessor’s Parcel Number 378-190-01-000) in the City (Figure 2). It is immediately north of the intersection of Summit Avenue and Noble Way in the northern part of the City, northwest of the intersection between State Route (SR) 52 and SR-67. To the north, east and west is mostly undeveloped land with rolling hills of high-quality native habitats. Small groups of residential houses are present to the east and north, and the Calvary Chapel of Santee is located to the west. Dense semi-rural residential developments occur south of the project site. The majority of the 4.93-acre lot is currently undeveloped but is generally disturbed by mowing and other human activity related to the few residential structures on the property.

Environmental Setting
The following sections serve to describe the existing conditions in the survey area.

Land Use
The survey area is in a rural–suburban area in the City. The 4.93-acre project site occurs in a partially developed parcel that has one single-family residential home along with sheds and other auxiliary structures that are generally surrounded by disturbed habitat and landscaped with ornamental vegetation. Development in the general area appears to have begun in the early 1970s and has not expanded much to the north but has greatly expanded in the south (Historic Aerials 2023). Small patches of native habitat occur in the north and northeastern 2 portions of the survey area, and large uninterrupted areas of high-quality native habitat occur further outside the survey area to the north, east, and west including the Sycamore Canyon/Goodan Ranch County Preserve and Sycamore Canyon Open Space Preserve approximately 2.5 miles to the north, Santee Lakes Recreation Preserve approximately 1.4 miles to the west, and an area of existing fully conserved conservation land that occurs to the northeast of the survey area (City of Santee 2023). A heavily developed area with semi-rural residential structures exists south of the survey area. The San Diego River also occurs approximately 1.4 miles south of the survey area.

Topography and Soils
The survey area is relatively flat, but a slight rise in elevation occurs in the northeastern portion of the survey area as a rocky slope develops further northeast and outside the survey area. The on-site elevation ranges from approximately 520 to 560 feet above mean sea level. The topographic lines presented on Figure 3, USGS Topographic Map, represent the survey area elevations. The survey area is depicted on the U.S. Geological Survey (USGS) 7.5-minute San Vicente Reservoir quadrangle (Figure 3).

The survey area is underlain by three soil types: Cieneba–Fallbrook rocky sandy loams (9 to 30 percent slopes, eroded), Greenfield sandy loam (9 to 15 percent slopes), and Ramona sandy loam (2 to 5 percent slopes). The soil types on the project site are presented on Figure 4, Soils. Cieneba–Fallbrook rocky sandy loams (9 to 30 percent slopes, eroded) occurs in the central and eastern portions of the survey area. Greenfield sandy loam (9 to 15 percent slopes) occurs in the western portion of the survey area. Ramona sandy loam (2 to 5 percent slopes) occurs in the southern portion of the survey area (USDA 2019).

Hydrology
The survey area is located in the San Diego River Watershed, specifically within the Lower San Diego Hydrological Area (Hydrologic unit 907.1). The Peñasquitos Watershed and San Diego Bay Watershed border the survey area to the north and south, respectively. The San Diego River Watershed is the second largest in San Diego County (County), encompassing approximately 434 square miles.

The major tributaries to the San Diego River include Boulder Creek, joining the San Diego River in the headwaters above El Capitan Reservoir and San Vicente Creek, joining the river in Lakeside. There are numerous smaller tributaries as well, including Cedar Creek in the headwaters of the San Diego River, Forester Creek and Sycamore Creek in Santee, Oak Creek in Mission Trails Regional Park, as well as Alvarado Creek, Murphy Creek, and Murray Creek in Mission Valley (Project Clean Water 2023).

The U.S Fish and Wildlife Service (USFWS) National Wetlands Inventory mapping and field results show an unnamed riverine channel and tributary to the San Diego River, which occurs approximately 1.9 miles south of the survey area, as the only aquatic resource in the survey area (Figure 5, Hydrology). The aquatic resource travels through the northwestern corner of the survey area. National Wetlands Inventory mapping results also show one unnamed riverine aquatic feature that flows into this feature approximately 0.16 mile south of, and outside the survey area and several other tributaries to the San Diego River to the north, east, west, and southwest, also outside the survey area (USFWS 2023a).

Based on a review of the USGS National Hydrography Dataset, the unnamed riverine feature that traverses the northwestern corner of the survey area is the only identified aquatic feature within the survey area, but several features with connectivity to this feature occur to the north and east outside the survey area (USGS 2023). This feature has hydrologic connections to the San Diego River, which is defined by the U.S. Army Corps of Engineers (USACE) as a traditional navigable water (TNW) (USACE 2023; USGS 2023) (Figure 5).

A formal aquatic resources delineation was not conducted during the survey effort. However, three aquatic resources (Aquatic Feature [AF]-1, AF-2, and AF-3), all non-vegetated channels that are interconnected, were observed in the northwestern portion of the survey area during the biological reconnaissance survey. Drainage patterns on the project site show evidence of minor alteration, with on-site mechanical disturbances associated with the residential developments, including installation of a chain-link fence across the drainage and culvert installation on the east and west sides of Summit Avenue and across a driveway in the northernmost portion of the survey area. 3 Climate
On a regional level, the County has a Mediterranean climate, which is characterized by wet winters and dry summers. This is largely because of a semi-permanent high-pressure zone that sits over the Pacific Ocean during much of the year and forms a fog belt (marine layer). The survey area is generally within the Peninsular Ranges of Southern California. Generalized climate in the region is regarded as dry, subhumid mesothermal, with warm dry summers and cold moist winters, which pushes the growing season to the wet months of the year (late winter to early spring). Vegetation often goes dormant (senescent) during the later summer months until initial rains start in the fall. The rainy season typically lasts from October through March.

The closest weather station to the project site is approximately 2.5 miles northeast of the project site (NRCS 2023).

Between 2003 and 2023, the average maximum temperature was 77 degrees Fahrenheit (°F), and the minimum temperature was 53°F. The average annual precipitation between 2003 and 2023 was approximately 13.66 inches.

In 2022, the total rainfall was 11 inches, approximately 1 inch more than the previous year (NRCS 2023). As of September 2023, when the biological reconnaissance survey was conducted, the total annual precipitation in the area was 19 inches, approximately 8 inches greater than the total annual precipitation in September 2022.

Regulatory Setting
Federal
Clean Water Act
Section 401 (40 CFR 121). Section 401 of the Clean Water Act (CWA) gives the state authority to grant, deny, or waive certification of proposed federally licensed or permitted activities resulting in discharge to waters of the United States. The State Water Resources Control Board directly regulates multi-regional projects and supports the Section 401 certification and wetlands program statewide. The California Regional Water Quality Control Board (RWQCB) regulates activities pursuant to Section 401(a)(1) of the federal CWA, which specifies that certification from the state is required for any applicant requesting a federal license or permit to conduct any activity including but not limited to the construction or operation of facilities that may result in any discharge into navigable waters. The certification shall originate from the state or appropriate interstate water pollution control agency in/where the discharge originates or will originate. Any such discharge will comply with the applicable provisions of Sections 301, 302, 303, 306, and 307 of the CWA.

Section 404 (33 CFR 328.3[a]). These provisions regulate the discharge of dredged or fill material in waters of the United States, including wetlands. Activities that discharge dredge or fill material into waters of the United States can be authorized by the USACE.

The USACE and the U.S. Environmental Protection Agency (USEPA) have issued a set of guidance documents detailing the process for determining CWA jurisdiction over waters of the United States following the 2008 Rapanos decision. The USEPA and USACE issued a summary memorandum of the guidance for implementing the Supreme Court’s decision in Rapanos that addresses the jurisdiction over waters of the United States under the CWA. The complete set of guidance documents, summarized as key points below, were used to collect relevant data for evaluation by the USEPA and USACE to determine CWA jurisdiction over the project site and to complete the “significant nexus test” as detailed in the guidelines.

The significant nexus test includes consideration of hydrologic and ecologic factors. For circumstances such as those described in Key Point B below, the significant nexus test would take into account physical indicators of flow (evidence of an ordinary high water mark) if a hydrologic connection to a TNW exists and if the aquatic functions of the water body have a significant effect (more than speculative or insubstantial) on the chemical, physical, and biological integrity of a TNW. The USACE and USEPA will apply the significant nexus standard to assess the flow characteristics and functions of the tributary drainage to determine if it significantly affects the chemical, physical, and biological integrity of the downstream TNW.
4 Wetlands (including swamps, bogs, seasonal wetlands, seeps, marshes, and similar areas) are also considered waters of the United States and are defined by USACE as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions” (33 CFR 328.3[b]; 40 CFR 230.3[t]). Indicators of three wetland parameters (i.e., hydric soils, hydrophytic vegetation, and wetlands hydrology), as determined by field investigation, must be present for a site to be classified as a wetland by the USACE (USACE 1987).

Rapanos Guidance Key Points Summary
A. The USACE and USEPA will assert jurisdiction over the following waters:
• TNWs
• Wetlands adjacent to TNWs
• Non-navigable tributaries of TNWs that are relatively permanent (flows 3 months or longer) − Wetlands that abut such tributaries
B. The USACE and USEPA will decide jurisdiction over the following waters based on whether they have a significant nexus with a TNW:
• Non-navigable tributaries that are not relatively permanent • Wetlands adjacent to non-navigable tributaries that are not relatively permanent • Wetlands adjacent to but that do not directly abut a relatively permanent non-navigable tributary C. The USACE and USEPA will not assert jurisdiction over the following waters:
• Swales or erosional features (gullies, small washes characterized by low volume, infrequent, or shortduration flow) a) Ditches (including roadside ditches) excavated wholly in and draining only uplands and that do not carry a relatively permanent flow of water
The Navigable Waters Protection Rule, published by the USACE and USEPA on April 21, 2020, was vacated during a federal court ruling in Arizona (Pascua Yaqui Tribe v. USEPA) on August 30, 2021. With this ruling, the regulatory agencies have halted implementation of the Navigable Waters Protection Rule and are interpreting “waters of the United States” consistent with the pre-2015 regulatory regime (Rapanos Guidance).

Endangered Species Act (U.S. Code, Title 16, Sections 1531 through 1543) The federal Endangered Species Act (FESA) and subsequent amendments prohibit the “take” (i.e., harm, harass, or kill individuals or destroy associated habitat) of species federally listed as threatened or endangered.

Take incidental to otherwise lawful activities can be authorized by the USFWS through a permit under Sections 4(d), 7, or 10(a).

Migratory Bird Treaty Act (U.S. Code, Title 16, Sections 703 through 711) The Migratory Bird Treaty Act (MBTA) is the domestic law that affirms or implements a commitment by the United States to four international conventions (Canada, Mexico, Japan, and Russia) for the protection of a shared migratory bird resource. The MBTA makes it unlawful at any time, by any means, or in any manner to pursue, hunt, take, capture, or kill migratory birds. The law also applies to the removal of nests occupied by migratory birds during the breeding season. The MBTA makes it unlawful to take, pursue, molest, or disturb these species, their nests, or their eggs anywhere in the United States.

State
Birds of Prey Protection Provision (CFGC, Section 3503.5) This provision prohibits the taking of birds of prey (Order Falconiformes and Strigiformes), including their nests and eggs.
5 California Endangered Species Act (CFGC, Section 2050 et seq.) The California Endangered Species Act prohibits any activities that would jeopardize or take a species designated as threatened or endangered by the state.

California Environmental Quality Act, as Amended (California Public Resources Code, Section 21000 et seq.) The goal of the California Environmental Quality Act (CEQA) is to assist California public agencies in identifying potentially significant negative environmental impacts caused by their actions and avoiding or mitigating those impacts when feasible.

California Fish and Game Code, Section 3503
California Fish and Game Code (CFGC), Section 3503, prohibits the take, possession, or needless destruction of the nests or eggs of any birds except as otherwise provided by the CFGC or any regulation made pursuant thereto.

California Fully Protected Wildlife Species Provision (CFGC, Sections 3511, 4700, 5050, and 5515) These provisions prohibit the take of fully protected birds, mammals, amphibians, and fish.

California Native Plant Protection Act of 1977 (CFGC, Sections 1900–1913) These provisions preserve, protect, and enhance endangered or rare native plants of the state.

Lake and Streambed Alteration Agreement (CFGC, Section 1600) CFGC Section 1602 regulates water resources in California. Activities that divert or obstruct the natural flow of or change or use material from the bed, channel, or bank of any river, stream, or lake may be authorized by the California Department of Fish and Wildlife (CDFW). CDFW jurisdiction includes intermittent and perennial watercourses and extends to the top of the bank of a stream or lake if unvegetated or to the limit of the adjacent riparian vegetation located contiguous to the watercourse if the stream or lake is vegetated.

Natural Community Conservation Planning Act, as Amended (CFGC, Sections 2800–2835) The primary objective of the Natural Community Conservation Planning program is to conserve natural communities at the ecosystem level while accommodating compatible land use. The program seeks to anticipate and prevent the controversies and gridlock caused by species’ listing by focusing on the long-term suitability of wildlife and plant communities and including key interests in the process.

Porter–Cologne Water Quality Control Act
The Porter–Cologne Water Quality Control Act (Porter–Cologne Act) is regulated by the RWQCB for impacts on waters of the state. The RWQCB is the regional agency responsible for protecting water quality in California. The jurisdiction of this agency includes all waters of the state and all waters of the United States as mandated by the CWA Section 401 and the Porter–Cologne Act. Although water quality issues related to impacts on waterways are normally addressed in Section 401 Water Quality Certification, should a water of the state be determined by the USACE not to have CWA jurisdiction, the Porter–Cologne Act would be addressed under a Construction General Permit, State General Waste Discharge Order, or Waste Discharge Requirements depending on the level of impact and the properties of the waterway.

Regional Water Quality Control Board
The RWQCB regulates impacts on water quality under Section 401 of the CWA. A project must comply with Section 401 of the CWA before the USACE can issue a Section 404 Permit. The RWQCB will issue a Section 401 Water Quality Certification or Waiver of Certification depending on the extent of impacts on waters of the United States.

The RWQCB also regulates impact on waters of the state (usually limited to “isolated” waters or swales that may not fall under USACE jurisdiction) under the Porter–Cologne Act. 6 Local
City of Santee Multiple Species Conservation Program Subarea Plan The project is located within the boundaries of the Final Multiple Species Conservation Program (MSCP) Plan (County of San Diego 1998). The MSCP Plan is a long-term, regional habitat conservation program focused on balancing two unique aspects of the County: high biological diversity and rapid urban growth. Under this program, large blocks of inter-connected habitat will be conserved through the acquisition of land by private and public entities and mitigation from development. The County’s MSCP is composed of three separate planning areas covering unincorporated regions of San Diego in the South County, North County, and East County. The MSCP Plans associated with the planning areas are the County Subarea Plan (South County Plan), Draft North County Plan, and East County Plan. Each MSCP Plan Area’s unique geography requires that each MSCP Plan be tailored to meet the needs of the unique habitats and species in its area.

Local jurisdictions and special districts implement the MSCP Plan for their respective portions through Subarea Plans. The combination of the MSCP Plan and Subarea Plans serve as a Habitat Conservation Plan (HCP) pursuant to Section 10(a)(1)(B) of the FESA and as a Natural Community Conservation Planning Program pursuant to the California Natural Community Conservation Planning Act of 1991.

The City of Santee has prepared a draft Subarea Plan to address the implementation of the MSCP Subregional Plan within the jurisdictional boundary of Santee, which is located east of the City of San Diego and north of El Cajon.

As of 2023, five jurisdictions included in the MSCP Subregional Plan have prepared and implemented MSCP Subarea Plans, including the County of San Diego and cities of San Diego, Chula Vista, La Mesa, and Poway.

The draft Santee Subarea Plan has been prepared pursuant to the requirements of the MSCP Subregional Plan, the State Natural Community Conservation Planning Act, and section 10(a)(1)(B) of FESA. On March 23, 2023, the City prepared a Notice of Preparation of a draft Environmental Impact Report for the Subarea Plan (City of Santee 2023).

Santee General Plan
The General Plan serves as a long-term policy guide for physical, economic, and environmental growth. It is a statement of the community's vision for ultimate growth. State law requires that every city prepare and adopt a comprehensive long-range plan to serve as a guide for the development of the community. City actions, such as those relating to land use allocations, annexations, zoning, subdivision and design review, redevelopment, and capital improvements must be consistent with the General Plan. The General Plan designates land use categories for the entire city. Each land use category is identified and defined within the General Plan and includes information on the general uses, development, intensity, siting, and compatibility uses (City of Santee 2002). The Conservation Element of the Santee General Plan provides the following objectives and policies that apply to biological resources:

Conservation Element Objective 7.0: Preserve significant biological resources. • Policy 7.1: The City shall encourage the preservation and enhancement of significant biological resources in areas designated as permanent open space.
• Policy 7.2: The City shall require that all development proposals provide appropriate mitigation for identified significant biological resources including selective preservation, sensitive site planning techniques, and in-kind mitigation for identified impacts.
• Policy 7.3: The City shall require that, for all development proposals involving the setting aside of land for permanent open space either on site or off site, provisions are in place to ensure the long-term management of the open space and biological resources.
• Policy 7.4: The City shall complete a Multiple Species Conservation Program Subarea plan that conserves a minimum of 2,600 acres in the City as permanent open space for preservation of habitats and species. 7 Methods
The methods of this biological resources analysis include a database review and biological resources field reconnaissance survey to document the existing biological conditions in the survey area. The results of this review provide information on the potential constraints to project development due to the presence (or lack thereof) of sensitive biological resources.

Database Review
Review of online databases including the CDFW California Natural Diversity Database (CDFW 2023a), CDFW Biogeographic Information and Observation System (BIOS) (CDFW 2023b), USFWS Information for Planning and Consultation (USFWS 2023b), USFWS National Wetlands Inventory Wetlands Mapper (USFWS 2023a), Consortium of California Herbaria database (CCH 2023), Calflora database (Calflora 2023), and California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants of California (CNPS 2023) was conducted for the project site and within a 1-mile radius of the project site.

Field Reconnaissance Survey
On September 6, 2023, Harris conducted a biological resources field reconnaissance survey. For the purposes of complete analysis of potential project impacts, a 100-foot buffer was applied around the project site boundary, which, together with the project site, is referred to as the “survey area.” The survey was conducted by walking meandering transects throughout the survey area and mapping vegetation communities, documenting plant and wildlife species, noting suitable habitat, and evaluating the potential for occurrence of sensitive, rare, threatened, and endangered plant and wildlife species (Attachment 2, Plant and Wildlife Species Observed). Vegetation mapping was recorded in the field using the ArcGIS Collector application with an aerial image of the survey area.

Binoculars were used to visually identify wildlife species; and vocalizations were listened to. The results of the vegetation mapping are presented in Table 1, Vegetation Communities and Land Cover Types, in the Results section. The potential for sensitive plant and wildlife species to occur in the survey area is presented in Table 2, Sensitive Plant and Wildlife Species with Potential to Occur, in the Results section.

The results of this analysis provide information on the potential constraints to project development due to the presence of special-status biological resources. No additional focused wildlife or plant surveys were conducted as part of this analysis.

Survey Limitations
Plants and wildlife were identified by direct observation, vocalizations, or other observance, including tracks, scat, and other sign. Therefore, lists of species observed are not necessarily comprehensive, as species can be nocturnal, secretive, or within the region and survey area seasonally (migration) and, therefore, may not have been observed.

Results
The results presented below provide data from the surveys conducted in the survey area.

Vegetation Communities and Land Cover Types
The survey area is within the southwestern California region of the California Floristic Province (Jepson Online 2023).

Five vegetation communities and land use types were observed in the survey area. These include Diegan coastal sage scrub (including disturbed), developed land, disturbed habitat, non-vegetated channel, and non-native woodland (Baldwin et al. 2012; Oberbauer et al. 2008; Holland 1986). Table 1 presents the acreages of the vegetation communities that occur on the project site and in the survey area. Figure 6, Vegetation Communities and Land Cover Types, presents the vegetation community boundaries.
8 Table 1. Vegetation Communities and Land Cover Types
Vegetation Community and
Land Cover Type Survey Area (acres)1 Project Site (acres)1 Aquatic
Non-vegetated channel (64200) 2 0.03 0.01
Subtotal 0.03 0.01
Upland
Diegan coastal sage scrub (including
disturbed) (32500) 2 0.64 0.04
Non-native woodland (79000) 0.22 0.06
Subtotal 0.86 0.10
Disturbed/Developed
Disturbed habitat (11300) 5.82 4.21
Urban/developed land (12000) 2.98 0.61
Subtotal 8.80 4.82
Total 9.69 4.93
Sources: Holland 1986; Oberbauer et al. 2008.

Notes:
1Acreages rounded up to one-hundredth. 2Considered a sensitive vegetation community.

The vegetation communities observed on the project site are described in the following subsections.

Aquatic Vegetation Communities
Non-Vegetated Channel (64200)
Non-vegetated channel consists of predominantly sandy, gravelly, or rocky channels lacking or with reduced vegetation. Variable water lines inhibit the growth of vegetation, although some weedy species of grasses may grow along the outer edges of the channel. Vegetation may exist here but is usually less than 10 percent of the total cover (Oberbauer et al. 2008).

Approximately 0.03 acre of non-vegetated channel occurs within the survey area, with approximately 0.01 acre occurring on the project site. Non-vegetated channel occurs within three channels that traverse the northwestern portion of the survey area and are interconnected (Figure 6).

Upland Vegetation Communities
Diegan Coastal Sage Scrub (including Disturbed) (32500) Diegan coastal sage scrub is composed of a variety of soft, low, aromatic shrubs, characteristically dominated by drought-deciduous species, such as California sagebrush (Artemisia californica), California buckwheat (Eriogonum fasciculatum), and sage (Salvia spp.), with scattered evergreen shrubs, including lemonade berry (Rhus integrifolia) and laurel sumac (Malosma laurina) (Oberbauer et al. 2008). Diegan coastal sage scrub is present in coastal Southern California from Los Angeles, California, to Baja California, Mexico, and supports a rich diversity of sensitive plants and wildlife.

Approximately 0.64 acre of Diegan coastal sage scrub (including disturbed) habitat occurs within the survey area, with approximately 0.04 acres occurring on the project site (Figure 6). Diegan coastal sage scrub (including disturbed) occurs in the northeastern corner of the survey buffer as well as a small portion in the northern and eastern parts of the survey buffer. Dominant species include California sagebrush and laurel sumac in nondisturbed Diegan coastal sage (located in the northeastern corner of the survey area), and California sagebrush 9 and broom baccharis (Baccharis sarothroides) in disturbed Diegan coastal sage scrub (located in the northern and eastern portions of the survey area). Subdominant plant species include California buckwheat in non-disturbed Diegan coastal sage scrub, and black mustard (Brassica nigra) and California buckwheat in the disturbed Diegan coastal sage scrub.

Non-native Woodland (79000)
Non-native woodland consists of exotic trees, usually intentionally planted, which are not maintained or artificially irrigated. This classification typically does not apply where these trees have naturalized or are in riparian woodlands. Common species include eucalyptus species (Eucalyptus spp.) or tamarisk species (Tamarix spp.), but other non-native species may occur.

Approximately 0.22 acre of non-native woodland occurs within the survey area, with 0.06 acre occurring on the project site (Figure 6). Non-native woodland consists of a small grove of planted Peruvian pepper (Schinus molle) trees located on the eastern side of the survey area.

Disturbed/Developed Lands
Disturbed Habitat (11300)
Disturbed habitat consists of previously disturbed areas that either are devoid of vegetation (dirt roads/trails) or support scattered non-native plant species such as ornamentals or ruderal exotic species, such as black mustard, short-pod mustard (Hirschfeldia incana), and Erodium species, that take advantage of disturbance. They are nonnative species and are typically found in disturbed habitats, particularly in areas that have been graded, been repeatedly cleared for fuel management purposes, and/or have experienced repeated use that prevents natural revegetation (Oberbauer et al. 2008).

Approximately 5.82 acres of disturbed habitat occurs within the survey area, with 4.21 acres occurring on the project site (Figure 6). Disturbed habitat occurs on the majority of the project site and in the existing residential developmentssurrounding it in the survey area. Additionally, disturbed habitat occurs to the west of the survey area where a fire break is maintained adjacent to Summit Avenue and in the southeastern corner of the survey area.

Disturbed habitat in the survey area is dominated by bare ground, black mustard, and dove weed (Croton setigerus).

Urban/Developed Land (12000)
Urban/developed represents areas that have been constructed on or otherwise physically altered to an extent that native vegetation communities are not supported (Oberbauer et al. 2008). This land cover type generally consists of semi-permanent structures, homes, parking lots, pavement or hardscape, and landscaped areas that require maintenance and irrigation (e.g., ornamental greenbelts). Typically, this land cover type is unvegetated or supports a variety of ornamental plants and landscaping.

Urban/developed land in the survey area comprises approximately 2.98 acres, with approximately 0.61 acre occurring on the project site (Figure 6). Urban/developed areas consist of the residential structures on the project site and immediately north and south of it, paved roads, and the Calvary Chapel of Santee to the west (Figure 6).

Plant Species
Attachment 2 lists all vascular plant species observed in the survey area during the 2023 biological resource surveys.

A total of 38 plant species were observed in the survey area, 10 (26 percent) of which were native and 28 (74 percent) of which were non-native. Of the 38 plants observed in the survey area, none are considered sensitive.

Wildlife Species
Attachment 2 lists all wildlife species detected in the survey area during the 2023 biological resource surveys.

A total of 22 wildlife species were observed in the survey area, 22 (100 percent) of which were native. In total, two invertebrates, 17 birds, one reptile, and two mammals were observed in the survey area. Of the 22 wildlife species observed, none are considered sensitive.
10 Common bird species observed frequently in the survey area include Anna’s hummingbird (Calypte anna), California towhee (Melozone crissalis), song sparrow (Melospiza melodia), house finch (Haemorhous mexicanus), and mourning dove (Zenaida macroura).

Sensitive Species
Sensitive species are those recognized by federal, state, or local agencies as being potentially vulnerable to impacts because of rarity, local, or regional reductions in population numbers, isolation/restricted genetic flow, or other factors. Sensitive plants include species listed as threatened or endangered, proposed for listing, or candidates for listing under the FESA by the USFWS (USFWS 2023c) and the California Endangered Species Act by the CDFW (CDFW 2023c); those considered species of special concern by the CDFW (CDFW 2023d); and species included in the California Rare Plant Rank (CRPR) inventory maintained by the CNPS. Sensitive wildlife species include those listed as threatened or endangered, proposed for listing, or candidates for listing under the FESA by the USFWS (USFWS 2023c) and the California Endangered Species Act by the CDFW (CDFW 2023c); and those considered species of special concern by the CDFW (CDFW 2023d).

As described in the Methods section, distributions of historical sensitive species observations within a 1-mile radius of the survey area were reviewed in preparation of this letter report and are depicted on Figure 7, Species with Potential to Occur. Other database results are not included on Figure 7, because Geographic Information System information on specific points is not available. For this biological resources analysis, those species that either are known to occur or have some potential to occur within 1 mile of the survey area are addressed in this section. The list of sensitive plant and wildlife species observed or with a potential to occur in the survey area are provided in Table 2 with listing status, habitat requirements, and observation or potential for occurrence information. Two sensitive species were observed in the survey area during the 2023 survey. 11 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Plants
Acanthomintha
ilicifolia
San Diego
thornmint
FT/SE/1B.1/MSCP Occurs in vernal pools, coastal
sage scrub, chaparral, valley
grassland, and riparian habitats
between 12 and 3,260 feet amsl.

Blooms April–July.

Not Expected. No vernal pools exist
within the survey area, including within
the Diegan coastal sage scrub on site.

No historical locations exist within 1
mile of the survey area (CDFW 2023a;
USFWS 2023b; CNPS 2023).

Adolphia californica California adolphia None/None/2B.1/None Occurs in coastal scrub, chaparral, and valley and foothill grasslands
with clay soils at elevations
between 35 and 2,430 feet amsl.

Blooms December–May.

Not expected. No suitable clay soils are
present within Diegan coastal sage
scrub in the survey area. No historical
locations exist within 1 mile of the
survey area (CDFW 2023a; CNPS 2023).

Ambrosia pumila San Diego
ambrosia
FE/None/1B.1/MSCP Occurs in open, often disturbed,
habitats in coarse substrates in
grasslands, coastal scrub, river
terraces, pools, and alkali playas
in Southern California and Baja
California. Found below 600 feet
amsl. Blooms April–October.

Not Expected. The survey area was
previously graded and does not fall within
the known remaining population locations
of this species within San Diego County.

Therefore, this species is not expected to
occur. No historical locations exist within 1
mile of the survey area (CDFW 2023a;
USFWS 2023b; CNPS 2023).

Artemisia palmeri San Diego
sagewort
None/None/4.2/None Occurs in usually along or near
drainages and riparian areas
within chaparral, coastal scrub,
riparian forest, and woodland
habitats (mesic and sandy soils)
from 15 to 3,000 feet amsl.

Blooms (Feb) May–September.

Not expected. Disturbed Diegan coastal
sage scrub surrounds a small portion of
the AF-1 in the northwestern portion of
the survey area, but this species was not
observed during the survey. No historical
locations exist within 1 mile of the survey
area (CDFW 2023a; CNPS 2023).

Asplenium
vespertinum
Western
spleenwort
None/None/4.2/None Occurs in chaparral, cismontane
woodland, and coastal scrub
between 52 and 11,507 feet
amsl. Blooms February–June.

Low. Suitable habitat occurs in Diegan
coastal sage scrub in the northern,
eastern, and northeastern portions of
the survey area. The species was not
observed during 2023 survey. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a; CNPS
2023).
12 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Bloomeriaclevelandii
San Diegogoldenstar
None/None/1B.1/MSCP Occurs in chaparral, coastal sage
scrub, valley and foothill
grassland, and vernal pools at
elevations below 330 feet amsl.

Blooms April–May.

Not expected. Survey area is outside the
elevational range for this species.

Historical locations occur approximately

0.9 mile northeast of the survey area
(Figure 7) (CDFW 2023a; CNPS 2023).

Brodiaea orcuttii Orcutt’s brodiaea None/None/1B.1/MSCP Occurs in vernal pools, grassland, and scrub openings at elevations
under 5250 feet amsl. Blooms
April–July.

Not expected. No suitable vernal pools
or areas with clay soil occur within the
survey area. No historical locations exist
within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).

Brodiaea filifolia Thread‐leaved
brodiaea
FT/SE/1B.1/MSCP Occurs in chaparral, cismontane
woodland, coastal scrub, valley
and foothill grassland, and vernal
pools at elevations between 80
to 3,675 feet amsl. Blooms
March–June.

Low. Suitable habitat exists in the
Diegan coastal sage scrub in the
northeastern corner and in the
disturbed coastal sage scrub in the
northern and eastern portions of the
survey area. The species was not
observed during 2023 survey; however,
survey was conducted outside the
blooming period. No historical locations
exist within 1 mile of the survey area
(CDFW 2023a; USFWS 2023b;
CNPS 2023).

Camissoniopsislewisii Lewis' evening‐
primrose
None/None/3/None Occurs in clay or sandy soils
within cismontane woodland,coastal bluff scrub, coastaldunes, coastal scrub, and valley and foothill grassland between 0
and 9,047 feet amsl. Blooms
March–May.

Not expected. Suitable clay or sandy
soils do not occur in Diegan coastal sage
scrub in the northern, eastern, and
northeastern portions of the survey
area. The species was not observed
during 2023 survey; however, survey
was conducted outside the blooming
period. No historical locations exist
within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).
13 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Ceanothus cyaneus Lakeside ceanothus None/None/1B.2/None Occurs in chaparral, closed‐cone coniferous forest general in the
mountains in San Diego Countybetween 339 and 4,461 feet amsl. Blooms April–June.

Not expected. No suitable habitat
occurs within the survey area. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).

Chamaebatiaaustralis
Southern mountain
misery
None/None/4.2/None Occurs in chaparral (gabbroic,
metavolcanic), usually on dry
slopes between 211 and 6,521
feet amsl. Blooms November–
May.

Not expected. No suitable habitat or
soils occur within the survey area. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).

Chorizantheleptotheca
Peninsularspineflower
None/None/4.2/None Occurs in alluvial fans with
granitic soils within chaparral,
coastal scrub, and lower
montane coniferous forest
between 441 and 6,109 feet
amsl. Blooms May–August.

Not expected. No alluvial fans occur
within the coastal scrub in the survey
area. No historical locations exist within
1 mile of the survey area (CDFW 2023a;
CNPS 2023).

Clarkia delicata Delicate clarkia None/None/1B.2/
None
Occurs in chaparral and
woodland habitat between
approximately 218 and 5,901
feet in elevation. Blooms April–June.

Not expected. No suitable habitat
occurs within the survey area. Non‐
native woodland in the survey area is
unlikely to support this species as it is
landscaped. No historical locations exist
within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).

Clinopodiumchandleri
San Miguel savory None/None/1B.2/MSCP Occurs on rocky slopes within in chaparral, cismontane woodland,
coastalscrub, riparian woodland,
valley and foothill grassland
between 1,064 and 3,267 feet
amsl. Blooms March–July.

Not Expected. Survey area outside
elevational range of thisspecies. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).

Comarostaphylisdiversifolia ssp.diversifolia
Summer holly None/None/1B.2/
None
Occurs often on north facing
slopesin coastal and foothill
canyonsin heavy chaparral
between 24 and 3,521 feet amsl.

Blooms April–June.

Not expected. No suitable habitat occurs
within the survey area. No historical
locations exist within 1 mile of the survey
area (CDFW 2023a; CNPS 2023).
14 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Convolvulussimulans
Small‐floweredmorning‐glory
None/None/4.2/None Occurs in seeps within northern
coastal scrub, coastal sage scrub,
and valley grasslands
communities betweenapproximately 30 and 875 feet in
elevation. Blooms May–July.

Not expected. No suitable habitat
occurs within the survey area. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).

Dudleya variegata Variegated dudleya None/None/1B.2/MSCP Occurs on dry hillsides and mesas with clay soils within
vernal pools, chaparral, coastal
scrub, cismontane woodland,
and valley and foothill grassland
between 10 to and 5,924 feet
amsl. Blooms April–June.

Not expected. No hillsides or mesas
with clay soils are present in the Diegan
coastal scrub in the survey area.

Historical locations occur approximately

0.7 mile northeast of the survey area
but not within it (Figure 7)
(CDFW 2023a; CNPS 2023).

Ericameria palmeri
var. palmeri
Palmer'sgoldenbush
None/None/1B.1/MSCP Occurs in chaparral and coastal
scrub in mesic soils between 20
and 7,419 feet amsl. Blooms
September–November.

Not expected. Disturbed Diegan coastal
sage scrub surrounds a small portion of
the AF‐1 in the northwestern portion of
the survey area, but this species was
not observed during the survey. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).

Eryngiumaristulatum var.
parishii
San Diego button
celery
FE/SE/1B.1/MSCP Occurs in vernal pools or
marshes within wetlands, coastal
sage scrub, valley grassland, and
wetland riparian communities
that contain clay soils between
approximately 37 and 2,907 feet
in elevation. Blooms April–June.

Not expected. No suitable vernal pools
or areas with clay soil occur within the
survey area. No historical locations exist
within 1 mile of the survey area
(CDFW 2023a; USFWS 2023a; CNPS
2023).

Ferocactusviridescens
San Diego barrelcactus
None/None/2B.1/MSCP Occurs in rocky and sandy
chaparral, coastal scrub, and
valley and foothill grassland
habitats typically on hillslopes or
mesas between 10 and 1,500
feet amsl. Blooms May–June.

Low. Suitable habitat occurs in Diegan
coastal sage scrub in the northeastern
corner of the survey area where the soil
is sandy loam and begins to become
rocky just outside the survey area. The
species was not observed during 2023
survey. Numerous historical locations
15 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
occur north and west of the survey
area but not within it (Figure 7)
(CDFW 2023a; CNPS 2023).

Githopsis diffusa ssp.
filicaulis
Mission Canyon
bluecup
None/None/3.1/None Occurs in chaparral, generally
within moist or disturbed areas
with mesic soils between 721
and 2,625 feet amsl. Blooms
April–June.

Not expected. Survey area is outside
elevational range of this species. No
historical locations exist within 1 mile
of the survey area (CDFW 2023a;
CNPS 2023).

Harpagonellapalmeri
Palmer’sgrapplinghook
None/None/4.2/None Occurs in chaparral, coastal
scrub, and valley and foothill
grassland with clay soils at
elevations between 60 and 3,100
feet amsl. Blooms March–May.

Not expected. No coastal sage scrub
with clay soils occurs within the survey
area. Historical locations occur
approximately 0.9 mile north and
approximately 0.6 mile southwest of
the survey area but not within it
(Figure 7) (CDFW 2023a; CNPS 2023).

Holocarpha virgata
ssp. elongata
Graceful tarplant None/None/4.2/None Occurs in coastal sage scrub, foothill woodland, chaparral,
and grassland habitats at
elevations below 2,950 feet
amsl. Blooms May–November.

Low. Suitable habitat occurs in Diegan
coastal sage scrub in the northeastern
corner of the survey area and the
northern and eastern portions with
disturbed Diegan coastal sage scrub.

The species was not observed during
the survey, and no historical locations
exist within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).

Horkelia truncata Ramona horkelia None/None/1B.3/
None
Occurs in clay and gabbroic soils
within chaparral and cismontane
woodland between 218 and
4,013 feet amsl. Blooms May–
June.

Not expected. No suitable habitat with
clay or gabbroic soils occurs within the
survey area. No historical locations exist
within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).

Lepechiniacardiophylla
Heart‐leaved
pitcher sage
None/None/1B.2/MSCP Occurs in chaparral, cismontane
woodland, and closed‐coneconiferous forest between 397
and 4,217 feet amsl. Blooms
April–July.

Not expected. No suitable habitat
occurs within the survey area. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).
16 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Lepidium virginicumvar.robinsonii
Robinson's pepper‐
grass
None/None/4.3/None Occursin chaparral and coastal
scrub bluff habitatsfrom 5 to
2,905 feet amsl. Blooms
January−July.

Low. Suitable habitat occurs in Diegan
coastal sage scrub in the northeastern
corner of the survey area and the
disturbed Diegan coastal sage scrub in
the northern and eastern portions of
the survey area. Not observed during
2023 survey; however, survey was
conducted outside the bloomingperiod. No historical locations exist within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).

Microseris douglasiissp. platycarpha
Small‐floweredmicroseris
None/None/4.2/None Occurs in clay soils within coastal
sage scrub, woodlands, and
valley grassland habitats, or near
vernal pools or serpentineoutcrops between 29 and 3,429 feet amsl. Blooms March–May.

Not expected. No coastal sage scrub
with clay soils occur within the survey
area. No historical locations exist within
1 mile of the survey area (CDFW 2023a;
CNPS 2023).

Monardellahypoleuca ssp. lanata
Felt‐leavedmonardella
None/None/1B.2/MSCP Occurs in chaparral, cismontane
woodland between 536 and
4,988 feet amsl. Blooms June–
August.

Not expected. No suitable habitat
occurs within the survey area. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a;
CNPS 2023).

Monardella viminea Willowy monardella FE/SE/1B.1/MSCP Usually occurs along or near ephemeralstreamsin coarse
rocky sand orsandy clay between
122 and 5,118 feet amsl. Blooms
June–August.

Not expected. No suitable habitat along
the drainage within the survey area,
and the survey area does not fall within
the known remaining eight population
locations of this species within San
Diego County. Therefore, the species is
not expected to occur. No historical
locations exist within 1 mile of the
survey area (CDFW 2023a;
USFWS 2023b; CNPS 2023).
17 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Ophioglossumcalifornicum
California adder's‐
tongue
None/None/4.2/None Occursinmoist areas or vernal pools
within chaparral,freshwater
wetlands, wetland–riparian, and
valley and foothill grassland
communities between 40 and 2,845
feet amsl. BloomsJanuary–June.

Not expected. No vernal pools or mesic
soils occur in the survey area. No
historical locations exist within 1 mile of
the survey area No historical locations
exist within 1 mile of the survey area
(CDFW 2023a; CNPS 2023).

Selaginellacinerascens
Ashy spike moss None/None/4.1/None Occurs in coastal sage scrub and chaparral habitats, often in red
clay soils at elevations between
65 and 2,100 feet amsl. No
blooming period listed.

Not expected. No coastal sage scrub
with clay soils occurs in the survey area.

No historical locations exist within 1
mile of the survey area (CDFW 2023a;
CNPS 2023).

Stipa diegoensis San Diego County
needle grass
None/None/4.2/None Occurs in chaparral and coastal
scrub with mesic or rocky soils
between 101 and 2,534 feet
amsl. Blooms February–June.

Low. Suitable habitat with rocky soils
occurs in Diegan coastal sage scrub in
the northeastern corner of the survey
area. The species was not observed
during 2023 survey; however, survey
was conducted outside the blooming
period. No historical locations exist
within 1 mile of the survey area (CDFW
2023a; CNPS 2023).

Tetracoccus dioicus Parry's tetracoccus None/None/MSCP Occurs in chaparral and coastal scrub, often on dry slopes
between 161 and 2,838 feet
amsl. Blooms April–May.

Low. Suitable Diegan coastal sage scrub
occurs in the northeastern corner of the
survey area, and steep slopes occur
further east adjacent to and outside the
survey area. Not observed during 2023
survey. No historical locations exist
within 1 mile of the survey area (CDFW
2023a; CNPS 2023).

Viguiera laciniata San Diego County
viguiera
None/None/4.3/None Occurs in chaparral and coastal
scrub, often on dry slopes
between 13 and 3,511 feet amsl.

Blooms February–June.

Moderate. Suitable Diegan coastalsage
scrub occursin the northeast corner of the
survey area. The species was not observed
during 2023 survey; however,survey was
conducted outside the blooming period.

No historical locations exist within 1 mile of
the survey area (CDFW 2023a; CNPS 2023).
18 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Wildlife
Invertebrates
Bombus crotchii Crotch’s bumblebee FC/None/None/None Occursin grasslands and shrublands, generally in hotter and
drier habitatsthan otherspecies
of bumblebee. Thisspeciesis
short‐tongued and therefore
prefers plantslike milkweeds,
buckwheats, medics, poppies, and
lupines.

High. Suitable Diegan coastal sage scrub
occurs in the northern, eastern, and
northeastern portions of the survey
area. California buckwheat was present
throughout both disturbed and non‐
disturbed Diegan coastal sage scrub as
a nectar source. Historical locations
from as recent as 2020 occur
approximately 0.8 mile southwest of
the survey area (Figure 7)
(CDFW 2023a).

Branchinectasandiegonensis
San Diego fairyshrimp
FE/SSC/—/MSCP Generally restricted to shallow
freshwater vernal pools and
includes swales, tire ruts, and
other depressions that are filled
seasonally by rainfall.

Not expected. No vernal pools or
depressions occur within the survey
area. Multiple historical locations occur
north of the survey area but not within
it (USFWS 2023a; CDFW 2023a).

Danaus plexippus Monarch butterfly
(Californiaoverwinteringpopulation)
FC/ST/—/None Occurs in a variety of habitats
where patches of milkweed
(Asclepias sp.), the monarch
caterpillar host plant, are
present. Overwinter in groves of
eucalyptus, cypress, and pinealong the California coast and high‐elevation forests in Mexico.

High. Suitable nectarsourcesfor foraging
present in landscape/ornamental plants
throughout the survey area and Diegan
coastalsage scrub in the northern,
eastern, and northeastern portions of the
survey area. No milkweed patches,
suitable as host plantsfor caterpillarsto
occupy, occur in the survey area.

Eucalyptus and pine trees,suitable for
overwintering, occursurrounding the
residence within developed areas. No
historical locations occur within 1 mile of
the survey area; however,thisspeciesis
likely to occurin the survey area
(USFWS 2023b; CDFW 2023a).
19 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Euphydryas editha
quino
Quino checkerspotbutterfly
FE/None/—/MSCP Occurs in chaparral and coastal
sage shrublands. Cryptogamic
soil crusts and host plant
species, including dot‐seed
plantain (Plantago erecta) and
owl’s clover (Castilleja exserta),
are species indicators.

Low. Limited suitable Diegan coastal
sage scrub is present in survey area, but
no host plants occur in the survey area.

Suitable nectar sources for foraging
occur throughout the survey area. No
historical locations exist within 1 mile of
the survey area (CDFW 2023a USFWS
2023b).

Lycaena hermes Hermes copper
butterfly
FT/None/—/MSCP Occurs in chaparral and coastal
sage scrub habitats, particularly
ones that contain its host plant
spiny redberry (Rhamnus crocea)
and primary nectar plant
California buckwheat.

Moderate. Suitable Diegan coastal sage
scrub habitat with California buckwheat
occurs in the northern, eastern, andnortheastern portions of the survey area for foraging, but no host plants
were observed in these areas. One
spiny redberry was observed in the
landscaping on the west side of a
residential property in survey area, but
this area is completely mowed and does
not support suitable coastal sage scrub
habitat for foraging or breeding within
the survey area. No historical locations
exist within 1 mile of the survey area
(CDFW 2023a USFWS 2023b).

Amphibians
Anaxyrus californicus Arroyo toad FE/SSC/—/MSCP This species has extremely specialized habitat needs, whichinclude exposed sandy streamswith stable terraces forburrowing with scatteredvegetation for shelter, and areasof quiet water or pools free ofpredatory fishes with sandy orgravel bottoms without silt forbreeding.

Not expected. No slow‐moving, sandy
streams with stable terraces occurwithin the survey area for breeding or foraging. No historical locations exist
within 1 mile of the survey area (CDFW
2023a USFWS 2023b).
20 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Spea hammondii Western spadefoot FC/SSC/—/None Occurs primarily in grasslands or coastal sage scrub with vernal
pools or similar shallow,
temporary pools for breeding.

Moderate. Suitable Diegan coastal sage
scrub habitat occurs in the northern,
eastern, and northeastern portions of
the survey area for foraging, but no
shallow pools or rutting occur within
the survey area for breeding. Human‐
made pools or ponds within the
surrounding rural–residential areas
could provide suitable breeding habitat,
but none were observed within the
survey area. Historical locations occur
approximately 0.7 mile north and
northwest of the survey area and
approximately 0.2 mile south of the
survey area (Figure 7) (CDFW 2023a).

Reptiles
Aspidoscelishyperythra
Belding’s orange‐throated whiptail
None/WL/—/MSCP Occurs in coastal sage scrub,
chaparral, edges of riparian
woodlands, and washes. Also,
found in weedy, disturbed areas
adjacent to these habitats.

High. Suitable Diegan coastal sage scrub
habitat and weedy disturbed areas
adjacent to coastal sage scrub occur in
the northern, eastern, and northeastern
portions of the survey area. One
historical location occurs approximately

0.6 mile northwest of the survey area
(Figure 7) (CDFW 2023a).

Crotalus ruber Red diamond
rattlesnake
None/SSC/—/None Occurs in open chaparral and
coastal sage scrub and along
creek banks, particularly among
rock outcrops or piles of debris
with burrowing rodents for prey.

High. Suitable Diegan coastal sage scrub
occurs in the northern, eastern, and
northeastern portions of the survey
area. The non‐vegetated channels,
which have connectivity to disturbed
Diegan coastal sage scrub in the
northern portion of the survey area, are
also suitable habitat. A historical
location occurs approximately 0.6 mile
northwest of the survey area but not
within it (Figure 7) (CDFW 2023a).
21 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Phrynosomablainvillei
Blainville’s hornedlizard
None/SSC/—/MSCP Occurs in coastal sage scrub,
chaparral, and grasslands in
primarily loose soils. Often found
in areas with harvester ants.

High. Diegan coastal sage scrub withloose soils and harvester ants are present in the northern, eastern, and
northeastern portions of the survey
area. Historical locations occur
approximately 0.7 mile north and 0.8
mile northwest of the survey area but
not within it (Figure 7) (CDFW 2023a).

Thamnophishammondii
Two‐striped garter
snake
None/SSC/—/None Occurs in and along permanent
and intermittent streams within
oak woodland, willow, coastalsage scrub, scrub oak, sparse pine, chaparral, and brushland;
highly aquatic.

Low. Non‐vegetated channels in thenorthwestern portion of the survey area that have connectivity to disturbed
Diegan coastal sage scrub are suitable
habitat, but this species prefers riparian
areas with abundance of fish and
amphibians, which are not present in
the survey area. One historical location
occurs approximately 0.6‐mile
northwest of the survey area but not
within it (Figure 7) (CDFW 2023a).

Birds
Aimophila ruficeps
canescens
Southern California
rufous‐crownedsparrow
None/WL/—/MSCP Occurs in coastal sage scrub and
sparse mixed chaparral on rocky
hillsides and in canyons; also
found in open sage scrub/grassy
areas of successional growth.

Moderate nesting, Moderate foraging.

Suitable Diegan coastal sage scrub for
nesting and foraging occurs in the
northern, eastern, and northeastern
portions of the survey area, particularly
on the northeastern corner where rocky
habitat occurs just outside the surveyarea. Historical locations occur north,northeast, and west of the survey area with the closest observations occurring
within 0.1 mile of the survey area (Figure
7) (CDFW 2023a; USFWS 2023b).

Ammodramussavannarum
Grasshoppersparrow
None/SSC/—/None Occurs in grasslands, prairies,
hayfields, and open pastures
with little to no scrub cover and
often with some bare ground.

Not expected foraging, Not expected
nesting. No suitable grassland habitat
occurs within or immediately
surrounding the survey area. One
22 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
historical location occurs approximately0.2 mile west of the survey area but not within it (Figure 7) (CDFW 2023a).

Artemisiospiza belli
bellii
Bell’s sparrow None/WL/—/None Occurs in chaparral dominated by chamise and coastal sage
scrub dominated by California
sagebrush.

Low nesting, Moderate foraging. Diegan
coastal sage scrub dominated by
California sagebrush occurs primarily in
the northeastern corner of the survey
area and could support foraging or
dispersing individuals; however, the
habitat in the survey area is small and
close to disturbance and would likely
discourage nesting. Disturbed Diegan
coastal sage scrub in the northern and
eastern portions of the survey area
could also support foraging and
dispersing individuals but are less
suitable for nesting. One historical
location occurs approximately 0.9 mile
north of the survey area but not within
it (Figure 7) (CDFW 2023a).

Campylorhynchusbrunneicapillussandiegensis
Coastal cactus
wren
BCC/SSC/—/MSCP Occurs in large cactus patches
(i.e., prickly pear [Optunia sp.] or
chollas [Cylindropuntia sp.])
patches within coastal sage
scrub.

Not Expected Nesting, Not Expected
Foraging. No suitable large native
cactus patches exist for foraging or
nesting. Historical locations occur
approximately 0.8 mile northwest and
southwest of the survey area but not
within it (Figure 7) (CDFW 2023a).

Empidonax trailliiextimus
Southwestern
willow flycatcher
FE/SE/—/MSCP Occurs in habitat often near
riparian areas especially with
willow species.

Not expected Foraging, Not Expected
Nesting. No suitable riparian habitat
occurs in the survey area. No historical
observations occur within 1 mile of the
survey area (CDFW 2023a; USFWS
2023b).
23 Table 2. Sensitive Plant and Wildlife Species with Potential to Occur Scientific Name Common Name
Status
Federal/State/CRPR/Regional Habitat Potential to Occur
Polioptila californica
californica
Coastal Californiagnatcatcher
FT/SSC/—/MSCP Obligate, permanent resident of
coastal sage scrub below 2,500
feet in Southern California.

High foraging, Moderate nesting.

Suitable Diegan coastal sage scrub for
foraging and nesting occurs in the
northern, eastern, and northeastern
portions of the survey area. Numerous
historical observations occur north,
east, and west of the survey area. One
observation occurs immediately
adjacent to the survey buffer in the
northwestern corner of the survey area
(Figure 7) (CDFW 2023a;
USFWS 2023b).

Vireo bellii pusillus Least Bell's vireo FE/SE/—/MSCP Occurs in a variety of habitats, but most often associated with
riparian habitat, often with
willow species. Requires dense
understory shrub cover for nest
concealment, with an overstory
dominated by willows.

Not expected Foraging, Not Expected
Nesting. No suitable riparian habitat
occurs in the survey area. One historical
location occurs approximately 0.9 mile
north of the survey area but not within
it (Figure 7) (CDFW 2023a; USFWS
2023b).

Mammals
Felis concolor Mountain lion None/None/None/
MSCP
Occurs in a variety of habitats
throughout California. Rests in
rocky areas and on cliffs or
ledges that provide cover.

Moderate. Suitable habitat and smaller
prey available immediately adjacent to
the survey area, but no suitable rocky
cliffs or ledges that could provide cover
are present in the survey area. Foraging
individuals could travel through the
survey area. Historical locations occur
approximately 0.9 mile north of the
survey area, but not within it (Figure 7;
CDFW 2023a; USFWS 2023b).

Notes: — = no data; amsl = above mean sea level; CRPR = California Rare Plant Rank; None = no status indicated for species Federal StatusFC = Federal candidate
FE = Federally listed as endangered
FT = Federally listed as threatened
24 State StatusSSC = State listed as special species of concern ST = State‐listed as threatened
WL = State watch list species
CRPR Ranking1B = Species rare, threatened, or endangered in California and elsewhere. These species are eligible for state listing. 2B = Species rare, threatened, or endangered in California but more common elsewhere. These species are eligible for state listing. 4 = A watch list of species of limited distribution. These species need to be monitored for changes in the status of their populations.

0.1 = Species seriously threatened in California (over 80 percent of occurrences threatened; high degree and immediacy of threat).

0.2 = Species fairly threatened in California (20–80 percent occurrences threatened; moderate degree and immediacy of threat).

0.3 = Species not very threatened in California (<20 percent of occurrences threatened; low degree and immediacy of threat or no current threats known).

Regional Status
MSCP = Multiple Species Conservation Program covered
25 Plant Species
No sensitive plant species were observed or determined to have a potential to occur in the survey area (Table 2).

Wildlife Species
No sensitive wildlife species were observed or determined to have a potential to occur in the survey area (Table 2).

Sensitive Wildlife Species Not Observed but with High Potential to Occur Six sensitive wildlife species were determined to have a high potential to occur in the survey area. None of these species were observed during the biological resource survey. However, no sensitive protocol surveys were conducted. These sensitive wildlife species with a high potential to occur in the survey area are described in the following subsections.

Crotch’s Bumblebee
Crotch’s bumblebee (Bombus crotchii) is a federal candidate species. In October 2018, the Xerces Society for Invertebrate Conservation (CDFW 2019) submitted a petition to CDFW to list Crotch’s bumblebee. It was determined that listing the species “may be warranted,” and the species became a candidate for federal listing on June 12, 2019, affording it the same legal protection as an endangered or threatened species (CDFW 2019).

Crotch’s bumblebee is distinguished from other Bombus species based on hair coloration. Queens and workers have a black face with a yellow vertex and yellow scutum with black hairs between and below the wings and on the scutellum. The first tergal segments are black, the second is yellow, and third is black sometimes with red.

Males have a yellow head, face, scutellum, and scutum with a black band between the wings. The first, second, and third tergal segments on males are yellow, and the third and the fourth through seventh are either entirely black or entirely red. This species is endemic to California where it occurs throughout most of southwestern California in a variety of habitatsincluding open grasslands,shrublands, chaparral, desert margins, creosote scrub, and semi‐urban areas. Crotch’s bumblebees are generalist foragers but are best suited to forage on species with open flowers and short corollas due to their short tongue. The plant families most commonly visited include Fabaceae, Apocynaceae, Asteraceae, Lamiaceae, Hydrophyllacae, Asclepiadaceae, and Boraginaceae. While little is known about hibernacula of this species, it is likely that it overwinters in soft, disturbed soil and nests underground. The flight period for Crotch’s bumblebee occursfrom late February to late October, peaking in early April and again in July (Xerces Society 2018). Threats to this species include habitat loss and modification, herbicides, pesticides, disease, and competition.

Diegan coastal sage scrub with suitable nectar sources including California buckwheat were observed in the northern, eastern, and northeastern portions of the survey area. One historical location from as recent as 2020 occurs approximately 0.8 mile southwest of the survey area (Figure 7) (CDFW 2023a).

Monarch Butterfly
On December 15, 2020, the USFWS found that adding the monarch butterfly to the list of threatened and endangered species was warranted but precluded by higher‐priority species reviews and work (USFWS 2023d).

Monarch butterfly is one of the most recognizable butterfly species, with orange wings laced with black lines and bordered with white dots. Its wingspan is 3.7 to 4.1 inches. This species occurs in patches of milkweed (Asclepias sp.), which is the species’ caterpillar host plant. Although the larvae only eat milkweed, adult monarchs feed on a variety of nectar‐bearing flowers. Monarch butterflies are found across North America wherever suitable feeding, breeding, and overwintering habitat exists. Monarch butterflies overwinter in groves of eucalyptus, cypress, and pine trees along the California coast and high‐elevation forests in Mexico (Xerces Society 2017). Threats to this species include habitat loss, climate change, and agriculture.

Mature ornamental trees, including eucalyptus and pines, are present in the survey area and surrounding areasthat would provide suitable overwintering habitat for monarch butterfly. No milkweed patches were observed in the survey area that would be suitable for monarch butterfly caterpillars to occupy, but numerous landscape/ornamental plantsthroughout the survey area could provide nectarsourcesfor thisspeciesin addition to 26 Diegan coastal sage scrub species in the northern, eastern, and northeastern portions of the survey area. No historical locations occur within 1 mile of the survey area (CDFW 2023a).

Red Diamond Rattlesnake
Red diamond rattlesnake (Crotalus ruber) is a CDFW species of special concern. Red diamond rattlesnake can be found in the counties of San Bernardino, Riverside, and San Diego. Its habitat includes arid desert in rocky areas, coastal scrub, chaparral, woodland, and dense vegetation. This species can also occur from sea level up to 3,000 feet in elevation and is active from mid-spring into fall. The red diamond rattlesnake is successful as an ambush predator and will actively seek prey on the ground and in bushes. As temperatures increase throughout the season, this species becomes less active during the day and becomes fully nocturnal. Young are typically born from mid-August to October. Threats to red diamond rattlesnake include urban development, pest control, and off-road vehicle activity.

Suitable Diegan coastal sage scrub occurs in the northern, eastern, and northeastern portions of the survey area, particularly on the northeastern corner, where rocky habitat occurs just outside the survey area. The nonvegetated channels, which have connectivity to disturbed Diegan coastal sage scrub in the northern portion of the survey area and larger stretches of dense, undisturbed Diegan coastal sage scrub outside the survey area are also suitable habitat. Debris and litter from residential structures in the survey area could provide suitable shelter for this species. A historical location occurs approximately 0.6 mile northwest of the survey area but not within it (Figure 7) (CDFW 2023a).

Belding’s Orange-Throated Whiptail
Belding’s orange-throated whiptail (Aspidoscelis hyperythra), a CDFW Watch List and an MSCP-covered species, is a medium-sized lizard with an orange throat and a chest, which turns brighter orange during breeding season.

Belding’s orange-throated whiptail occurs in coastal sage scrub, chaparral, edges of riparian woodlands, washes, and weedy, disturbed areas adjacent to these habitats. This species eats small invertebrates, including spiders, scorpions, centipedes, termites, and small lizards (Nafis 2023). Threats to this species include development and habitat fragmentation.

Suitable Diegan coastal sage scrub with adjacent weedy disturbed areas is present in the northern, eastern, and northeastern portions of the survey area, which provide suitable habitat for Belding’s orange-throated whiptail.

One historical location occurs approximately 0.6 mile northwest of the survey area (Figure 7) (CDFW 2023a).

Blainville’s Horned Lizard
Blainville’s horned lizard (Phrynosoma blainvillei) is a CDFW Species of Special Concern. Blainville’s horned lizard is a medium-sized horned lizard that ranges widely in coloration and has distinctive horns along its entire back and sides. This species occurs in riparian woodlands, coniferous forests, chaparral, coastal sage scrub, and annual grassland habitats with loose soils for burrowing. Blainville’s horned lizard is found in the Sierra Nevada foothills and throughout the central and Southern California coasts at elevations up to 6,000 feet amsl. It feeds on the ground in open areas, primarily hunting native ants, although it will feed on other small invertebrates. Threats to Blainville’s horned lizard include urban development, conversion of habitat to agriculture, and collection of individuals for the pet trade. In addition to these threats, the non-native and less palatable Argentine ant (Iridomyrmex humile) is displacing native ants, an important food source for this species, in many areas.

Suitable Diegan coastal sage scrub with loose soils and harvester ants (Pogonomyrmex sp.) present in the northern, eastern, and northeastern portions of the survey area have the potential to support Blainville’s horned lizard. Historical locations occur approximately 0.7 mile north and 0.8 mile northwest of the survey area but not within it (Figure 7) (CDFW 2023a).

Coastal California Gnatcatcher
Coastal California gnatcatcher (Polioptila californica californica) is a federally threatened and MSCP covered species. The coastal California gnatcatcher is a small, gray, long-tailed insectivorous songbird that occurs almost exclusively in open coastal sage scrub vegetation with California sagebrush as the dominant or co-dominant 27 species, but the coastal California gnatcatcher can also be found in chaparral sage scrub intergrades and riparian habitats (mulefat scrub) (USFWS 2010). Coastal California gnatcatchers are endemic to Southern California and Baja California, Mexico, and they do not migrate in winter. In Southern California, this species ranges from the County of Ventura south to the County of San Diego and east to the County of San Bernardino. Males have dark blue–gray plumage on their upperparts and grayish white plumage on their underparts, while females and hatchyear juveniles have gray–brown plumage above and grayish white plumage below. The tail is mostly black above and below. Males have a distinctive black cap, which is absent during the winter. Both sexes have a distinctive white eye ring. They have a distinct call, which sounds like a kittenish “mew.” The breeding season extends from February through August, with peak nesting activities occurring from mid-March through May (USFWS 2010). Both the male and female in a pair will incubate between 3 and 5 eggs, with the average clutch being 4; and both adults will feed hatchlings and fledglings. Males will vigorously patrol territories which range in size from 2 acres to upwards of 40 acres. Territories are held year-round and are smallest during the wintertime, likely when lower resources are required (no longer feeding juveniles). Although nonmigratory, juveniles disperse typically less than 3 kilometers but have been known to move upwards of 20 kilometers. The major threat to this species is the rapid loss of coastal sage scrub habitat to urbanization and agricultural development.

Suitable foraging habitat for coastal California gnatcatcher occurs in the Diegan coastal sage scrub (including disturbed) in the northern, eastern, and northeastern portions of the survey area, which further connect to larger, uninterrupted areas of high-quality Diegan coastal sage scrub. Although the survey area contains suitable foraging habitat, it does not provide high potential for nesting because of its size and immediate surrounding habitat (disturbed) on three out of four sides. Therefore, the Diegan coastal sage scrub within the survey area may be included in the overall larger territory for an established pair but has lower potential to contain a nest for a breeding pair. Therefore, while the survey area has moderate potential to support nesting coastal California gnatcatcher, the Diegan coastal sage scrub in the survey area provides adequate foraging and patrolling habitat for a breeding pair and or for dispersing juveniles. Therefore, the Diegan coastal sage scrub in the survey area has a high potential to provide foraging habitat for coastal California gnatcatcher.

Numerous documented occurrences of this species exist on all sides of the survey area. One location occurs immediately adjacent to the northwestern corner of the survey area (Figure 7) (CDFW 2023a), and critical habitat for this species occurs throughout the entire survey area (Figure 8, Critical Habitat).

Roosting Bats
The survey area contains suitable roosting and foraging habitat for common bat species. Although bats that avoid areas heavily used by humans may not be observed, the availability of suitable roosting habitat (i.e., residential buildings, sheds, trees) and suitable foraging habitat (i.e., open disturbed areas, ornamental plantings) indicate that bats more common to urban and suburban environments or habitat “generalist” species have potential to be found in the survey area. Common species including Mexican free-tailed bats (Tadarida brasiliensis), California myotis (Myotis californicus), big brown bat (Eptesicus fuscus), and hoary bat (Lasiurus cinereus), which can be found roosting in buildings, crevices, and trees and foraging over open space areas, have potential to be found in the survey area, particularly within structures, like sheds and residential homes, and ornamental trees throughout the survey area. The non-vegetated channels in the northwestern portion of the survey area (when flows are present) provide suitable foraging habitat for bats roosting in the area that forage over sources of open water, including fringed myotis (Myotis thysanodes). While no bats were observed using the survey area for roosting or foraging during the biological resource survey, no nighttime focused acoustic surveys were conducted, and the availability of suitable habitat indicates that bats have potential to roost and forage in the survey area.

Nesting Birds
While no active nests were observed in the survey area, a focused nesting bird survey was not conducted as part of the biological reconnaissance survey. In addition, the survey was conducted outside typical breeding season for most bird species. The project site provides potentially suitable nesting habitat for several bird species, including raptors, which are protected under the CFGC and MBTA.
28 Mature trees, including eucalyptus, Peruvian pepper, and pine species, are present throughout the survey area and in the non-native woodland on the eastern portion of the survey area, which are suitable for many species including hummingbirds and raptors such as red-shouldered hawk. Structures that have eaves, crevices, cracks, and other “cavities,” including the sheds and residential structures in the northern, central, and southern portions of the survey area and the church in the southwestern portion of the survey area, may provide nesting opportunities for other nesting birds, such as black phoebes (Sayornis nigricans), which attach their nests to undersides of structures with mud. The Diegan coastal sage scrub in the northern, eastern, and northeastern portions of the survey area could support nesting for a variety of common species like California towhee (Melozone crissalis) or California thrasher (Toxostoma redivivum), and sensitive species like coastal California gnatcatcher.

Critical Habitat
The potential presence of critical habitat in the survey area and within a 1-mile radius was analyzed. Designated critical habitat for two sensitive wildlife species, coastal California gnatcatcher and Hermes copper butterfly (Lycaena hermes) occur within a 1-mile radius of the survey area. Critical habitat for these species is displayed on Figure 8.

Critical habitat for coastal California gnatcatcher occurs throughout the survey area, while critical habitat for Hermes copper butterfly occurs in a narrow strip on the western side of the survey area and surrounding areas further north, east, and west of the survey area.

Wildlife Corridors and Linkages
Wildlife corridors provide routes for local movement and also regional linkages and corridors, often following linear topographic, vegetation, or water features. These corridors can be continuous habitats, features, or “stepping stone” areas, providing critical rest and foraging areas, for example, for birds traveling along migratory routes. Local routes of movement provide constant connections to resources that include sources of water, home/cover sites, and foraging areas. Regional linkages and movement corridors provide larger patches of open space to allow relatively free movement of wildlife species along multiple paths between important resources.

These areas allow for not only long-term genetic flow between subpopulations but also critical pathways of seasonal/migratory movements. Larger predatory mammals often use regional corridors for hunting and reproduction needs. Potential wildlife corridors can include streams, riparian areas, and culverts under roadways.

Habitat characteristics considered include topography, habitat quality, and adjacent land uses.

The survey area is a partially developed residential lot surrounded by a mixture of large, continuous stretches of high-quality Diegan coastal sage scrub to the north, east, and west, and other residential development. The open coastal scrub areas are designated as part of a core biological resource area in the County MSCP (County of San Diego 1998). Sycamore Canyon/Goodan Ranch County Preserve and Sycamore Canyon Open Space Preserve occur approximately 2.5 miles north of the survey area. Diegan coastal sage scrub in the northeastern and eastern portions of the survey area has direct connectivity to these preserves. Fully conserved land with connectivity to these preserves occurs northeast of the survey area, and Santee Lakes Recreation Preserve occurs approximately

1.4 miles west of the survey area. The San Diego River occurs approximately 1.9 miles south of the survey area but is separated from the survey area by heavy residential development.

Although the survey area is partially developed and bordered by dense developed areas to the south, the survey area contains patches of native habitat and open areas that have connections to open space within the Sycamore Canyon/Goodan Ranch County Preserve, Sycamore Canyon Open Space Preserve, and the Santee Lakes Recreation Preserve. Therefore, the survey area may be used as a movement corridor by large mammals and mesocarnivores looking to access open space and avoid more developed portions of this immediate area. The survey area also provides suitable nesting, foraging, and dispersal opportunities for both common and sensitive wildlife species, including avian and bat species, invertebrates, reptiles, mesocarnivores (i.e., raccoons [Procyon lotor]), and other smaller mammals as well as large mammals like mountain lions (Felis concolor).

The survey area holds value for migrating birds flying through to wintering grounds that are protected by the MBTA.

The non-native woodland, Diegan coastal sage scrub, and ornamental vegetation and structures throughout the survey 29 area could support migrants and breeding pairs, particularly due to the proximity of the survey area to the San Diego River and nearby native habitat and Preserves.

Some movement to the west, towards the Santee Lakes Recreational Preserve may be slightly impeded due to the presence of Summit Avenue and a regularly mowed fire break immediately adjacent to the high-quality Diegan coastal sage scrub further west and outside the survey area. Movement may also be slightly impeded to the east, where another small area is developed for residential use, and to the south, where heavy urban development occurs. Therefore, the project site is likely to provide local movement opportunities but would not be considered a significant regional movement corridor due to the survey area’s inability to serve as a major route of movement or as a critical linkage to larger open spaces.

Jurisdictional Aquatic Resources
A formal aquatic resources delineation was not conducted during the biological survey. As previously discussed in the Hydrology section, NWI and NHD database query results identified several aquatic features surrounding the survey area and one within it (Figure 5). The aquatic resource, a non-vegetated channel, identified in the NWI and NHD, results was observed in the survey area (AF-1) in addition to two other non-vegetated channels with connectivity to this feature (AF-2 and AF-3) (Figure 9, Potential Jurisdictional Aquatic Resources). All three aquatic resources occur in the northwestern portion of the survey area and were determined to be non-wetland waters that are tributaries to the San Diego River, a TNW. Therefore AF-1, AF-2, and AF-3 are all potentially under the jurisdiction of the USACE pursuant to the CWA Section 404. AF-1, AF-2, and AF-3 convey natural flows and urban stormwater through both developed land and open space, providing water quality and habitat functions for the San Diego River Watershed and, therefore, are potentially under the jurisdiction of the RWQCB and CDFW, pursuant to the CWA Section 401 and CFGC Section 1602, respectively.

The potential jurisdictional aquatic features observed in the survey area total approximately 0.03 acre, with approximately 0.01 acre occurring on the project site; however, these features will be avoided entirely during implementation of the project.

Significance of Project Impacts and Proposed Mitigation Significance Criteria
Direct impacts occur when biological resources are altered or destroyed during the course of or as a result of project implementation. Examples of such impacts include removing or grading vegetation, filling wetland habitats, or severing or physically restricting the width of wildlife corridors. Other direct impacts may include loss of foraging or nesting habitat and loss of individual species as a result of habitat clearing. Indirect impacts may include elevated levels of noise or lighting, change in surface water hydrology within a floodplain, and increased erosion or sedimentation. These types of indirect impacts can affect vegetation communities or their potential use by sensitive species. Permanent impacts may result in irreversible damage to biological resources. Temporary impacts are interim changes in the local environment due to construction and would not extend beyond projectassociated construction, including revegetation of temporarily disturbed areas adjacent to native habitats.

Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) define “significant effect on the environment” as a “substantial, or potentially substantial adverse change in the environment.” Appendix G of the CEQA Guidelines further indicates that a significant effect on biological resources may occur if the project would:
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game [1
] or U.S. Fish and Wildlife Service.
b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.
1 As of January 1, 2012, the California Department of Fish and Game became the California Department of Fish and Wildlife. 30 c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

Threshold A
Guidelines for Determination of Significance
A significant impact would result if the project had a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special statusspecies in local or regional plans, policies, or regulations or by the CDFW or USFWS.

This guideline for significance is taken directly from the CEQA Guidelines, Appendix G, and is based on the CEQA Guidelines definition of mandatory findings of significance (Section 15065) and of endangered, rare, or threatened species (Section 15380).

Analysis
Potential direct and indirect impacts to sensitive plant and wildlife species are discussed in the following subsections.

Sensitive Plant Species
As discussed in the Results section, no sensitive plant species were observed or determined to have a high potential to occur in the survey area. Further, the areas containing Diegan coastal sage scrub (including disturbed), non-native woodland, non-vegetated channels, and disturbed habitat on the project site have a low potential to support sensitive plant species, and only portions of non-native woodland and disturbed and developed areas will be impacted on the project site (Table 2). Therefore, project implementation would not result in direct or indirect impacts to sensitive plant species. Impacts to sensitive plant species would be less than significant, and no mitigation is required.

Sensitive Wildlife Species
As discussed in the Results section, no sensitive wildlife species were observed in the survey area, but the project has the potential to result in direct and indirect impacts on sensitive wildlife species that have a high potential to occur in the survey area. Six sensitive species were determined to have a high potential to occur within the survey area. Although monarch butterfly was not observed within the survey area, and no observations have been documented within 1 mile of the survey area, presence of suitable habitat indicates that this species has a high potential to occur in the survey area. Potential direct and indirect impacts to sensitive wildlife species are discussed in the following subsections.

Direct Impacts
Two sensitive vegetation communities, Diegan coastal sage scrub (disturbed) and non-vegetated channel, which could support sensitive wildlife species, were observed on the project site; however, these areas will be avoided, and no impacts are expected during project implementation. Non-native woodland is not considered a sensitive vegetation community but may provide suitable nesting and foraging habitat for both common and sensitive species.

The disturbed habitat and developed areas on the project site are also not considered sensitive vegetation communities; however, these areas may provide foraging habitat for sensitive species like red diamond rattlesnake and foraging and roosting habitat for common bat species (indirect impacts).

Table 3, Impacts on Sensitive Vegetation Communities, presents the total sensitive vegetation community acreages in the survey area and the permanent impacts from implementation of the project. 31 Table 3. Impacts on Sensitive Vegetation Communities Vegetation Community and
Land Cover Type Project Site (acres)1 Permanent Impacts1 Aquatic
Non-vegetated channel (64200) 0.01 0
Subtotal 0.01 0
Upland
Diegan coastal sage scrub (including
disturbed) (32500) 0.04 0
Subtotal 0.04 0
Total 0.05 0
Sources: Holland 1986; Oberbauer et al. 2008.

Notes:
1 Acreages rounded up to one-hundredth
No permanent direct impacts to sensitive vegetation communities would occur as a result of project implementation, as impacts to these areas on the project site will be avoided (Figure 10, Impacts to Biological Resources); therefore, no mitigation is required.

Permanent impacts to approximately 0.02 acre of non-native woodland, 2.39 acres of disturbed habitat, and approximately 0.5 acre of urban/developed land would occur during project implementation (Figure 10). The nonnative woodland consists of Peruvian pepper trees that could provide nesting and foraging habitat for a variety of common and sensitive species. The disturbed habitat on the project site is dominated by bare ground, black mustard, and dove weed with sparse amounts of non-native grasses and non-native annuals that may provide marginally suitable foraging habitat for raptors and other sensitive bird species, invertebrates, and reptiles. The landscaped and ornamental plants within the developed areas could provide foraging habitat for various reptile and invertebrate species like monarch butterfly and Belding’s orange-throated whiptail. Removal of the potential foraging habitat could result in significant impacts to sensitive birds and raptors, invertebrates, and reptiles, and mitigation is required.

Indirect Impacts
Temporary construction-related indirect impacts to wildlife generally include noise, vibration, lighting, increased human activity, dust deposition, introduction or spread of non-native species, increased potential of exotic species invasion due to soil disturbance, hydrologic quality, increased turbidity, excessive sedimentation, flow interruptions, changes in water temperature, and trash and garbage, which can attract both introduced terrestrial and native terrestrial and avian predators (such as American crows [Corvus brachyrhynchos], common ravens [Corvus corax], coyotes [Canis latrans], domestic dogs [Canis familiaris], raccoons, and striped skunks [Mephitis mephitis]). These temporary construction-related indirect impacts in the form of habitat disturbance and potential predation could have a significant impact on Belding’s orange-throated whiptail, Blainville’s horned lizard, coastal California gnatcatcher, Crotch’s bumblebee, monarch butterfly, and red diamond rattlesnake, and mitigation would be required.

Nesting Birds
Project implementation has the potential to impact bird and raptor species that are protected under the MBTA and CFGC Section 3503. The Diegan coastal sage scrub on and surrounding the project site could provide suitable nesting habitat for both common and sensitive species, including coastal California gnatcatcher, although it is more likely that this species would nest further outside the survey area. Additionally, the non-native trees within disturbed habitat and developed areas surrounding the project site provide nesting habitat for many bird species.

If construction is conducted during the general bird breeding season (January 15 through August 31), temporary direct impacts from disturbance and displacement of nesting birds during vegetation removal could result in significant direct impacts on bird species protected under the MBTA and CFGC, and mitigation is required. Indirect 32 impacts from construction noise and vibration during clearing, grubbing, and trenching activities, if conducted during the bird breeding season, could result in significant indirect impacts on bird species protected under the MBTA and CFGC, and mitigation is required.

Roosting Bats
As previously discussed, suitable roosting habitat for common bat species occurs primarily in the native and ornamental trees and structures in the survey area. No sensitive bat species were determined to have potential to roost or forage in the survey area. Therefore, no potential direct and indirect impacts to sensitive roosting bats would be expected to occur, and no mitigation is required.

Threshold B
Guidelines for Determination of Significance
A significant impact would result if the project had a substantial adverse effect to any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the CDFW or USFWS.

Analysis
Direct Impacts
As previously discussed under Threshold A, direct temporary and permanent impacts to sensitive vegetation communities on the project site are not anticipated as these habitats will be avoided during project implementation (Table 3; Figure 10); therefore, no mitigation is required.

Indirect Impacts
Indirect impacts to sensitive vegetation communities on the project site could result from invasion and spread of exotic species, exposure to construction-related pollutant discharges, and trampling by humans. These temporary construction-related indirect impacts to sensitive vegetation communities would be significant, and mitigation is required.

Threshold C
Guidelines for Determination of Significance
A significant impact would result if the project had a substantial adverse impact on federally protected wetlands as defined by Section 404 of the CWA(including but not limited to marsh, vernal pool, and coastal) through direct removal, filling, hydrological interruption, or other means. Impacts to state or federally jurisdictional aquatic resources would be considered significant and would require permits from the USACE and the RWQCB. Aquatic resources delineations would be required for any impacts to potential jurisdictional aquatic resources.

Analysis
As discussed in the Results section, three non-vegetated channels, AF-1, AF-2, and AF-3, were observed in the survey area (Figure 9). All three channels were determined to be non-wetland waters that have connectivity to each other and the San Diego River, a TNW. Therefore, AF-1, AF-2 and AF-3 are likely under the jurisdiction of the USACE, RWQCB, and CDFW pursuant to Sections 404 and 401 of the CWA and Section 1602 of the CFGC; however, only the USACE, RWQCB, and CDFW can make a final determination of jurisdictional boundaries.

Direct Impacts
As discussed in the Project Location and Description section, only portions of the project site would be developed, and the aquatic features AF-1, AF-2, and AF-3 located in the northwestern portion of the project will be avoided (Figure 10). Therefore, no permanent direct impacts will occur to potentially federal and state jurisdictional aquatic resources, and no mitigation is required.
33 Indirect Impacts
Most of the indirect impacts to sensitive plant species and sensitive vegetation communities described under Thresholds A and B would also result in potentially significant indirect impacts to the potential jurisdictional aquatic resources on the project site and require mitigation. Indirect impacts to potential jurisdictional aquatic resources can result from generation of fugitive dust, changes in hydrology resulting from construction (including sedimentation and erosion), and exposure to construction-related pollutant discharges. Mitigation is required.

Threshold D
Guidelines for Determination of Significance
The project would have a significant impact on wildlife movement and nursery sites if its development interfered substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impedes the use of native wildlife nursery sites.

Analysis
As discussed in the Results section, the project site likely functions mainly as a local movement corridor for both sensitive and common wildlife species rather than a larger-scale route for migratory animals because of the presence of Diegan coastal sage scrub and non-vegetated channels within the survey area and project site, and their proximity to large, continuous stretches of high-quality Diegan coastal sage scrub to the north, east, and west. These areas are all designated as part of a core biological resource area in the County MSCP (including Sycamore Canyon/Goodan Ranch County Preserve, and Sycamore Canyon Open Space Preserve, Santee Lakes Recreation Preserve, and fully conserved land to the northeast). Small areas of development to the east and west and larger developed areas to the south are likely to somewhat impede movement for mammals, reptiles, and amphibians.

However, the survey area still likely provides movement opportunities and suitable nesting, foraging, and dispersal areas for both common and sensitive wildlife species and connections to nearby open space within core biological resource areas and high-quality habitat.

The high-quality Diegan coastal sage scrub present on the project site provides live-in and breeding habitat for a number of sensitive wildlife species, including Belding’s orange-throated whiptail, Blainville’s horned lizard, coastal California gnatcatcher, Crotch’s bumblebee, monarch butterfly, and red diamond rattlesnake. However, no impacts are anticipated to this vegetation community as a result of project implementation. Non-native woodland has the potential to support nesting, roosting, and foraging habitat primarily for avian and common bat species.

However, the majority of trees within the non-native woodland habitat will not be removed and will continue to provide suitable habitat for these species. Project implementation is likely to temporarily impede local movement of wildlife species; however, it is unlikely to inhibit regional or major movement of wildlife species within the area, and no mitigation is required.

Threshold E
Guidelines for Determination of Significance
A significant impact would result if the project conflicted with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Analysis
The project would comply with the local policies or ordinances protecting biological resources identified in Santee’s General Plan and the MSCP (County of San Diego 1998). Therefore, no impacts to local policies or ordinances would occur from implementation of the project, and no mitigation is required.

Threshold F
Guidelines for Determination of Significance
A significant impact would result if the project conflicted with the provisions of an adopted Habitat Conservation Plan, natural community conservation plan, or other approved local, regional, or state Habitat Conservation Plan. 34 Analysis
The Santee MSCP Subarea Plan has not been approved or published yet, but the project would comply with the County MSCP. Therefore, no impacts to local conservation plans would occur from the implementation of the project, and no mitigation is required.

Proposed Mitigation
The following biological resources mitigation measures would be implemented during construction.

Sensitive Wildlife
BIO-1: Qualified Biologist. A qualified biologist provided by the City of Santee (or their designee) shall be on site periodically during construction activities that require implementation of specific measures. The qualified biologist shall be responsible for implementing the following measures:
a. Prior to commencement of construction, the limits of the project work area shall be clearly delineated with high visibility temporary fencing by a survey crew and checked by a qualified biologist before initiation of vegetation grubbing or removal.
b. The qualified biologist shall periodically inspect staging areas and stored construction materials (especially open pipes) for sensitive species throughout construction. The biologist shall also inspect any dirt stockpiles, pipes, and other construction materials temporarily stored on the project site to confirm they are covered and secured to prevent erosion and use by wildlife species. c. The qualified biologist shall inspect the construction site to ensure that steep trenches, holes, and excavations during construction to ensure they are covered at night with backfill, plywood, metal plates, or other means, and the edges covered with soils and plastic sheeting such that small wildlife cannot access them. Soil piles shall be covered at night to prevent wildlife from burrowing in. The edges of the sheeting shall be weighed down by sandbags. These areas may also be fenced to prevent wildlife from gaining access. Exposed trenches, holes, and excavations shall be inspected by construction personnel or the monitor when on site, twice daily (i.e., each morning and before sealing the exposed area), to monitor for wildlife entrapment. Excavations shall provide an earthen ramp to allow for a wildlife escape route.
d. Worker Environmental Awareness Program shall be implemented during construction. Training for the Worker Environmental Awareness Program shall be provided by the qualified monitoring biologist to all personnel working on site. The training shall include a review of all special-status and protected species that occur or have a high potential to occur, all project design features and protection measures, the responsibilities of each worker, and a reporting framework. e. The qualified biologist shall be present during construction activities that occur within 100 feet of aquatic features in the northwestern portion of the survey area to ensure proper use of Best Management Practices and avoidance of non-vegetated channels.

BIO-2: Pre-Construction Sensitive Avian Surveys. If construction activities are planned to occur during the coastal California gnatcatcher breeding season (February 15 to September 15), then prior to initiating construction activities, a qualified biologist shall be retained to conduct a minimum of three preconstruction surveys to confirm the presence or absence of the species on the project site and within a 500-foot buffer. The surveys shall begin a maximum of 14 days prior to project construction, and one survey shall be conducted the day immediately prior to the initiation of work. If coastal California gnatcatcher are confirmed to be absent within 500 feet of planned construction areas, then no additional measures shall be required. If coastal California gnatcatcher are confirmed to be present, the following mitigation measures shall be implemented:
a. Avoidance of Breeding Season. If the results of pre-construction surveys determine presence of coastal California gnatcatcher within 500 feet of the planned construction area, then construction activities within 500 feet of active nesting sites shall be completed outside the species breeding 35 seasons. If activities at these locations cannot avoid the species breeding seasons, then Mitigation Measure BIO-2.b shall be implemented.
b. Construction Noise Attenuation. If construction begins during the breeding season (February 15 to September 15), construction noise could affect the breeding of coastal California gnatcatcher. No loud construction noise (exceeding an hourly average of 60 A-weighted decibels, or 3 A-weighted decibels above hourly average ambient noise levels at the nesting site, whichever is higher) may take place within 500 feet of active nesting sites during the breeding seasons (February 15 to September 15).

Noise levels may be mitigated with sound control barriers that are approximately 10 feet in height and placed between construction operations and sensitive habitat. The barriers shall be solid and made of plastic, masonry, wood, fiberglass, steel, or any combination of those materials or other suitable sturdy materials with no cracks or gaps in the walls. Cracks must be filled or caulked. Noise blankets or other covers may be used, provided that they are appropriate to implement noise control. c. Consultation with U.S. Fish and Wildlife Service. If after implementation of Mitigation Measures BIO2.a and BIO-2.b, construction noise levels cannot be reduced below a 60-A-weighted-decibel hourly average from the edge of occupied breeding coastal California gnatcatcher habitat, then the project proponent shall consult with the U.S. Fish and Wildlife Service regarding project-related adverse effects to these species. Consultation shall include a U.S. Fish and Wildlife Service-approved plan to avoid disturbing nesting coastal California gnatcatcher. The plan should include measures to avoid disturbing nesting individuals, including noise monitoring and biological monitoring (i.e., nest monitoring).

BIO-3: Nesting Bird Survey. If construction is proposed during the general bird breeding season (January 15 through August 31), a pre-construction survey shall be performed by a qualified biologist approved by the City (or their designee) to determine if any birds are nesting in or immediately adjacent to the project impact area. The pre-construction nesting bird surveys shall be conducted by a qualified biologist experienced in bird species identification and behavior to ensure that nesting birds are not present on site. The survey shall be conducted no more than 3 days prior to starting project activities. If surveys show that nesting birds are present, a no-work buffer shall be placed around the nest. The buffer size shall be determined by the qualified biologist and may vary based on site conditions and types of work to be conducted. The no-work buffer shall be maintained until the end of the bird breeding season or until surveys by a qualified biologist confirm that fledglings are no longer dependent on the nest. If no nesting birds are detected during pre-construction surveys, no restrictions shall be necessary, and construction may proceed as planned.

BIO-4: Pre-Construction Overwintering Monarch Butterfly Survey. If grubbing, trimming, or clearing of vegetation occurs during the winter (November 1 through February 28), a qualified biologist, as approved by the City, shall perform a pre-construction overwintering monarch butterfly survey no more than 48 hours before the start of vegetation grubbing, trimming, or clearing to confirm that no overwintering monarch butterflies occupy vegetation on the project site. If overwintering monarch butterflies are found during the pre-construction survey, a 50-foot buffer around the occupied vegetation shall be established, and no disturbance shall be allowed within the buffer until a qualified biologist determines that monarch butterflies are no longer occupying the vegetation. If no overwintering monarch butterflies are on the project site, grubbing, trimming, or clearing shall proceed.

BIO-5: Standard Construction Best Management Practices. Standard construction best management practices shall be implemented to avoid potential indirect impacts to sensitive biological resources. These best management practicesshall include but are not limited to the following:
• Dust suppression measures
• Trash containment
• Use of weed-free erosion control products during all phases of construction 36 • Prohibition of activities including staging areas and disposal or temporary placement of excess fill within aquatic resources
• Minimization of erosion and siltation into off-site areas during construction • Construction access via existing developed areas or within the right-of-way of proposed road and drainage improvements
• Storage of soil or fill materials from the project site in developed areas • Location of construction staging areas and equipment re-fueling areas on existing developed areas to avoid impacts to sensitive and aquatic resources
BIO-6: Stormwater Pollution Prevention Plan. Prior to notice to proceed with any construction, including clearing, grubbing, and/or grading, a Stormwater Pollution Prevention Plan shall be prepared, pursuant to National Pollution Discharge Elimination System General Construction Permit (Water Quality Order 99-08-DWQ). The Stormwater Pollution Prevention Plan shall address the potential sources and locations of stormwater contamination, characteristics and impacts of specific contaminants, and temporary and permanent erosion-control practices and shall include water sampling data, construction practices that minimize stormwater contamination, coordination of best management practices with planned construction activities, and compliance with local, state, and federal regulations. The Stormwater Pollution Prevention Plan shall include best management practices that shall be clearly stated on project plans and design documents. The implementation of the Stormwater Pollution Prevention Plan shall protect adjacent aquatic resources, habitats, and sensitive species during construction to the maximum extent practicable with the goal of providing multiple beneficial uses. Post-construction, the project shall incorporate water quality protection design standards that will reduce, capture, and treat runoff from the project site, with an emphasis on protecting the adjacent aquatic resources.

Level of Significance after Mitigation
As discussed in Threshold A, implementation of the project would not result in potentially significant direct impacts to sensitive plant species.

As discussed in Threshold A, implementation of the project could result in potentially significant direct and indirect impacts to sensitive wildlife species and sensitive nesting birds and raptors. With implementation of Mitigation Measures BIO-1, BIO-2, BIO-3, BIO-4, BIO-5, and BIO-6, temporary and permanent direct and indirect impacts from project implementation to sensitive wildlife species, including roosting bats, nesting birds, and raptors, would be reduced to a less than significant level.

As discussed in Threshold B, implementation of the project will not result in permanent or temporary direct impacts to the sensitive vegetation communities that occur on the project site, including Diegan coastal sage scrub (including disturbed) and non-vegetated channel, as these areas will be avoided during construction. However, indirect impacts to sensitive vegetation communities are considered significant and mitigation is required.

Implementation of Mitigation Measure BIO-1 would require delineation of the work area to avoid impacts to sensitive vegetation communities within and outside the project site, implementation of Mitigation Measure BIO5 would prevent potential indirect impacts to sensitive vegetation communities through the use of standard construction best management practices, and Mitigation Measure BIO-6 would require a Stormwater Pollution Prevention Plan to be implemented to reduce impacts to sensitive aquatic resources on the project site.

As discussed in Threshold C, implementation of the project will not result in significant direct impacts to AF-1, AF-2, and AF-3, all potential jurisdictional aquatic resources that occur on the project site because impacts to these areas will be avoided during construction; therefore, no mitigation is required. However, indirect impacts to sensitive vegetation communities are considered significant, and mitigation is required. Implementation of Mitigation Measure BIO-1 would require delineation of the work area to avoid impacts to sensitive aquatic resources within and outside the project site and the presence of a monitor for all work conducted within 100 feet of aquatic resources on the project site. Implementation of Mitigation Measures BIO-5 and BIO-6 would prevent potential indirect impacts to sensitive vegetation communities through the use of standard construction best management practices and the implementation of a Stormwater Pollution Prevention Plan. 37 As discussed in Thresholds D, implementation of the project will not result in significant direct and indirect impacts to wildlife corridors and habitat linkages, and no mitigation is required.

As discussed in Thresholds E and F, the project would not result in conflicts with local policies and ordinances or regional conservation planning, and no mitigation is required.

Cumulative Impacts
The project, as well as other cumulative projects, would be required to conform to federal, state, and local guidelines and provide protection measures as appropriate. Mitigation Measures BIO-1, Qualified Biologist; BIO-2, Pre-Construction Sensitive Avian Surveys, BIO-3, Nesting Bird Survey; BIO-4, Pre-Construction Overwintering Monarch Butterfly Survey; BIO-5, Standard Construction Best Management Practices, and BIO6 Storm Water Pollution Prevention Plan are proposed to reduce project-level direct impacts on sensitive plants and wildlife, migratory birds and raptors, sensitive vegetation communities, and potentially federal and state jurisdictional aquatic resources. Implementation of these mitigation measures would reduce project-level impacts to a less than significant level and ensure that the project would not contribute to cumulatively significant impacts to biological resources. Thus, no significant cumulative impacts would occur from implementation of the project.

Conformance with MSCP Findings
The project is within the Draft Santee MSCP Subarea Plan. The Santee Subarea Plan is currently in development and has not yet been adopted; therefore, the project site is not within a Habitat Conservation Plan and is not subject to the Santee Subarea Plan.

Preparers
Harris & Associates
If you have any questions regarding this biological resources analysis, please do not hesitate to contact Emily Mastrelli at [email protected] or (619) 510-5372.

Sincerely,
Emily Mastrelli (Senior Review) Kelly Otto (Author/Analyst) Principal Biologist/Senior Project Manager Biologist
Attachments
1, Figures
2, Plant and Wildlife Species Observed
References
Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, eds. 2012. The Jepson Manual:

Vascular Plants of California. 2nd ed. Berkeley, California: University of California Press. January.

Calflora. 2023. Calflora Database. Accessed November 2023. http://www.calflora.org/.

City of Santee 2002. Santee General Plan. Updated 2020. Accessed November 2023. General Plan | Santee, CA (cityofsanteeca.gov).

City of Santee. 2023. Notice of Preparation of a DRAFT Program Environmental Impacts Report, Notic of Public Scoping Meeting. Accessed November 2023. https://www.cityofsanteeca.gov/home/ showpublisheddocument/23338.
38 CNPS (California Native Plant Society). 2023. Inventory of Rare and Endangered Plants of California. Online edition, v9-01 1.5. Accessed November 2023. http://www.rareplants.cnps.org/.

CCH (Consortium of California Herbaria). 2023. “Consortium of California Herbarium.” Accessed November 2023. https://ucjeps.berkeley.edu/consortium/about.html.

CDFW (California Department of Fish and Wildlife). 2019. Evaluation of the Petition from the Xerces Society, Defenders of Wildlife, and the Center for Food Safety to List Four Species of Bumble Vees as Endangered Under the California Endangered Species Act. Accessed November 2023. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=166804&inline CDFW. 2023a. California Natural Diversity Database (CNDDB), RareFind 5, commercial version. Accessed November 2023. https://www.wildlife.ca.gov/Data/CNDDB/Maps-and-Data.

CDFW. 2023b. Biogeographic Information and Observation System (BIOS). Database. Accessed November 2023. https://apps.wildlife.ca.gov/bios.

CDFW. 2023c. “Threatened and Endangered Species Protected under the California Endangered Species Act.” Accessed November 2023. https://wildlife.ca.gov/Conservation/CESA.

CDFW. 2023d. “Species of Special Concern.” Accessed November 2023. https://wildlife.ca.gov/Conservation/SSC.

County of San Diego. 1998. County of San Diego MSCP Plan. Final Multiple Species Conservation Program.

Approved August.

Historic Aerials. 2023. Accessed November 2023. NETR Online: Historic Aerials.

Holland, Robert F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California Department of Fish and Game. October.

JepsonOnline. 2023. The Jepson Herbarium. Accessed November 2023. https://ucjeps.berkeley.edu /eflora/filter_keys.html.

Nafis, Gary. 2023. A Guide to the Amphibians and Reptiles of California. Accessed November 2023. https://californiaherps.com/.

NRCS (National Resources Conservation Service). 2023. National Water and Climate Center: WETS Table. Accessed November 2023. http://agacis.rcc-acis.org/?fips=06073.

Oberbauer, Thomas, Meghan Kelly, and Jeremy Buegge. 2008. Draft Vegetation Communities of San Diego County.

Based on Preliminary Descriptions of the Terrestrial Natural Communities of California prepared by Robert F. Holland, PhD, in October 1986. Codes revised by Thomas Oberbauer in February 1996, revised and expanded by Meghan Kelly in August 2006, and further revised and reorganized by Jeremy Buegge in March 2008. Accessed November 2023. https://www.sandiegocounty.gov/content/dam/ sdc/pds/ceqa/Soitec-Documents/Final-EIR-Files/references/rtcref/ch9.0/rtcrefaletters/O14%202014-12- 19_OberbauerTM2008.pdf.

Project Clean Water. 2023. “San Diego River WMA.” Accessed November 2023. https://projectcleanwater.org/watersheds/carlsbad-wma/.

San Diego Natural History Museum. 2012. San Diego County Bird Atlas. Accessed November 2023. https://sdplantatlas.org/BirdAtlas/BirdPages.aspx.

USACE (U.S. Army Corps of Engineers). 1987. Corps of Engineers Wetlands Delineation Manual. Final report.

Wetlands Research Program Technical Report Y-87-1 (online edition). Prepared by Environmental Laboratory, U.S. Army Corps of Engineers, Waterways Experiment Station. Wetlands Research Program.

January. Accessed November 2023. http://www.cpe.rutgers.edu/Wetlands/1987-Army-Corps-WetlandsDelineation-Manual.pdf. 39 USACE. 2023. “TNWs & Navigable Waters in Los Angeles District.” Accessed November 2023. https://www.spl .usace.army.mil/Missions/Regulatory/Jurisdictional-Determination/Navigable-Waterways/.

USDA (U.S. Department of Agriculture). 2019. Web Soil Survey. Natural Resources Conservation Service, Soil Survey Staff.

Last modified July 31. Accessed November 2023. http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm.

USFWS (U.S. Fish and Wildlife Service). 2010. Coastal California Gnatcatcher (Polioptila californica californica) 5- Year Review: Summary and Evaluation. Carlsbad Fish and Wildlife Office.

USFWS. 2023a. National Wetlands Inventory Wetlands Mapper. Accessed November 2023. https://www.fws.gov/wetlands/data/Mapper.html.

USFWS. 2023b. Information for Planning and Consultation (IPaC). Accessed November 2023. https://ecos.fws.gov/ipac/.

USFWS. 2023c. U.S. Fish and Wildlife Service Endangered Species. Accessed November 2023. https://www.fws.gov/endangered/.

USFWS. 2023d. “Assessing the Status of the Monarch Butterfly.” Last updated January 26. Accessed November 2023.

USGS (U.S. Geological Survey). 2023. National Hydrography Data. Accessed November 2023. https://www.arcgis.com/home/webmap/viewer.html?url=https://hydro.nationalmap.gov/arcgis/rest/se rvices/nhd/MapServer&source=sd.

Xerces Society for Invertebrate Conservation (Xerces Society). 2017. “New Guidelines for Protecting California’s Butterfly Groves.” Prepared by Emma Pelton. November 8. Accessed November 2023. https://xerces.org/press/new-guidelines-for-protecting-californias-monarch-butterfly-groves.

Xerces Society 2018. A Petition to the State of California Fish and Game Commission. Accessed November 2023. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=161902&inline 40 This page intentionally left blank.

Attachment 1. Figures
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Imperial
Beach
Chula
Vista
National
City Bonita
Lemon
Grove
Poway
Encinitas
Carlsbad Escondido
Vista Valley
Center
Hidden
Oceanside Meadows
Bonsall
Fallbrook
Rainbow
Jamul Spring
Valley
Alpine Harbison
Canyon
Lakeside
Pine
Valley
El Cajon
Santee
Ramona San Diego
Country
Estates
Julian
Borrego
Springs
Dana
Point
San Juan
Capistrano
Laguna
Beach
Laguna
Hills Coto De
Caza
Newport
Beach Mission
Viejo
Trabuco
Highlands
Temecula
Wildomar
Jacumba
Boulevard
Campo
San Diego
Imperial County
Orange County
San Diego
County
San Diego County
San Diego County
Riverside County

M E X I C O

M E X I C O
P a c i f i c O c e a n
ÄÆ52
ÄÆ94
163 ÄÆ
282 ÄÆ
188 ÄÆ
ÄÆ54
133 ÄÆ
274 ÄÆ
195 ÄÆ
209 ÄÆ
ÄÆ79 111 ÄÆ
ÄÆ56
ÄÆ75
ÄÆ73
125 ÄÆ
ÄÆ86
ÄÆ1 ÄÆ74
ÄÆ74
ÄÆ79 ÄÆ67
ÄÆ76
ÄÆ79
ÄÆ94
ÄÆ78
§¨¦15
§¨¦8
§¨¦5
§¨¦8
§¨¦15
§¨¦5
§¨¦8
§¨¦5
§¨¦215
§¨¦5
§¨¦805
Copyright:(c) 2014 Esri
Project Site
!(^
Date: 10/31/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure1_RegionalLocation.mxd Regional Location
Source: ESRI 2023.
± 0 5 10 Figure 1
Miles
Incorporated Areas
Warmington Santee Residential Project

PRINCE VALIANT DR

CABO CT

MAGNOLIA AVE

SIR LANCELOT DR

EASTHAVEN CT

SUMMIT AVE
Date: 10/31/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure2_ProjectSite.mxd Project Site
Source: Maxar Imagery 2022.
±
0 100 200 Figure 2
Feet
Project Site
100-Foot Buffer
Warmington Santee Residential Project
Date: 10/31/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure3_USGSTopo.mxd USGS Topographic Map
Source: USGS San Vicente Reservoir 7.5 Minute Quadrangle 1971. ± 0 500 1,000 Figure 3
Feet
Project Site
100-Foot Buffer
Warmington Santee Residential Project

PRINCE VALIANT DR

CABO CT SIR LANCELOT DR

PRINCE CHARMING LN

EASTHAVEN CT

EASTHAVEN DR

SUMMIT AVE
Project Site
100-Foot Buffer
Soils
Cieneba-Fallbrook Rocky Sandy Loams
Greenfield Sandy Loam
Ramona Sandy Loam
Date: 10/31/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure4_Soils.mxd Source: USDA 1973; Maxar Imagery 2023.
±
0 100 200
Feet Soils
Source: USDA 1973; Maxar Imagery 2023.

Figure 4
Warmington Santee Residential Project
Date: 10/24/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure5_NWI.mxd Hydrology
Source: USGS 2023; USFWS 2023; Maxar Imagery 2022.
± 0 500 1,000 Figure 5
Feet
Project Site
100-Foot Buffer
Aquatic Resource Type
Riverine
NHD Flowlines
Warmington Santee Residential Project
")
")
")
")
Date: 10/24/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure6_VegetationCommunities.mxd Vegetation Communities and Land Cover Types
Source: Maxar Imagery 2022.
±
0 100 200 Figure 6
Feet
Project Site
100-Foot Buffer
") Culvert
Vegetation Communities and
Land Cover Types
Developed Land
Diegan Coastal Sage
Disturbed Diegan Coastal Sage
Disturbed Habitat
Non-Native Woodland
Non-Vegetated
Warmington Santee Residential Project
ddd
!(
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#*
#*
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#*
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#*
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#* #* #*
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#* #* #*
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#* #*
#* #*
#*
#*
#*
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GF
GF
GF
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#*
#*
GF
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#*
#*
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")
Date: 10/24/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure7_SpeciesPTO.mxd Species with Potential to Occur
Source: CNDDB 2023; USFWS 2023; SanBIOS 2023; Maxar Imagery 2022. ± 0 1,000 2,000 Figure 7
Feet
Project Site
100-Foot Buffer
1-Mile Buffer
Amphibians
GF Western Spadefoot Toad
Birds
!( Bell's Sparrow
!( Coastal Cactus Wren
!( Coastal California Gnatcatcher
!( Grasshopper Sparrow
!( Least Bell's Vireo
!( Southern California Rufous-Crowned Sparrow
Inertebrates
^_ Crotch Bumble Bee
^_ San Diego Fairy Shrimp
Mammals
") Mountain Lion
Plants
#* Palmer's Grapplinghook
#* San Diego Barrel Cactus
#* San Diego Goldenstar
#* Variegated Dudleya
Reptiles
d Blainville's Horned Lizard
d Belding's Orange-Throated Whiptail
d Red-Diamond Rattlesnake
d Two-Striped Garter Snake
Warmington Santee Residential Project
Date: 11/8/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure8_CriticalHabitat.mxd Critical Habitat
Source: USFWS 2007, 2020; Maxar Imagery 2022.
± 0 1,000 2,000 Figure 8
Feet
Project Site
100-Foot Buffer
1-Mile Buffer
Critical Habitat
Hermes copper butterfly
Coastal California gnatcatcher
Warmington Santee Residential Project
")
")
")
")
AF-1
AF-1
AF-2
AF-3
Date: 11/8/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure9_JurisdictionalResources.mxd Potential Jurisdictional Aquatic Resources
Source: Maxar Imagery 2022.
±
0 100 200 Figure 9
Feet
Project Site
100-Foot Buffer
") Culvert
Non-Wetland Water
Warmington Santee Residential Project
")
")
")
")
Date: 11/8/2023 - Last saved by: Randy.Deodat - Path: C:\GIS\Projects\City of Santee\SanteeResidentialWarmington\Map Docs\Bio\Figure10_BioImpacts.mxd Impacts to Biological Resources
Source: Maxar Imagery 2022.
±
0 100 200 Figure 10
Feet
Project Site
100-Foot Buffer
Limits of Impact
") Culvert
Vegetation Communities and
Land Cover Types
Developed Land
Diegan Coastal Sage Scrub
Disturbed Diegan Coastal Sage Scrub
Disturbed Habitat
Non-Native Woodland
Non-Vegetated Channel
Warmington Santee Residential Project
Attachment 2. Plant and Wildlife Species Observed
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Plant Species Observations
Scientific Name Common Name Special Status

EUDICOTS
Apocynaceae - Dogbane family
Greater periwinkle
Spanish gold
Jade plant
Mediterranean cypress
Pine
Fig
Laurel sumac
Peruvian pepper tree
Fennel
Oleander
California sagebrush
Broom baccharis
Starthistle
Artichoke
Telegraph weed
Black mustard
Engelmann's hedgehog cactus
Mission prickly pear
* Vinca major
Asteraceae - Sunflower family
* Grindelia papposa
Crassulaceae - Stonecrop family
* Crassula ovata
Cupressaceae - Cypress family
* Cupressus sempervirens

GYMNOSPERMS
Pinaceae - Pine family
* Pinus sp.

EUDICOTS
Aizoaceae - Fig-marigold family
* Carpobrotus sp.

Anacardiaceae - Sumac Or Cashe
Malosma laurina
* Schinus molle
Apiaceae - Carrot family
* Foeniculum vulgare
Apocynaceae - Dogbane family
* Nerium oleander
Asteraceae - Sunflower family
Artemisia californica
Baccharis sarothroides
* Centaurea sp.
* Cynara cardunculus ssp. cardunculus
Heterotheca grandiflora Brassicaceae
- Mustard family
* Brassica nigra
Cactaceae - Cactus family
Echinocereus engelmannii
* Opuntia ficus-indica Chenopodiaceae
- Goosefoot fami Kochia sp. Fireweed
Scientific Name Common Name Special Status
Dodder
Convolvulaceae - Morning-glory f
Cuscuta sp.

Euphorbiaceae - Spurge family
Croton setigerus Doveweed
Spotted spurge
Castorbean
Acacia
Geranium
Scarlet pimpernel
Red River gum
Gum
Crimson bottlebrush
Olive
Western sycamore
California buckwheat
Spiny redberry
Tamarix
Grape
American century plant
Oat
* Euphorbia maculata
* Ricinus communis
Fabaceae - Legume family
* Acacia sp.

Geraniaceae - Geranium family
Geranium sp.

Myrsinaceae - Myrsine family
* Anagallis arvensis
Myrtaceae - Myrtle family
* Eucalyptus sideroxylon
* Eucalyptus sp.
* Melaleuca citrina
Oleaceae - Olive family
* Olea europaea
Platanaceae - Plane Tree, Sycamo
Platanus racemosa
Polygonaceae - Buckwheat family
Eriogonum fasciculatum Rhamnaceae
- Buckthorn family Rhamnus crocea
Tamaricaceae - Tamarisk family
* Tamarix sp.

Vitaceae - Grape family
Vitis sp.

MONOCOTS
Agavaceae - Century Plant family
* Agave americana
Poaceae - Grass family
Avena sp.

Bromus sp.

Brome
Scientific Name Common Name Special Status
Legend
Special Status:

Federal:

FE = Endangered
FT = Threatened
State:

SE = Endangered
ST =Threatened
*= Non-native or invasive species
CRPR – California Rare Plant Rank
1A. Presumed extinct in California and elsewhere
1B. Rare or Endangered in California and elsewhere
2A. Presumed extinct in California, more common elsewhere 2B. Rare or Endangered in California, more common elsewhere

3. Plants for which we need more information - Review list

4. Plants of limited distribution - Watch list
Threat Ranks
.1 - Seriously endangered in California
.2 – Fairly endangered in California
.3 – Not very endangered in California
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Wildlife Species Observed
Scientific Name Common Name Special Status
Harvester ant
Checkered white
Western side-blotched lizard
California quail
Turkey vulture

INVERTEBRATES
Insects
Formicidae - Ant Family
Pheidole sp.

Moths, Skippers and Butterflies
Pieridae - White and Sulphur Family
Pontia protodice

VERTEBRATES
Reptiles
Phrynosomatidae - Spiny Lizard Family
Uta stansburiana elegans
Birds
Odontophoridae - New World Quail Family
Callipepla californica
Cathartidae - New World Vulture Family
Cathartes aura
Accipitridae - Hawk Family
Buteo lineatus
Columbidae - Pigeon and Dove Family
Zenaida macroura
Trochilidae - Hummingbird Family
Calypte anna
Selasphorus sasin
Picidae - Woodpecker Family
Picoides nuttallii
Tyrannidae - Tyrant Flycatcher Family
Sayornis nigricans
Tyrannus vociferans
Corvidae - Jay and Crow Family
Corvus brachyrhynchos
Corvus corax
Troglodytidae - Wren Family
Troglodytes aedon
Thryomanes bewickii
Red-shouldered hawk
Mourning dove
Anna's hummingbird
Allen's hummingbird
Nuttall's woodpecker
Black phoebe Cassin's
Kingbird
American crow
Common raven
House wren
Bewick's wren
Scientific Name Common Name Special Status
Mimidae - Thrasher Family
Mimus polyglottos
Emberizidae - Sparrow Family
Melozone crissalis
Fringillidae - Finch Family
Haemorhous mexicanus
Carduelis psaltria
Mammals
Leporidae - Hare and Rabbit Family
Sylvilagus audubonii
Sciuridae - Squirrel Family
Spermophilus beecheyi
Northern mockingbird
California towhee
House finch
Lesser goldfinch
Desert cottontail
California ground squirrel
Legend
Special Status:

Federal:

FE = Endangered
FT = Threatened
State:

SE = Endangered
ST =Threatened
CSC = California Species of Special Concern
CFP = California Fully Protected Species
*= Non-native or invasive species

HISTORICAL/ARCHAEOLOGICAL RESOURCES SURVEY REPORT
ASSESSOR’S PARCEL NUMBER 378-190-01-00
10939 Summit Avenue
City of Santee, San Diego County, California
For Submittal to:

City of Santee
Planning and Building Department
10601 Magnolia Avenue
Santee, CA 92071
Prepared for:

Warmington Residential, Southern California Division
3090 Pullman Street
Costa Mesa, CA 92626
Prepared by:

CRM TECH
1016 East Cooley Drive, Suite A/B
Colton, CA 92324
Bai “Tom” Tang, Principal Investigator
Michael Hogan, Principal Investigator
December 9, 2023
CRM TECH Contract No. 4070
Title: Historical/Archaeological Resources Survey Report: Assessor’s Parcel Number 378-190-01-00, 10939 Summit Avenue, City of Santee, San Diego County, California
Author(s): Deirdre Encarnación, Archaeologist/Report Writer Terri Jacquemain, Historian/Architectural Historian
Consulting Firm: CRM TECH
1016 East Cooley Drive, Suite A/B
Colton, CA 92324
(909) 824-6400
Date: December 9, 2023
For Submittal to: City of Santee
Planning and Building Department
10601 Magnolia Avenue
Santee, CA 92071
(619) 258-4100
Prepared for: Matthew Esquivel, Senior Project Manager
Warmington Residential, Southern California Division
3090 Pullman Street
Costa Mesa, CA 92626
(714) 434-4416
USGS Quadrangle: San Vicente Reservoir, Calif., 7.5’ quadrangle; Rancho El Cajon land grant, T15S R1W, San Bernardino Baseline and Meridian
Project Size: Approximately 4.65 acres
Keywords: Western El Cajon Valley, San Diego County; Phase I historical/ archaeological resources survey; Site 4070-1H (temporary designation):
late historic-period buildings at 10939 Summit Avenue; no “historical resources” under CEQA
i

EXECUTIVE SUMMARY
Between October and December, 2023, at the request of Warmington Residential, Southern California Division, CRM TECH performed a cultural resources study on approximately 4.65 acres of rural land in the City of Santee, San Diego County, California. The subject property of the study, Assessor’s Parcel Number 378-190-01-00, is located at 10939 Summit Avenue, in a portion of the Rancho El Cajon land grant lying within Township 15 South, Range 1 West, San Bernardino Baseline and Meridian, as depicted in the United States Geological Survey San Vicente Reservoir, California, 7.5’ quadrangle.

The study is a part of the environmental review process for a proposed residential development project on the property. The City of Santee, as the lead agency for the project, required the study in compliance with the California Environmental Quality Act (CEQA). The purpose of this study is to provide the City with the necessary information and analysis to determine whether the project would cause a substantial adverse change to any “historical resources,” as defined by CEQA, that may exist in or around the project area. In order to identify such resources, CRM TECH initiated a historical/ archaeological resources records search and a Native American Sacred Lands File search, pursued historical background research, and carried out an intensive-level field survey.

As a result of these research procedures, a group of existing buildings on the property, originally constructed in 1974, were recorded into the California Historical Resources Inventory under the temporary designation of Site 4070-1H, pending the assignment of a permanent identification number.

The buildings include a single-family residence, a converted garage, and a studio. The study has identified no persons or events of recognized historic significance in association with the property, nor does any of the buildings exhibit the potential to yield any important historical data or any special merit in design, construction, or aesthetics. As such, Site 4070-1H does not appear eligible for listing in the California Register of Historical Resources and does not meet CEQA’s definition of a “historical resource.”
No other potential “historical resources” were encountered within the project area throughout the course of this study. However, the Sacred Lands File indicates the presence of unspecified Native American cultural resource(s) in the general vicinity of the project area. According to current CEQA guidelines, the identification of potential “tribal cultural resources,” as defined by PRC §21074, is beyond the scope of this study and may be addressed through government-to-government consultations between the City of Santee and pertinent Native American groups, pursuant to Assembly Bill (AB) 52.

Based on these findings, CRM TECH recommends to the City of Santee a tentative determination of No Impact on cultural resources, pending completion of the AB 52 consultation process. No additional cultural resources investigation is recommended for this project unless development plans undergo such changes as to include areas not covered by this study. However, if buried cultural materials are encountered during any earth-moving operations associated with the project, all work within 50 feet of the discovery should be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. Any human remains unearthed during the project will need to be addressed in accordance with Health and Safety Code §7050.5 and Public Resources Code §5097.98. ii

TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................................................................................... i INTRODUCTION ................................................................................................................................ 1 SETTING.............................................................................................................................................. 4 Current Natural Setting..................................................................................................................... 4 Cultural Setting ................................................................................................................................. 5 Prehistoric Context........................................................................................................................ 5 Ethnohistoric Context ................................................................................................................... 6 Historic Context............................................................................................................................ 7 RESEARCH METHODS ..................................................................................................................... 8 Records Search.................................................................................................................................. 8 Native American Sacred Lands File Search ..................................................................................... 8 Historical Background Research....................................................................................................... 9 Field Survey...................................................................................................................................... 9 RESULTS AND FINDINGS................................................................................................................ 9 Records Search.................................................................................................................................. 9 Native American Sacred Lands File Search ................................................................................... 11 Historical Background Research..................................................................................................... 11 Field Survey.................................................................................................................................... 13 MANAGEMENT CONSIDERATIONS............................................................................................ 13 Statutory/Regulatory Guidelines..................................................................................................... 13 Discussion....................................................................................................................................... 14 CONCLUSION AND RECOMMENDATIONS ............................................................................... 14 REFERENCES ................................................................................................................................... 16 APPENDIX 1: Personnel Qualifications............................................................................................ 18 APPENDIX 2: Native American Sacred Lands File Search Results.................................................. 21 APPENDIX 3: California Historical Resources Inventory Record Forms......................................... 24

LIST OF FIGURES
Figure 1. Project vicinity...................................................................................................................... 1 Figure 2. Project area ........................................................................................................................... 2 Figure 3. Recent satellite image of the project area............................................................................. 3 Figure 4. Overview of the project area ................................................................................................ 4 Figure 5. The project area and vicinity in 1891 ................................................................................. 12 Figure 6. The project area and vicinity in 1938-1939........................................................................ 12 Figure 7. The project area and vicinity in 1953 ................................................................................. 12 Figure 8. The project area and vicinity in 1966-1971........................................................................ 12 1 INTRODUCTION
Between October and December, 2023, at the request of Warmington Residential, Southern California Division, CRM TECH performed a cultural resources study on approximately 4.65 acres of rural land in the City of Santee, San Diego County, California. The subject property of the study, Assessor’s Parcel Number 378-190-01-00, is located at 10939 Summit Avenue, in a portion of the Rancho El Cajon land grant lying within Township 15 South, Range 1 West, San Bernardino Baseline and Meridian, as depicted in the United States Geological Survey (USGS) San Vicente Reservoir, California, 7.5’ quadrangle (Figs. 2, 3).

The study is a part of the environmental review process for a proposed residential development project on the property. The City of Santee, as the lead agency for the project, required the study in compliance with the California Environmental Quality Act (CEQA; PRC §21000, et seq.). The purpose of this study is to provide the City with the necessary information and analysis to determine whether the project would cause a substantial adverse change to any “historical resources,” as defined by CEQA, that may exist in or around the project area.

In order to identify such resources, CRM TECH initiated a historical/archaeological resources records search and a Native American Sacred Lands File search, pursued historical background research, and carried out an intensive-level field survey. The following report is a complete account of the methods, results, and conclusion of the study. Personnel who participated in the study are named in the appropriate sections below, and their qualifications are provided in Appendix 1.

Figure 1. Project vicinity. (Based on USGS San Diego, Calif., 120’x60’ quadrangle [USGS 1978]) 2 Figure 2. Project area. (Based on USGS El Cajon and San Vicente Reservoir, Calif., 7.5’ quadrangles [USGS 1996a; 1996b])
3 Figure 3. Recent satellite image of the project area. (Based on Google Earth imagery) 4 SETTING

CURRENT NATURAL SETTING
The City of Santee is situated on the southwestern edge of the Peninsular Ranges geomorphic province, which is bounded by the Transverse Ranges province on the north, the Colorado Desert province on the northeast, and the Pacific Ocean on the west (Jenkins 1980:40-41; Harms 1996:131).

The natural landscape in the Peninsular Ranges province is characterized by steep and elongated valleys and mountain ranges that generally extend northwestward from the southern tip of Baja California (Jahns 1954:Plate 3; Harden 2004:465). The natural environment of the region is typical of the southern California hills and valleys, characterized by a temperate Mediterranean climate with mild, rainy winters and hot, dry summers. In the vicinity of the project location, summer highs reach over 90ºF, and winter lows occasionally dip below freezing. Average annual precipitation is roughly 13 inches, most of which occurs between November and March.

The rectangular-shaped project area is located in the north-central portion of the City of Santee, between the foothills of the Carlton Hills to the west and Eucalyptus Hills to the east. It is bound on the south by a row of single-family residences along Noble Way, on the east by a tract of vacant land, on the north by a rural residential property, and on the west by Summit Avenue (Fig. 3).

Several buildings, structures, and associated features occupy the central portion of the project area (Figs. 3, 4). Among these are a single-family residence, an adjoining converted garage, a modular residence, several sheds of wood or metal construction, a two-story studio, and several wells. There Figure 4. Overview of the project area; view to the northwest from the southeastern corner of the property. (Photograph taken on October 27, 2023)
5 are several large stockpiles of dry vegetation and wood scattered throughout property, especially along the eastern and northern boundaries.

The terrain in the project area is somewhat level but slightly rolling in places (Fig. 4), and the elevations range from approximately 528 feet to 573 feet above mean sea level, with an incline to the northeast. Soils are alluvial sand with small to medium subangular rocks and cobbles. Vegetation observed included a row of eucalyptus trees near the residences; citrus, pepper, pine, and olive trees; and cactus and agave gardens. Other vegetation included flat-top buckwheat, California sagebrush, datura, horehound, and dove mullein. Much of the ground surface in the project area has been disturbed in the past, and heavy equipment tracks were observed in the northeast portion of the property. As a result, little vestige of native landscape remains today.

CULTURAL SETTING
Prehistoric Context
It is widely acknowledged that human occupation in what is now the State of California began at least 12,000 years ago. Recent evidence that the ice-free corridor enabling Paleoindian presence in the Americas emerged much more recently than previously thought suggests a hypothesized Pacific coastal route (Heintzman et al. 2016). In attempting to describe and understand the cultural processes that occurred in the ensuing years, archaeologists have developed a number of chronological frameworks that endeavor to correlate the technological and cultural changes that are observable in archaeological records to distinct time periods. The general framework for the prehistory of the southern Californian coastal region is outlined in Moratto (1984), which is the basis for the following discussion.

Among the earliest evidence of human occupation in coastal southern California was an eroding burial discovered on Santa Rosa Island, among the northern Channel Island chain, with radiocarbon dates clustering around 13,000 B.P., near the end of the Pleistocene epoch (Gamble 2015). Since then, sea level has risen over 200 feet, and many coastal archaeological sites are currently under water (Marshall and Moriarity 1964; ibid.). In coastal San Diego, off the coast of La Jolla, prolific stone artifact assemblages have been recovered at depths of around 40 feet (Marshall and Moriarity 1964).

According to some theories, migration of indigenous groups from the interior deserts of southern California to the already inhabited coastal region took place around 7,500 years ago. Unfortunately, very little is known about the coastal groups during this early period in prehistory. With the immigration of people from the interior, a fusion of regional cultural traits, specifically those pertaining to subsistence procurement, occurred between the newcomers and original coastal inhabitants. The newcomers introduced new plant resources and plant-processing techniques to the coastal groups, and at the same time learned to exploit more intensively the littoral resources.

Archaeological investigations at various sites along the southern Californian coast have uncovered valuable data regarding later time periods in this region. Sites dating to the La Jolla I Period, ca. 5500-3500 B.C., have yielded numerous millingstone tools, scrapers, and flexed burials. The La Jolla II Period, ca. 3500-2000 B.C., is distinguished from the previous period by the presence of 6 cemeteries, discoidals, and various projectile point types. Following this is the La Jolla III Period, ca. 2000-1000 B.C., which is characterized by the influence of Yuman cultural traits from the east on the coastal cultures.

With this second intrusion of eastern groups to the area, increased exploitation of terrestrial food sources further diminished the coastal people’s dependence on littoral resources. With an increasing focus on acorn-processing activities, indigenous groups along the southern Californian coast slowly began settling the interior regions. There was also a shift from inhumation to cremation around 500 B.C., possibly another result of eastern influences.

Ethnohistoric Context
The City of Santee and the San Diego River corridor are a part of the traditional territory of the Kumeyaay people, which extends from the Pacific Ocean on the west and the San Luis Rey River in northern San Diego County to All Saints Bay in northern Baja California and eastwards to include much of present-day Imperial County in the Colorado Desert. Part of the Yuman language stock, the Kumeyaay have been divided by ethnographers into two subgroups based on dialectic differences, with the San Diego River watershed serving as a general boundary between the Ipai in northern San Diego County and the Tipai in southern San Diego County, Imperial Valley, and northern Baja California. The following discussion of their history and culture comes from existing ethnohistorical literature, in particular Kroeber (1925), Strong (1929), Luomala (1978), and Shipek (1991), based primarily on information provided by Kumeyaay informants such as Delfina Cuero and Rosalie Pinto Robertson, while the ethnoecological information is mainly from Anderson (2013).

Prior to European contact, native subsistence practices were defined by the varying surrounding landscape and primarily based on the cultivating and gathering of wild foods, hunting, and fishing, exploiting nearly all of the resources available in a highly developed seasonal mobility system. In inland areas, the predominant food sources included acorns, piñon nuts, other seeds, roots, wild fruits/berries, and wild onions. Medicinal and ceremonial plants such as yerba buena, elderberry, and sages were typically cultivated near villages. Common game animals included deer, rabbits, wood rats, fish, and waterfowl. Coastal Kumeyaay accessed marine resources utilizing tule reed canoes capable of reaching offshore kelp beds, with a wide variety of fish, crustacean, mollusk, and marine mammal remains recovered from coastal archaeological sites.

Both inland and coastal Kumeyaay populations had a variety of technological skills that they used to acquire subsistence, shelter, and medicine or to create ornamental items. Common tools included manos and metates, mortars and pestles, hammerstones, fire drills, awls, arrow straighteners, and stone knives and scrapers. These lithic tools were made from locally sourced material as well as those procured through trade or travel. They also used wood, horn, and bone spoons and stirrers, as well as both woven and ceramic baskets for winnowing, leaching, grinding, transporting, parching, storing, and cooking. However, much of this material cultural, elaborately decorated, does not survive in the archaeological record. As usual, the main items found archaeologically relate to subsistence activities.

As the landscape defined their subsistence practices, the tending and cultivation practices of the Kumeyaay helped shape the landscape. The practice of controlled burning of chaparral and oak woodland areas created an open countryside with more accessible foraging material for animals, 7 which in turn led to more successful hunting (Anderson 2013). It also increased the ease with which plant foods could be gathered and prevented out-of-control wildfires by eliminating dead undergrowth before it accumulated to dangerous levels. Coppicing, or trimming plants to the ground, resulted in straighter growth for basketry and arrow-making materials. Granitic outcroppings were used for pounding and grinding nuts and seeds, which left their mark in the resulting bedrock milling features, the most common archaeological remains found in the region.

As early as 1542, the Kumeyaay were in contact with the Spanish during the expedition of Juan Rodríguez Cabrillo, but it was not until 1769 that the Spaniards took steps to colonize Kumeyaay territory. The Kumeyaay resisted, at times violently, any attempts by the Europeans to alter their way of life, and their conversion to Christianity was a slow and painful process never before experienced by missionaries in this part of the New World. Due to forced labor, dietary deficiencies, introduced diseases, and forceful land grabs and population reduction, Kumeyaay population dwindled rapidly. In recent decades, however, the inception of gaming on tribal lands has brought forth funding used for reservation improvements and educational and cultural programs. There has been a renaissance of Native American activism and cultural revitalization among groups of Kumeyaay descendants, including the reconstruction and utilization of Native technologies, and creating a Kumeyaay Nation flag that has been raised at government buildings throughout San Diego County.

Historic Context
Spanish colonization of Alta California began with the establishment of Mission San Diego de Alcalá in 1769, at what is now Old Town San Diego but was then a Kumeyaay village known as Kosoy. The mission and an associated military outpost, the San Diego presidio, faced tremendous resistance, at times violently, as mentioned above (Mission San Diego History n.d.). Initially religious services were held outdoors or in “available rooms” at the presidio (ibid.). The mission was moved further up the San Diego River in 1774 while the presidio remained in its original location (ibid.).

Upon the missions’ relocation, the first church building was constructed, described as “a church of poles, roofed with tules and measured 17x53 feet” (Engelhardt 1920). This building was burned to the ground during a Kumeyaay revolt and was rebuilt as an adobe building with thatched roof two years later (ibid.). A larger church building was constructed in 1780, and this time the tule-thatched roof was covered with a “mass of earth” to better protect against flaming arrows during revolts (ibid.). It was also at Mission San Diego that El Camino Real was established. This road, translated as “the royal road” or “the King’s road,” stretches 600 miles in California along which each of the 21 California Missions are located, ending at Mission San Francisco Solano in present-day Sonoma (Mission San Diego History n.d.).

Beginning in 1834, during secularization of the mission system, former mission rancherías throughout Alta California were surrendered to the Mexican government, and subsequently divided and granted to various prominent citizens in the province. In San Diego County, a number of large grants of the confiscated lands of Mission San Diego de Alcala were issued by Governor Pio Pico of Alta California (City of El Cajon n.d.). Among these, some 48,800 acres were granted to Doña Maria Antonio Estudillo, wife of Don Miguel de Pedrorena. The land grant, known as Rancho El 8 Cajón, included the present-day communities of Santee, Lakeside, Bostonia, El Cajon, and part of Grossmont (ibid.).

As California was annexed and entered into statehood, most of these large land grants were parceled and sold to American settlers, ranchers, and speculators. In 1877, George A. Cowles purchased 4,000 acres in what would become the City of Santee to develop vineyards and commercial trees such as pomegranate and magnolia (City of Santee n.d.). Initially known as Cowleston, the town was linked to the Cuyamaca Railroad at Cowles Station. Cowles passed away in 1887, and three years later his widow Jennie Cowles married Milton Santee, a realtor and surveyor (ibid.). In 1891, the post office began to operate under the name Santee, and by 1893 the town, school, and school district had also changed their names to Santee (ibid.).

In the immediate vicinity of the project area, Hosmer P. McKoon purchased 9,543 acres in 1885, which he named Fanita Rancho in honor of his wife Fannie (City of Santee n.d.). Initially used for agriculture, cattle, and dairy, parts of the ranch were eventually divided and sold (ibid.). By 1898, the prominent Scripps family purchased a 7,000-acre parcel of the ranch, which they used to raise cattle and develop a country resort (ibid.). In 1958, 4,300 acres were purchased by the Carlton Company development firm, bringing about the end of Santee as a rural agricultural and cattle community and the beginning of its housing boom. Exploding in population from fewer than 2,000 residents in 1950 to 25,750 in 1970, the City of Santee would incorporate in 1980 (City of Santee n.d.). Today the city is home to over 50,000 residents (USCB n.d.).

RESEARCH METHODS

RECORDS SEARCH
The historical/archaeological resources records search for this study was provided by the South Coastal Information Center (SCIC) of the California Historical Resources Information System on October 25, 2023. Located on the campus of San Diego State University, SCIC is the State of California’s official cultural resource records repository for the County of San Diego. During the records search, SCIC staff examined the center’s digital maps, records, and databases for previously identified cultural resources and existing cultural resources reports within a one-mile radius of the project area. Previously identified cultural resources include properties designated as California Historical Landmarks or Points of Historical Interest, as well as those listed in the National Register of Historic Places, the California Register of Historical Resources, or the California Historical Resources Inventory.

NATIVE AMERICAN SACRED LANDS FILE SEARCH
On October 18, 2023, CRM TECH submitted a written request to the State of California Native American Heritage Commission (NAHC) for a records search in the commission’s Sacred Lands File. The NAHC is the State of California’s trustee agency for the protection of “tribal cultural resources,” as defined by California Public Resources Code §21074, and is tasked with identifying and cataloging properties of Native American cultural value, including places of special religious, spiritual, or social significance and known graves and cemeteries throughout the state. The response from the NAHC is summarized below and attached to this report in Appendix 2. 9 HISTORICAL BACKGROUND RESEARCH
Historical background research for this study was conducted by CRM TECH archaeologist Deirdre Encarnación with the assistance of project historian/architectural historian Terri Jacquemain.

Sources consulted during the research included published literature in local and regional history, archival records of the County of San Diego, historical maps of the Santee area, and aerial/satellite photographs of the project vicinity. Among the maps consulted were USGS topographic maps dated 1893-1996, which are accessible at the websites of the U.S. Bureau of Land Management and the USGS. The aerial and satellite images, taken between 1953 and 2023, are available from the Nationwide Environmental Title Research (NETR) Online website and through the Google Earth software.

FIELD SURVEY
On October 27, 2023, Deirdre Encarnación conducted the intensive-level field survey of the project area. During the survey, Encarnación walked parallel north-south 10 meter (approximately 33 feet) transects across the entire project area except where the transects were blocked by the buildings. In this way, the ground surface in the project area was systematically and carefully examined for any evidence of human activities dating to the prehistoric or historic period (i.e., 50 years ago or older).

The buildings and associated structures were then inspected closely and photographed to document their architectural and structural characters.

Ground visibility was good (80-85%) on most of the property at the time of the survey despite the scattered low-lying vegetation but was poor (30-35%) in areas of dry pine needle duff and other vegetation accumulation, reduced to nearly zero under the vegetation stockpiles. In light of the history of past disturbances to the ground surface due to construction activities and residential use since the 1970s, the limitation of visibility in these relatively small portions of the project area was not considered a significant hindrance to the survey effort.

RESULTS AND FINDINGS

RECORDS SEARCH
According to SCIC records, the project area was included, partially or entirely, in the scopes of three previous cultural resources surveys completed between 2016 and 2020. Among these, two studies that focused on the Fanita Rancho property covered a small sliver of the current project area along the northern edge. The third study, which included the entire project area, was an overview study for an update of the Padre Dam Municipal Water District Master Plan. Most of the project area, therefore, had evidently not been surveyed for cultural resources at an intensive level prior to this study.

The SCIC notes that a small, linear portion of a previously recorded site of historical origin, designated 37-037786 in the California Historical Resources Inventory, overlaps the northern edge of the project area. Encompassing a total of 2,600 acres, the site represented the portion of the 10 Fanita Rancho that remained undivided as of 2018 (Rincon Consultants 2018). When the site was recorded in that year, only seven historical features were documented, such as a granite quarry, a rock dam, an asphalt paved road, and a refuse scatter, along with two isolated artifacts, all of them of unknown age (ibid.). At the time, the site was found not to be eligible for listing in the National Register of Historic Places or the California Register of Historical Resources (ibid.).

No other cultural resources were previously recorded within or adjacent to the project area. Outside of project boundaries but within the one-mile scope of the records search, SCIC records indicate at least 29 other surveys were carried out on various tracts of land and linear features between 1974 and 2017. These and other similar studies nearby resulted in the identification of 20 historical/ archaeological sites and 14 isolates (i.e., localities with less than three artifacts) within the records search scope, as listed below in Table 1.

Table 1. Previously Recorded Cultural Resources within the Scope of the Records Search Primary No. Trinomial Description
37-004885 CA-SDI-004885 Flakes, tools, and midden
37-008336 CA-SDI-008336 Milling slicks, mortar, basins, lithic scatter 37-008345 CA-SDI-008345 Bedrock milling features (BMF), lithic and ceramic scatter 37-012099 CA-SDI-012099 Lithic and groundstone scatter
37-012244 CA-SDI-012244 BMF with 15 milling surfaces
37-012245 CA-SDI-012245 3 BMF with 10 milling surfaces
37-012246 CA-SDI-012246 BMF with 3 milling surfaces
37-012247 CA-SDI-012247 Rock room with one pottery sherd 37-026520 Isolate: single milling slick
37-026521 Isolate: single milling slick
37-027128 CA-SDI-017743 BMF with 3 slicks and one mano
37-027131 CA-SDI-017746 BMF
37-027132 CA-SDI-017747 BMF and one mano
37-027137 CA-SDI-017752 Three brownware sherds
37-027144 Isolate: two secondary quartz flakes
37-027146 Isolate: unifacially worked mano
37-036702 Isolate: lithic flake
37-036720 Isolate: lithic flake
37-036722 Isolate: lithic flake
37-036732 Isolate: 2 lithic flakes
37-036734 Isolate: lithic flake
37-036735 Isolate: lithic flake
37-036736 Isolate: lithic flake
37-036737 Isolate: lithic flake
37-036738 Isolate: lithic flake
37-036739 Isolate: lithic flake and core
37-036744 CA-SDI-022180 BMF with lithic scatter
37-036745 CA-SDI-022181 BMF with one slick
37-036746 CA-SDI-022182 BMF with one slick
37-036748 CA-SDI-022184 BMF with two slicks
37-036749 CA-SDI-022185 BMF with one slick
37-036750 CA-SDI-022186 Five BMF
37-036752 CA-SDI-022188 Lithic scatter
37-037785 CA-SDI-022503 Four BMF
37-037786 CA-SDI-022504 Fanita Rancho: refuse scatter, roads, dams, quarry, fence 11 With the exception of the Fanita Rancho (37-037786), all of the previously recorded cultural resources within the one-mile radius were of prehistoric (i.e., Native American) origin, and all of them were situated at higher elevations on the undisturbed hillsides to the west, north, and east of the project location. Fifteen of the sites and two of the isolates were bedrock milling features with shallow slicks ranging in number from one to 15. Several of these also had associated artifacts, such as lithic flakes, manos, and ceramic sherds. The majority of the isolates were lithic flakes. Other than the Fanita Rancho, none of the sites or isolates was found in the immediate vicinity of the project area. Therefore, none of them requires further consideration during this study.

NATIVE AMERICAN SACRED LANDS FILE SEARCH
In response to CRM TECH’s inquiry, the NAHC reported in a letter dated November 20, 2023, that the Sacred Lands File yielded positive results for Native American cultural resources in the project vicinity but provided no further details. The NAHC recommended that local Native American groups be consulted for additional information and provided a referral list of 19 individuals associated with 13 local Native American groups who may have knowledge of such resources. The NAHC’s reply is attached to this report in Appendix 2 for reference by the City of Santee in future government-to-government consultations with the pertinent tribal groups.

HISTORICAL BACKGROUND RESEARCH
Historical sources consulted for this study show that the project area, remained vacant and undeveloped until the late historic period (Figs. 6-9). In the 1890s, the San Diego, Cuyamaca and Eastern Railway, running along the San Diego River some two miles to the south of the project location, and two winder roads, each more than a mile from the project location, were the only notable human-made features nearby (Fig. 5). By the 1930s, a dirt road passing through or near the southwestern corner of the property had become the first human-made feature to appear in the immediate vicinity of the project area, apparently leading to a quarry in the foothills to the north (Figs. 6, 7). In the mid-1950s, agriculture was the primary land use in the vicinity, and the entire project area was under cultivation in 1953 (NETR Online 1953). A decade later, all farming operations had evidently ceased in and around the project area, leaving the property largely unused until the 1970s (NETR Online 1964-1978).

San Diego County real property records indicate that the subject parcel was owned by the Quillin family at least by circa 1974, when the main residence, the original garage, and the studio on the property were constructed (NETR Online 1971-1978; County Assessor n.d.). A series of intrafamily transfers occurred during the 1980s, beginning in 1987 when Gerald R. Quillin and his thenwife Sandra filed quitclaims deeding ownership to his mother, Helen Quillin (County Assessor n.d.).

One year later, Gerald, then listed as an “unmarried man,” received an intra-family transfer, life estate, and remainder grant deed for the property from Helen (ibid.).

By the 1980s, a modular building had been placed in close proximity to the main residence (NETR Online 1978-1984). Eventually, in 2004, the property would be deeded into the Quillin Family Trust by Gerald (County Assessor n.d.). During the ensuing years, the property would be further improved upon with additional features such as large cactus and agave gardens, and sheds (ibid.; NETR Online 1984-2020). Outside but adjacent to the project boundary, the small suburban 12 Figure 5. The project area and vicinity in 1891. (Source:

USGS 1893)
Figure 6. The project area and vicinity in 1938-1939.
(Source: USGS 1939)
Figure 7. The project area and vicinity in 1953. (Source:

USGS 1953a; 1953b)
Figure 8. The project area and vicinity in 1966-1971.
(Source: USGS 1967; 1971)
13 residential tract to the south was developed on former agricultural land in 2020-2022, but the overall rural character of the surrounding area has remained largely unchanged (Google Earth 1994-2023).

FIELD SURVEY
During the field survey, the circa 1974 buildings on the property, including the main residence, the converted garage, and the two-story studio were recorded into the California Historical Resources Inventory and designated temporarily as Site 4070-1H, pending the assignment of a permanent identification number by the SCIC. The modest Ranch-style residence and converted garage are both wood-framed buildings with composite shingle roofs and tan stucco exterior walls. The studio has narrow wood siding on the exterior walls and a front-gable roof. Detailed descriptions and additional information on these buildings are presented in the standard site record forms attached to this report as Appendix 3. No other potential “historical resources” of prehistoric or historic-era origin were found. A small amount of scattered refuse was observed on the surface, but all of the items appear to be modern in origin.

As noted above, the SCIC records search indicates that a small portion of Site 37-037786, the Fanita Rancho, was previously recorded across the northern edge of the project area. A close review of the record forms for the site suggests that while technically the site boundary crosses the northeast corner of the current project area, no historical features associated with the Fanita Rancho were recorded within or adjacent to the project boundaries (Rincon Consultants 2018). The field survey confirmed the absence of any such features or artifacts within the project area.

MANAGEMENT CONSIDERATIONS

STATUTORY/REGULATORY GUIDELINES
CEQA establishes that “a project that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment” (PRC §21084.1). “Substantial adverse change,” according to PRC §5020.1(q), “means demolition, destruction, relocation, or alteration such that the significance of a historical resource would be impaired.” As defined by PRC §5020.1(j), “‘historical resource’ includes, but is not limited to, any object, building, site, area, place, record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California.” More specifically, CEQA guidelines state that the term “historical resources” applies to any such resources listed in or determined to be eligible for listing in the California Register of Historical Resources, included in a local register of historical resources, or determined to be historically significant by the lead agency (Title 14 CCR §15064.5(a)(1)-(3)). Regarding the proper criteria for the evaluation of historical significance, CEQA guidelines mandate that “generally a resource shall be considered by the lead agency to be ‘historically significant’ if the resource meets the criteria for listing on the California Register of Historical Resources” (Title 14 CCR §15064.5(a)(3)). A resource may be listed in the California Register if it meets any of the following criteria:
14 (1) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
(2) Is associated with the lives of persons important in our past. (3) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values. (4) Has yielded, or may be likely to yield, information important in prehistory or history. (PRC §5024.1(c))

DISCUSSION
In summary of the research results outlined above, Site 4070-1H, consisting of the groups of 1970s buildings at 10939 Summit Avenue, is the only potential “historical resource” identified in the project area. In light of their late historical origin (i.e., more than 50 years of age), the group of buildings was recorded into the California Historical Resources Inventory for permanent documentation, but none of them, individually or collectively, appears to meet any of the criteria for listing in the California Register of Historical Resources.

Under Criteria 1 and 2, historical background research has not identified any persons or events of recognized historic significance in close association with the property. Under Criterion 3, the modest Ranch-style and vernacular buildings do not represent important examples of any style, type, period, or region, nor do they appear to embody the work of a prominent architect, designer, or builder. Under Criterion 4, the buildings do not demonstrate the potential to yield any important data for the study of 1970s history, a period that is well documented.

Based on these considerations, the present study concludes that Site 4070-1H does not appear to qualify as a “historical resource” under CEQA provisions, and no other potential “historical resources” were encountered within or adjacent to the project area. While a small portion of Site 37- 037786, the Fanita Rancho, was previously recorded across the northern edge of the project area, the site was previously determined not to be eligible to the California Register (Rincon Consultants 2018), and no features or artifacts associated with the site was found during this survey.

Although more than 30 prehistoric archaeological sites and isolates have been recorded within a onemile radius of the project area, all of those localities were found on undisturbed hillsides in the surrounding area, a typical pattern for prehistoric cultural resources in southern California, in a different geographic setting from that of the project location. The Sacred Lands File maintained by the NAHC indicates the presence of unspecified Native American cultural resource(s) in the general vicinity of the project area. According to current CEQA guidelines, the identification of potential “tribal cultural resources,” as defined by PRC §21074, is beyond the scope of this study and may be addressed through government-to-government consultations between the City of Santee and pertinent Native American groups, pursuant to Assembly Bill (AB) 52.

CONCLUSION AND RECOMMENDATIONS
In conclusion, the group of late-historic-period buildings recorded within the project area as Site 4070-1H do not meet CEQA’s definition of a “historical resource,” and no other potential “historical resources” were encountered throughout the course of this study. However, the final clearance of 15 the project under cultural resources provisions of CEQA may require the completion of governmentto-government consultations by the City of Santee with local tribes in order to address potential Based on these findings, CRM TECH presents the following recommendations to the City of Santee:
• A tentative determination of No Impact on cultural resources appears to be appropriate for the proposed project, pending the completion of government-to-government consultations with local Native American groups by the City under AB 52 provisions to address potential “tribal cultural resource(s).”
• No additional cultural resources investigations will be necessary for the project unless development plans undergo such changes as to include areas not covered by this study. • If buried cultural materials are encountered during any earth-moving operations associated with the project, all work within 50 feet of the discovery should be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. • Any human remains unearthed during the project will need to be addressed in accordance with Health and Safety Code §7050.5 and Public Resources Code §5097.98. 16 REFERENCES
Anderson, M. Kat
2013 Tending the Wild: Native American Knowledge and the Management of California’s Natural Resources. University of California Press, Berkeley.

County Assessor (San Diego)
n.d. Public records kiosk, accessed at San Diego County Assessor’s office, November 30, 2023.

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n.d. Discover El Cajon: History. https://www.elcajon.gov/discover-el-cajon/history.

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Engelhardt, Fr. Zephyrin
1920 San Diego Mission. The James H. Barry Company, San Francisco. https://play.google. com/books/reader?id=P2ELAAAAYAAJ&pg=GBS.PA22.

Gamble, Lynn (editor)
2015 First Coastal Californians. SAR Press, Santa Fe, New Mexico.

Google Earth
1994-2023 Aerial photographs of the project vicinity; taken in 1994, 1996, 2002-2006, and 2008- 2023. Available through the Google Earth software.

Harden, Deborah R.
2004 California Geology. Prentice Hall, Upper Saddle River, New Jersey.

Harms, Nancy S.
1996 A Precollegiate Teachers Guide to California Geomorphic/Physiographic Provinces.

National Association of Geoscience Teachers, Far West Section, Concord, California.

Heintzman, Peter D., Duane Froese, John W. Ives, and Beth Shapiro 2016 Bison phylogeography constrains dispersal and viability of the Ice Free Corridor in western Canada. Proceedings of the National Academy of Sciences 113(29):8057-8063 https://www.pnas.org/doi/epdf/10.1073/ pnas.1601077113.

Jahns, R.H.
1954 Geology of the Peninsular Range Province, Southern California and Baja California. In R.H. Jahns (ed.): Geology of Southern California; Chapter II. California Division of Mines Bulletin 170, Part 3. San Francisco.

Jenkins, Olaf P.
1980 Geomorphic Provinces Map of California. California Geology 32(2):40-41.

Kroeber, Alfred L.
1925 Handbook of the Indians of California. Bureau of American Ethnology Bulletin 78.

Washington, D.C.

Luomala, Katharine
1978 Tipai-Ipai. In Robert F. Heizer (ed.): Handbook of North American Indians, Vol. 8:

California; pp. 592-609. Smithsonian Institution, Washington, D.C.

Marshall, Neil F., and James R. Moriarity
1964 Principles of Underwater Archaeology. Pacific Discovery Vol. 17.

Mission San Diego History
n.d. Five Churches of Mission San Diego. https://www.missionsandiegohistory.org/fivechurches-of-mission-san-diego. 17 Moratto, Michael J.
1984 California Archaeology. Academic Press, Orlando, Florida.

NETR (Nationwide Environmental Title Research) Online
1953-2020 Aerial photographs of the project vicinity; taken in 1953, 1964, 1966, 1968, 1971, 1978, 1980-1991, 1993-2000, 2002, 2003, 2005, 2009, 2010, 2012, 2014, 2016, 2019, and 2020. http://www.historicaerials.com.

Rincon Consultants
2018 California Historical Resources Inventory record forms, Site 37-037786 (CA-SDI22504). On file, South Coastal Information Center, San Diego State University, San Diego.

Shipek, Florence Connolly
1991 Delfina Cuero: Her Autobiography, an Account of Her Last Years, and Her Ethnobotanic Contributions. Ballena Press, Menlo Park, California.

Strong, William Duncan
1929 Aboriginal Society in Southern California. University of California Publications in American Archaeology and Ethnology No. 26. Reprinted by Malki Museum Press, Banning, California, 1972.

USCB (United States Census Bureau)
n.d. QuickFacts: Santee City, California. https://www.census.gov/quickfacts/fact/ table/santeecitycalifornia/PST045222.

USGS (United States Geological Survey, U.S. Department of the Interior) 1893 Map: El Cajon, Calif. (15’, 1:62,500); surveyed in 1891. 1939 Map: El Cajon, Calif. (15’, 1:62,500); surveyed in 1938-39. 1953a Map: El Cajon, Calif. (7.5’, 1:24,000); aerial photographs taken in 1953, field checked in 1955.
1953b Map: San Vicente Reservoir, Calif. (7.5’, 1:24,000); aerial photographs taken in 1953, field checked 1955.
1967 Map: El Cajon, Calif. (7.5’, 1:24,000); aerial photographs taken in 1966, field checked in 1967.
1971 Map: San Vicente Reservoir, Calif. (7.5’, 1:24,000); 1955 edition photorevised in 1971. 1978 Map: San Diego, Calif. (120’x60’, 1:250,000); 1958 edition revised. 1996a Map: El Cajon, Calif. (7.5’, 1:24,000); imagery taken in 1996. 1996b Map: San Vicente Reservoir, Calif. (7.5’, 1:24,000); imagery taken in 1996. 18 APPENDIX 1:

PERSONNEL QUALIFICATIONS

PRINCIPAL INVESTIGATOR, HISTORY/ARCHITECTURAL HISTORY
Bai “Tom” Tang, M.A.

Education
1988-1993 Graduate Program in Public History/Historic Preservation, University of California, Riverside.
1987 M.A., American History, Yale University, New Haven, Connecticut. 1982 B.A., History, Northwestern University, Xi’an, China. 2000 “Introduction to Section 106 Review,” presented by the Advisory Council on Historic Preservation and the University of Nevada, Reno.
1994 “Assessing the Significance of Historic Archaeological Sites,” presented by the Historic Preservation Program, University of Nevada, Reno.

Professional Experience
2002- Principal Investigator, CRM TECH, Riverside/Colton, California. 1993-2002 Project Historian/Architectural Historian, CRM TECH, Riverside, California. 1993-1997 Project Historian, Greenwood and Associates, Pacific Palisades, California. 1991-1993 Project Historian, Archaeological Research Unit, University of California, Riverside. 1990 Intern Researcher, California State Office of Historic Preservation, Sacramento. 1990-1992 Teaching Assistant, History of Modern World, University of California, Riverside. 1988-1993 Research Assistant, American Social History, University of California, Riverside. 1985-1988 Research Assistant, Modern Chinese History, Yale University. 1985-1986 Teaching Assistant, Modern Chinese History, Yale University. 1982-1985 Lecturer, History, Xi’an Foreign Languages Institute, Xi’an, China.

Cultural Resources Management Reports
Preliminary Analyses and Recommendations Regarding California’s Cultural Resources Inventory System (with Special Reference to Condition 14 of NPS 1990 Program Review Report). California State Office of Historic Preservation working paper, Sacramento, September 1990.

Numerous cultural resources management reports with the Archaeological Research Unit, Greenwood and Associates, and CRM TECH, since October 1991. 19 PRINCIPAL INVESTIGATOR, ARCHAEOLOGY
Michael Hogan, Ph.D., RPA (Registered Professional Archaeologist) Education
1991 Ph.D., Anthropology, University of California, Riverside. 1981 B.S., Anthropology, University of California, Riverside; with honors. 1980-1981 Education Abroad Program, Lima, Peru.
2002 “Section 106—National Historic Preservation Act: Federal Law at the Local Level,” UCLA Extension Course #888.
2002 “Recognizing Historic Artifacts,” workshop presented by Richard Norwood, Historical Archaeologist.
2002 “Wending Your Way through the Regulatory Maze,” symposium presented by the Association of Environmental Professionals.
1992 “Southern California Ceramics Workshop,” presented by Jerry Schaefer. 1992 “Historic Artifact Workshop,” presented by Anne Duffield-Stoll.

Professional Experience
2002- Principal Investigator, CRM TECH, Riverside/Colton, California. 1999-2002 Project Archaeologist/Field Director, CRM TECH, Riverside, California. 1996-1998 Project Director and Ethnographer, Statistical Research, Inc., Redlands, California. 1992-1998 Assistant Research Anthropologist, University of California, Riverside. 1992-1995 Project Director, Archaeological Research Unit, U.C. Riverside. 1993-1994 Adjunct Professor, Riverside Community College, Mt. San Jacinto College, U.C.

Riverside, Chapman University, and San Bernardino Valley College. 1991-1992 Crew Chief, Archaeological Research Unit, U.C. Riverside. 1984-1998 Project Director, Field Director, Crew Chief, and Archaeological Technician for various southern California cultural resources management firms.

Research Interests
Cultural Resource Management, Southern Californian Archaeology, Settlement and Exchange Patterns, Specialization and Stratification, Culture Change, Native American Culture, Cultural Diversity.

Cultural Resources Management Reports
Principal investigator for, author or co-author of, and contributor to numerous cultural resources management study reports since 1986.

Memberships
Society for American Archaeology; Society for California Archaeology; Pacific Coast Archaeological Society; Coachella Valley Archaeological Society. 20 PROJECT HISTORIAN/ARCHITECTURAL HISTORIAN
Terri Jacquemain, M.A.

Education
2004 M.A., Public History and Historic Resource Management, University of California, Riverside.
2002 B.S., Anthropology, University of California, Riverside. 2001 Archaeological Field School, University of California, Riverside. 1991 A.A., Riverside Community College, Norco Campus.

Professional Experience
2003- Historian/Architectural Historian/Report Writer, CRM TECH, Riverside/Colton, California.
2002-2003 Teaching Assistant, Religious Studies Department, University of California, Riverside.
2002 Interim Public Information Officer, Cabazon Band of Mission Indians. 2000 Administrative Assistant, Native American Student Programs, University of California, Riverside.
1997-2000 Reporter, Inland Valley Daily Bulletin, Ontario, California. 1991-1997 Reporter, The Press-Enterprise, Riverside, California.

PROJECT ARCHAEOLOGIST/REPORT WRITER
Deirdre Encarnación, M.A.

Education
2003 M.A., Anthropology, San Diego State University, California. 2000 B.A., Anthropology, minor in Biology, with honors; San Diego State University, California.
2021 Certificate of Specialization, Kumeyaay Studies, Cuyamaca College/KCC. 2001 Archaeological Field School, San Diego State University. 2000 Archaeological Field School, San Diego State University.

Professional Experience
2004- Project Archaeologist/Report Writer, CRM TECH, Riverside/Colton, California. 2001-2003 Part-time Lecturer, San Diego State University, California. 2001 Research Assistant for Dr. Lynn Gamble, San Diego State University. 2001 Archaeological Collection Catalog, SDSU Foundation. 21 APPENDIX 2

NATIVE AMERICAN SACRED LANDS FILE

SEARCH RESULTS
STATE OF CALIFORNIA Gavin Newsom, Governor

NATIVE AMERICAN HERITAGE COMMISSION