— Santee City Council, August 27, 2025 (part 2 of 3)

The Draft Santee MSCP Subarea Plan Preserve boundaries are a result of the City of Santee’s efforts to refine and expand the MHPA boundaries, to better define conservation priorities within the City of Santee, and to formulate an HCP under the MSCP Plan. Because the Draft Santee MSCP Subarea Plan is still in development, portions of the subarea plan may still change, including hardline Preserve areas and Covered Species. The Project site is entirely outside of the Preserve areas identified in the Draft Santee MSCP Subarea Plan (City of Santee 2023). However, as shown in Figure 1 of the BTR for this Project (see Appendix C of this Draft EIR), the Project site is adjacent to Preserve areas associated with the San Diego River corridor, as identified in the Draft Santee MSCP Subarea Plan (City of Santee 2023).

4.3.3 Thresholds of Significance
The significance criteria used to evaluate Project impacts to biological resources are based on CEQA Guidelines Appendix G. Potential Project-related impacts analyzed in this section account for biological resources that occur or have the potential to occur on the Project site. According to CEQA Guidelines Appendix G, a significant impact related to biological resources would 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 Wildlife 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 Wildlife or U.S. Fish and Wildlife Service.

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.

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-13
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.

4.3.4 Impacts Analysis
A. Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Direct Impacts
Less-than-Significant Impact with Mitigation Incorporated. No special-status plant or wildlife species were observed within the Project site during surveys, and due to lack of habitat, none are expected to occur. Therefore, no direct impacts would occur to special-status plant or wildlife species with Project implementation.

Direct impacts to nesting birds, specifically nesting bird habitat, protected under Section 3503 of the California Fish and Game Code, could occur within areas of the Project site mapped as non-native woodland or within the existing ornamental trees as part of the current development’s landscaping. Project implementation of Mitigation Measure (MM) BIO-1 (Pre-Construction Nesting Bird Survey) would reduce potential direct impacts to nesting birds to a lessthan-significant level through performance of a nesting bird survey if construction occurs during the nesting season.

Additionally, all trees removed as part of Project implementation, that could potentially provide nesting habitat for birds, would be replaced as directed by MM-BIO 4, which is required as part of Threshold E, below. Therefore, with implementation of mitigation, direct impacts to nesting birds or their habitat would be less than significant.

The Project site does not occur within federally designated critical habitat for plant or wildlife species. Therefore, no direct impacts would occur to critical habitat with Project implementation.

Indirect Impacts
Less-than-Significant Impact with Mitigation Incorporated. Project implementation has the potential to result in indirect impacts to special-status wildlife species, specifically least Bell’s vireo, yellow-breasted chat, and yellow warbler, as well as special-status plant species occurring within 500 feet of the Project site.

Construction-Related: Potential short-term or temporary indirect impacts to least Bell’s vireo, yellow-breasted chat, yellow warbler, and special-status plant species resulting from construction activities include the release of chemical pollutants; adverse effects from noise, vibration, and increased human presence; and night-time lighting.

These potential construction-related indirect impacts would be potentially significant absent mitigation.

Project implementation of MM BIO-1 (Pre-Construction Nesting Bird Survey) would reduce potential indirect impacts from construction noise to a less-than-significant level through performance of a nesting bird survey if construction occurs during the nesting season. If nesting least Bell’s vireo, yellow-breasted chat, and/or yellow warbler are identified, an adequate buffer will be implemented to ensure that effects from noise, vibration, and human presence are minimized. In addition, implementation of MM-BIO-2 (Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) will minimize indirect impacts to least Bell’s vireo, yellow-breasted chat, yellow warbler, and special-status plant species through biological monitoring, requirement of a Worker Environmental Awareness Training that will cover the special-status resources and mitigation requirements for the Project, delineation of Project boundaries, requiring that all vehicles

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-14
and equipment be serviced in designated staging areas, and ensuring that construction will not be conducted at night. Project construction would be limited to the City’s allowable construction hours of 7:00 a.m. and 7:00 p.m. and is not anticipated to require lighting. In the event that construction lighting is required, it would be properly shielded to avoid spillover effects (MM-BIO-2).

Implementation of MM-BIO-1 (Pre-Construction Nesting Bird Survey) and MM-BIO-2 (Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of construction-related indirect impacts to least Bell’s vireo, yellow-breasted chat, yellow warbler, and special-status plant species to less than significant with mitigation incorporated.

Long-Term: Potential long-term, indirect impacts that could result from Project implementation to suitable foraging and nesting habitat for least Bell’s vireo, yellow-breasted chat, and yellow warbler and special-status plants include chemical releases, such as oils and grease from vehicles that could degrade habitat; increased invasive plant species that may degrade habitat; night-time lighting; and trampling of vegetation and soil compaction by humans, which could affect soil moisture, water penetration, surface flows, and erosion. These potential long-term indirect impacts would be potentially significant absent mitigation. Because the Project site is located within the City of Santee’s industrial zone, there are existing ambient noise levels that were measured by Dudek and are included in Table 2 of the Project’s Noise Technical Report (Appendix K to this Draft EIR). The measured baseline outdoor ambient noise level for areas north of the Project site (i.e. occurring within the San Diego River corridor) were established to be between 50 to 56 dBA. Figures 5 and 6 of the Project’s Noise Technical Report (Appendix K to this Draft EIR) show that the maximum predicted operational noise levels will be in the 35 to 45 dBA range for areas occurring north of the Project site within the San Diego River. Installation of an eight-foot-tall noise barrier along the northern perimeter of the Project site is proposed as a feature of the Project. With installation of this noise barrier, Project-related operational noise levels are predicted to be less than the current existing ambient sound levels in the areas occurring north of the Project site within the San Diego River by a factor of 5 to 21 dBA. Additionally, all operational noise levels comply with the City of Santee’s noise threshold for industrial land uses and are below the 60 dBA, which is typically used as the noise threshold for wildlife species). Therefore, long-term operational noise impacts are less than significant.

The Project site currently contains sources of artificial nighttime light that are typical of a drive-in movie theatre use.

In addition, streetlights are present along Wheatlands Court and North Woodside Avenue to the west, south, and east, all of which are sources of nighttime light as well. Other exterior artificial light sources in the immediate vicinity of the Project site include nearby industrial uses bordering the site to the south, east, and west. There are no existing sources of light or glare from the San Diego River abutting the Project site to the north, however, typical residential light sources in the residential neighborhood to the north of the Project site and San Diego River may be visible from the Project site. Implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of long-term indirect impacts from proposed lighting as it would be designed consistent with the requirements of Section 13.30.030(B) of the Santee Municipal Code, which states that lighting shall be shielded, or recessed, and directed downward and away from adjoining properties.

Implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of long-term indirect impacts to least Bell’s vireo, yellow-breasted chat, yellow warbler, and special-status plant species by requiring measures to ensure runoff is not altered from existing conditions and toxicants are not discharged, preparation of landscaping plans that will emphasize native species and not include species from the California Invasive Plant Council’s Invasive Plant Inventory, and incorporation of barriers to prevent unauthorized public access to open space areas associated

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-15
with the San Diego River corridor. Therefore, long-term indirect impacts to special-status species would be reduced to less than significant with mitigation incorporated.

B. Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service?
Direct Impacts
Less-than-Significant Impact. The entire approximately 13.5-acre Project site would be directly impacted with Project implementation. Acreages for each vegetation community or land cover type permanently impacted are provided in Table 4.3-2, below, and their spatial distribution is shown in Figure 4.3-2, Impacts.

Table 4.3-2. Impacts to Vegetation Communities and Land Covers within the Project Site
Vegetation Community/
Land Cover Type Holland/Oberbauer Code Permanent Impact (Acres) Non-Native Grassland 42200 0.27
Non-Native Woodland 79000 0.51
Disturbed Habitat 11300 0.02
Urban/Developed 12000 12.70
Total 13.49
Note: Totals may not sum due to rounding.

A total of approximately 13.5 acres would be permanently impacted with Project implementation (see Figure 4.3-2).

No riparian habitat would be impacted with Project implementation. Communities listed by CDFW as high priority for inventory (i.e., State Rank [S] 1, 2, or 3) are considered sensitive and typically require mitigation (CDFW 2023).

There are no sensitive vegetation communities with CDFW state rankings of 1, 2, or 3 within the Project site.

Permanent impacts to non-native grassland would typically require mitigation to comply with regional MSCP conservation goals (City of San Diego 1998). However, because the Project’s impact to non-native grassland is very minimal (0.27 acres) and this vegetation community is highly disturbed and dominated by annual forb species, impacts to non-native grassland would be less than significant and no mitigation measures are required.

Indirect Impacts
Less-than-Significant Impact with Mitigation Incorporated. Project implementation has the potential to result in indirect impacts to sensitive vegetation communities occurring adjacent to the Project site.

Construction-Related: Sensitive vegetation communities may be indirectly impacted during construction of the proposed Project. Potential short-term or temporary indirect impacts to sensitive vegetation communities resulting from construction activities include inadvertent spillover impacts, including unintentional clearing, trampling, or grading outside of the Project footprint; generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; the release of chemical pollutants; and the adverse effect of invasive plant species. These potential construction-related, indirect impacts to sensitive vegetation communities would be potentially significant absent mitigation.

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-16
Implementation of MM-BIO-2 (Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of construction-related indirect impacts to sensitive vegetation communities to less than significant with mitigation incorporated.

Long-Term: Potential long-term, indirect impacts that could result from development near sensitive vegetation communities include chemical releases, such as oils and grease from vehicles that could degrade habitat; increased invasive plant species that may degrade habitat; and trampling of vegetation and soil compaction by humans, which could affect soil moisture, water penetration, surface flows, and erosion. These potential long-term indirect impacts to sensitive vegetation communities would be potentially significant absent mitigation.

Implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of long-term indirect impacts by requiring measures to ensure runoff is not altered from existing conditions and toxicants are not discharged, preparation of landscaping plans that will emphasize native species and not include species from the California Invasive Plant Council’s Invasive Plant Inventory, and incorporation of barriers to prevent unauthorized public access to open space areas associated with the San Diego River corridor. Therefore, long-term indirect impacts to sensitive vegetation communities would be reduced to less than significant with mitigation incorporated.

C. Would the Project 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? Direct Impacts
No Impact. No jurisdictional aquatic resources, including state or federally protected wetlands, occur within the Project site. The edge of the Project site occurs at least 20 to 30 feet in elevation higher than and approximately 70 to 100 feet south of the riparian (willow forest) and wetland (freshwater marsh) vegetation communities associated with the San Diego River. Therefore, no direct impacts to state or federally protected wetlands are anticipated within Project implementation and no permits under Section 401 or 404 of the Clean Water Act are required.

Indirect Impacts
Less-than-Significant Impact with Mitigation Incorporated. Project implementation has the potential to result in indirect impacts to jurisdictional aquatic resources occurring within 500 feet of the Project site associated with the San Diego River.

Construction-Related: Jurisdictional aquatic resources of the United States/state may be indirectly impacted during construction. Potential short-term or temporary indirect impacts to jurisdictional aquatic resources resulting from construction activities could include the generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; the release of chemical pollutants; and unintentional clearing, trampling, or grading outside of the proposed construction zone. Construction-related indirect impacts to jurisdictional aquatic resources would be potentially significant absent mitigation. 0#
#0
#0
#0
#0
#0
#0
#0
#0
0#
0#
0#
0#
0#
0#
Woodside Ave
N Woodside Ave
Hillc
re
e
k
Wa
y
H
i
l
l
c
re
e
k
Ln
Mission Park Ct
Wheatlands Ct
Bloomdale St
Jeremy St
Steven
s
R
d
Collinwood Dr
Bird St
Mission Park Pl
Isaac St
Shadow Hill Rd
Meadow Terrace Dr
Wheatlands
Rd
Taffy Ln Hartley Rd
Hillcreek Rd
Abraham Way
Wheatlands Ave
Ä67
S a n D i e g o R i v e r
Project Boundary
Study Area (500 Foot - Buffer)
Permanent Impacts
Sensitive Species Observation
0#
coastal California gnatcatcher (Polioptila
californica californica)
#0
least Bell's vireo (Vireo bellii pusillus)
0# yellow-breasted chat (Icteria virens)
0# yellow warbler (Setophaga petechia)
Vegetation Communities and Land Covers
Coastal and Valley Freshwater Marsh
Diegan Coastal Sage Scrub
Non-Native Grassland
Non-Native Woodland
Southern Arroyo Willow Riparian Forest
Southern Cottonwood-Willow Riparian
Forest
Southern Willow Scrub
Disturbed Habitat
Open Water
Urban/Developed
Impacts
SOURCE: SanGIS, Open Street Maps
Date: 5/9/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\BTR\BTR_figures.aprx 0 100 200 n Feet
Figure 4.3-2 Figure 4.3-2
Impacts
Palisade Santee Commerce Center Project

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-18

INTENTIONALLY LEFT BLANK

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-19
Implementation of MM-BIO-2 (Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize construction-related indirect impacts through biological monitoring, requirement of Worker Environmental Awareness Training that will cover the special-status resources and mitigation requirements for the Project, delineation of Project boundaries, implementation of standard dust control measures, development of a Stormwater Pollution Prevention Plan, and requiring all vehicles and equipment to be serviced in designated staging areas. Therefore, construction-related indirect impacts to jurisdictional aquatic resources would be less than significant with mitigation incorporated.

Long-Term: Potential long-term indirect impacts that could result from development near jurisdictional aquatic resources of the United States/state include pollutants that could degrade water quality and habitat; increased invasive plant species that may degrade habitat; and trampling of vegetation and soil compaction by humans, which could affect soil moisture, water penetration, surface flows, and erosion. Long-term indirect impacts to jurisdictional aquatic resources would be potentially significant absent mitigation.

Implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize long-term indirect impacts by requiring measures to ensure runoff is not altered from existing conditions and toxicants are not discharged, preparation of landscaping plans that will emphasize native species and not include species from the California Invasive Plant Council’s Invasive Plant Inventory, and incorporation of barriers to prevent unauthorized public access to areas with state and federally protected waterways. Therefore, long-term indirect impacts to jurisdictional aquatic resources would be less than significant with mitigation incorporated.

D. Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Direct Impacts
No Impact. The Project site is currently developed as a parking lot and drive-in theater and is not mapped as a core area or habitat linkage under the MSCP (City of San Diego 1998). Therefore, the Project site does not function as a wildlife corridor or habitat linkage. For these reasons, no direct impacts are anticipated to wildlife corridors and/or habitat linkages with Project implementation.

Indirect Impacts
Less-than-Significant Impact with Mitigation Incorporated. Project implementation has the potential to result in indirect impacts to the San Diego River corridor, which occurs adjacent to the Project site and may function as a local wildlife corridor.

Construction-Related: The San Diego River wildlife corridor may be indirectly impacted during construction of the proposed Project. Potential short-term or temporary indirect impacts to biological resources within the San Diego River wildlife corridor resulting from Project construction activities include inadvertent spillover impacts, including unintentional clearing, trampling, or grading outside of the Project footprint; generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; the release of chemical pollutants; and the adverse effects of invasive plant species. These potential construction-related, indirect impacts to the San Diego River wildlife corridor would be potentially significant absent mitigation.

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-20
Implementation of MM-BIO-2 (Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of construction-related indirect impacts to the San Diego River wildlife corridor to less than significant with mitigation incorporated. Project construction would be limited to the City’s allowable construction hours of 7:00 a.m. and 7:00 p.m. and is not anticipated to require lighting. In the event that construction lighting is required, it would be properly shielded to avoid spillover effects (MM-BIO-2).

Long-Term: Potential long-term, indirect impacts that could result from development near the San Diego River wildlife corridor include chemical releases such as oils and grease from vehicles that could degrade habitat; increased invasive plant species that may degrade habitat; night-time lighting; and trampling of vegetation and soil compaction by humans, which could affect soil moisture, water penetration, surface flows, and erosion. These potential long-term indirect impacts to the San Diego River wildlife corridor would be potentially significant absent mitigation. Because the Project site is located within the City of Santee’s industrial zone, the Project’s operational noise (e.g., manufacturing, HVAC, truck loading and unloading, etc.) would not change the existing noise levels in the surrounding vicinity and all operational noise levels comply with the City of Santee’s noise threshold for industrial land uses. Therefore, long-term operational noise impacts are less than significant.

The Project site contains sources of artificial nighttime light that are typical of a drive-in movie theatre use. In addition, streetlights are present along Wheatlands Court and North Woodside Avenue to the west, south, and east, all of which are sources of nighttime light as well. Other exterior artificial light sources in the immediate vicinity of the Project site include nearby industrial uses bordering the site to the south, east, and west. There are no existing sources of light or glare from the San Diego River abutting the Project site to the north, however, typical residential light sources in the residential neighborhood to the north of the Project site and San Diego River may be visible from the Project site. Implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of long-term indirect impacts from the Project’s lighting as it would be designed consistent with the requirements of Section

13.30.030(B) of the Santee Municipal Code, which states that lighting shall be shielded, or recessed, and directed downward and away from adjoining properties.

Implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources) would minimize the effect of long-term indirect impacts to the San Diego River wildlife corridor by requiring measures to ensure runoff is not altered from existing conditions and toxicants are not discharged, preparation of landscaping plans that will emphasize native species and not include species from the California Invasive Plant Council’s Invasive Plant Inventory, and incorporation of barriers to prevent unauthorized public access to open space areas associated with the San Diego River corridor. Therefore, long-term indirect impacts to wildlife corridors would be reduced to less than significant with mitigation incorporated.

E. Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less-than-Significant Impact with Mitigation Incorporated. The City of Santee’s Urban Forestry Ordinance contains tree-related policies, regulations, and generally accepted standards for planting, trimming, and removing trees on public property and public rights-of-way (Santee Municipal Code, Section 8.06 [City of Santee 2020]). The ordinance gives the City of Santee control of all trees, shrubs, and other plantings in any street, park, public right-of-way, landscape maintenance district or easement, or other City-owned property. City of Santee staff review of development plans for the City-owned and maintained property would ensure that the proposed landscaping and maintenance requirements conform to the Urban Forestry Ordinance. The proposed site plan would require removal of 109 trees,

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-21
encroachment upon 24 trees, and preservation of 7 trees. As such, tree replacement would occur at a 1:1 mitigation ratio with 15-gallon trees, as directed by MM-BIO-4. Additionally, measures to minimize damage to the encroachment and preserved trees, as well as recommendations for long-term maintenance and care for trees that will be retained on site, would be included in the Project’s Landscape Plan. Therefore, the proposed Project would comply with the Urban Forestry Ordinance, and impacts would be less than significant with mitigation incorporated.

In the Conservation Element of the City of Santee General Plan, biological resources are discussed, and specific objectives and policies are presented (City of Santee 2003). The proposed Project does not conflict with any objectives or policies as presented in the Conservation Element of the Santee General Plan. Therefore, impacts to local policies and ordinances would be less than significant and no mitigation measures are required.

F. Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? MSCP Plan and Draft Santee MSCP Subarea Plan
Less-than-Significant Impact. The Project site is within the boundaries of the MSCP Plan (City of San Diego 1998).

The Draft Santee MSCP Subarea Plan would serve as an HCP under the MSCP Plan pursuant to Section 10(a)(1)(B) of FESA, and as an NCCP pursuant to the California Natural Community Conservation Planning Act of 1991. The Draft Santee MSCP Subarea Plan, once finalized, will contribute to the regional MSCP for preservation, mitigation for impacts, and conservation of sensitive biological resources within San Diego County. The Draft Santee MSCP Subarea Plan is also intended to provide cumulative mitigation for impacts to Covered Species within the City of Santee’s jurisdiction, as long as projects are consistent with and covered by provisions of the Santee MSCP Subarea Plan, and to ensure sufficient biological resources are conserved to assist in the conservation and recovery of Covered Species under the MSCP.

Although the Draft Santee MSCP Subarea Plan has not yet been approved or permitted, it is used as the guidance document for projects occurring within the City of Santee. All Project impacts would occur outside of the Draft Santee MSCP Subarea Plan Preserve area. However, as shown in Figure 1 of the BTR for this Project (see Appendix C of this Draft EIR), the Project site is adjacent to Preserve areas associated with the San Diego River corridor as identified in the Draft Santee MSCP Subarea Plan. MM-BIO-2 and MM-BIO-3 are proposed to prevent any indirect impacts to special-status species, sensitive vegetation communities, and jurisdictional aquatic resources associated with the San Diego River Preserve. Furthermore, Project implementation would not conflict with the provisions of the MSCP Plan or Draft Santee MSCP Subarea Plan, nor would it prevent the Draft Santee MSCP Subarea Plan from being approved or compromise continued implementation of the MSCP in San Diego County.

Therefore, impacts related to HCPs would be less than significant and no mitigation measures are required.

4.3.5 Mitigation Measures and Level of Significance
After Mitigation
A. Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Areas of the Project site mapped as non-native woodland or existing ornamental trees could potentially provide nesting habitat for birds protected under Section 3503 of the California Fish and Game Code. If construction occurs

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-22
during the nesting bird season, a pre-construction nesting bird survey could reduce potential direct impacts to nesting birds. Implementation of MM-BIO-1 would reduce impacts to a less than significant level. Additionally, all trees removed as part of Project implementation would be replaced as directed by MM-BIO-4, as required under Threshold E.

Potential short-term or temporary indirect impacts to least Bell’s vireo, yellow-breasted chat, yellow warbler, and special-status plant species resulting from construction activities include the release of chemical pollutants; adverse effects from noise, vibration, and increased human presence; and night-time lighting. Implementation of MM-BIO-2 would reduce impacts to a less than significant level.

Potential long-term, indirect impacts that could result from Project implementation to suitable foraging and nesting habitat for least Bell’s vireo, yellow-breasted chat, and yellow warbler and special-status plants include chemical releases, such as oils and grease from vehicles that could degrade habitat; increased invasive plant species that may degrade habitat; and trampling of vegetation and soil compaction by humans, which could affect soil moisture, water penetration, surface flows, and erosion. Implementation of MM-BIO-3 would reduce impacts to a less than significant level.

MM-BIO-1 Pre-Construction Nesting Bird Survey. Construction within all potential nesting resource areas within the Project site (i.e., non-native woodland areas and ornamental trees) and areas of the Project site within 500 feet of the San Diego River should be avoided during the migratory bird nesting season (typically January 1 through September 30). If construction activities (i.e., grading, tree removal, external construction involving heavy equipment generating noise in excess of 60dBA (leq)) must occur during the bird nesting season, an avian nesting survey of all potential nesting resource areas (e.g., non-native woodland areas and ornamental trees) within the Project site and areas of the San Diego River within 500 feet of all impact areas must be conducted to determine the presence/absence of special-status species, protected migratory birds, and active nests. The avian nesting survey shall be performed by a qualified wildlife biologist within 14 days prior to the start of construction and one more survey pass within 24 hours of initiation of construction activities in accordance with the Migratory Bird Treaty Act and California Fish and Game Code Sections 3503, 3503.5, and 3513. If construction activities are on hold for more than 30 days, then pre-construction surveys would need to be reinitiated. If an active bird nest is found, the nest shall be flagged and mapped on the construction plans, along with an appropriate buffer established around the nest, which will be determined by the biologist based on the species’ sensitivity to disturbance (typically 300 feet for passerines and 500 feet for raptors and specialstatus species), existing nearby conditions (e.g., natural habitat versus roads or existing noisy activities), existing buffering features (e.g., topography, tall and dense trees, buildings), legal status of species (i.e., listed versus non-listed), general sensitivities of the species (e.g., disturbance tolerant or urban versus non disturbance tolerant), and other variables. The nest area shall be avoided until the nest is vacated and the juveniles have fledged. The nest area shall be demarcated in the field with flagging and stakes or construction fencing. On-site construction monitoring shall also be conducted when an active nest buffer is in place. No Project activities shall encroach into established buffers without the consent of a monitoring biologist. The buffer shall remain in place until it is determined that the nestlings have fledged and the nest is no longer active.

MM-BIO-2 Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources. Prior to approval of grading plans and issuance of a grading permit, construction plans and conditions of approval shall include the

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-23
following to address potential indirect impacts to special-status species occurring within all suitable habitat associated with the San Diego River corridor (i.e., within 500 feet of the Project site):
▪ Biological Monitoring. A qualified Project biologist approved by the City of Santee shall monitor ground-disturbing and vegetation clearing activities for the duration of the Project to ensure that practicable measures are being employed to avoid incidental disturbance of habitat, species of concern, and other sensitive biological resources outside the Project footprint. Once ground-disturbing and vegetation clearing activities are complete, the Project biologist shall conduct weekly checks to inspect construction fencing and ensure that all applicable requirements from the mitigation measures are being upheld. ▪ Worker Environmental Awareness Training. Prior to grading, a pre-construction meeting shall be required that includes a training session for Project personnel by a qualified biologist. The training shall include (1) a description of the species of concern and its habitats; (2) the general provisions of the applicable regulations pertaining to biological resources, including the Endangered Species Act and the Clean Water Act; (3) the need to adhere to the provisions of the Endangered Species Act, the Clean Water Act, and other applicable regulations; (4) the penalties associated with violating the provisions of the Endangered Species Act, Clean Water Act, and other applicable regulations; (5) the general measures that are being implemented to conserve the species of concern as they relate to the Project; and (6) the access routes to and Project site boundaries within which the Project activities must be accomplished. Additionally, the training shall include the measures and mitigation requirements for the applicable resources. Copies of the mitigation measures and any required permits from the resource agencies shall be made available to construction personnel. ▪ Delineation of Property Boundaries. Before beginning activities that would cause impacts, the contractor shall, in consultation with the biological monitor, clearly delineate the boundaries with fencing, stakes, or flags, consistent with the grading plan, within which the impacts will take place. All impacts outside the fenced, staked, or flagged areas shall be avoided, and all fencing, stakes, and flags shall be maintained until the completion of impacts in that area. In addition, any avoided environmental resources shall be clearly delineated. Prior to implementing construction activities, the biological monitor shall verify that the flagging clearly delineates the construction limits and any sensitive environmental resources to be avoided. ▪ Standard Dust Control Measures. Standard dust control measures as per the San Diego County Air Pollution Control District shall be implemented to reduce impacts on nearby plants and wildlife. Measures include controlling speed to 15 miles per hour or less on unpaved roads, replacing ground cover in disturbed areas as quickly as possible, frequently watering active work sites, installing shaker plates, and suspending excavation and grading operations during periods of high winds.
▪ Stormwater Pollution Prevention Plan. Prior to issuance of a grading permit for construction, the applicant shall submit a Stormwater Pollution Prevention Plan (SWPPP) to the City of Santee that specifies best management practices to prevent all construction pollutants from contacting stormwater, with the intent of keeping sedimentation or any other pollutants from moving off site and into receiving waters. The requirements of the SWPPP shall be incorporated into design specifications and construction contracts. Best management practice categories employed on site shall include erosion control, sediment control, and non-stormwater good

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-24
housekeeping. Best management practices recommended for the construction phase shall include, but not be limited to, the following:
- Limiting grading to the minimum area necessary for construction, operation, and decommissioning of the Project.
- Limiting vegetation disturbance/removal to the maximum extent practicable. - Implementing fiber rolls and sandbags around drainage areas and the site perimeter. - Stockpiling and disposing of demolition debris, concrete, and soil properly. - Installing a stabilized construction entrance/exit and stabilizing disturbed areas. - Installing proper protections for fueling and maintaining equipment and vehicles. - Managing waste, aggressively controlling litter, and implementing sediment controls. - Stabilizing soil in disturbed areas through revegetation.

The following water quality measures shall be included in the SWPPP:
▪ Erodible fill material shall not be deposited into water courses. Brush, loose soils, or other similar debris material shall not be stockpiled within the stream channel or on its banks. ▪ The Project shall be designed to avoid the placement of equipment and personnel within the stream channel or on sand and gravel bars, banks, and adjacent upland habitats used by target species of concern, as feasible. Project activities that cannot be conducted without placing equipment or personnel in sensitive habitats shall be timed to avoid the breeding season of riparian species.
▪ Water pollution and erosion control plans shall be developed and implemented in accordance with the Regional Water Quality Control Board.
▪ Minimize Spills of Hazardous Materials. All vehicles and equipment shall be maintained in proper condition to minimize the potential for fugitive emissions of motor oil, antifreeze, hydraulic fluid, grease, or other hazardous materials. Hazardous spills shall be immediately cleaned up and the contaminated soil shall be properly handled and disposed of at a licensed facility. Servicing of construction equipment shall take place only at a designated staging area.

The staging area will be located on the south side of the Project site, away from the San Diego River, and no stockpiles will be allowed adjacent to the San Diego River corridor. ▪ Wildlife Hazards. The following measures shall be implemented to ensure that wildlife do not become trapped, entangled, injured, or poisoned by construction activities:
- Structures in which wildlife may become trapped (e.g., open pipes, pits, trenches) shall be tightly covered at the end of each work day. If covering the structure is not possible, an escape ramp shall be provided to allow any wildlife that falls in to safely escape. - Debris piles, construction materials, equipment, and other items that may be used as wildlife refuge shall be inspected for wildlife at the start of each work day and prior to disturbance. If wildlife is discovered, it shall either be moved out of harm’s way by a qualified biologist or allowed to move off of the Project site on its own. - Nets and mesh shall be made of loose weave material that is not fused at the intersections of the weave because nets with welded weaves present an entanglement risk. - Toxic materials and garbage shall be removed from the work site and safely stored or disposed of at the end of each work day.

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-25
▪ Invasive Weeds. To reduce the spread of invasive plant species, landscape plants shall not be on the most recent version of the California Invasive Plant Council’s Invasive Plant Inventory (http://www.cal-ipc.org/ip/inventory/index.php).
▪ Night Work. All construction activities shall be conducted during the daytime, and lights shall not be kept on overnight in the construction area, as practicable. If night lighting is required during construction activities, all exterior lighting along undeveloped land shall be fully shielded and directed downward in a manner that will prevent light spillage or glare into the adjacent open space.

MM-BIO-3 Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources. Prior to approval of grading plans and issuance of a grading permit, construction plans and conditions of approval shall include the following to address potential indirect impacts to special-status species occurring within all suitable habitat associated with the San Diego River corridor (i.e., within 500 feet of the Project site):
▪ Runoff: Future development within 500 feet of suitable habitat for special-status species shall incorporate measures, including measures required through the National Pollutant Discharge Elimination System, to ensure that the quantity and quality of runoff discharged is not altered in an adverse way when compared with existing conditions. In particular, measures such as an infiltration system designed to capture and treat stormwater pollutants, consistent with commercial/industrial developments and associated parking lots, and including oil, grease, metals, trash, and debris, shall be put in place to avoid discharge of untreated surface runoff from developed and paved areas into proposed open space or suitable habitat for specialstatus species. Stormwater systems shall be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant materials, or other elements that might degrade or harm biological resources or ecosystem processes. This can be accomplished using a variety of methods, including natural detention basins, grass swales, or mechanical trapping devices.

Regular maintenance shall occur to ensure effective operation of runoff control systems. ▪ Lighting: Project lighting would be designed consistent with the requirements of Section

13.30.030(B) of the Santee Municipal Code. Night lighting shall be directed away from proposed open space and/or suitable habitat for special-status species to protect species from direct night lighting. Shielding, including use of light controlling devices such as light guards, shall be incorporated in Project designs to ensure that ambient lighting is not increased. ▪ Invasive Species: Landscape Plans shall incorporate native species that occur in the region.

Invasive, non-native plant species listed on the most recent California Invasive Plant Council’s Invasive Plant Inventory (https://www.cal-ipc.org/plants/inventory/) with a rating of moderate or high shall not be included in landscaping.
▪ Barriers: The proposed Project shall incorporate barriers, where appropriate, to minimize unauthorized public access, domestic animal predation, illegal trespass, or dumping in open space and/or suitable habitat for special-status wildlife (e.g. San Diego River corridor). Such barriers may include native landscaping, rocks/boulders, fencing, walls, signage, and/or other appropriate mechanisms.

MM-BIO-4 Tree Replacement, Encroachment, and Preservation. Prior to approval of grading plans and issuance of a grading permit, construction plans, conditions of approval, and the Project’s

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-26
Landscape Plan shall include the following to address tree removal, encroachment into protected zone, and retained trees:
▪ Replacement: The proposed site plan would require removal of 109 trees. Tree replacement shall occur at a 1:1 mitigation ratio with 15-gallon trees and be included in the Project’s Landscape Plan, which shall also include recommendations for long-term maintenance and care for regulated trees that will be retained on site. ▪ Encroachment into Protected Zone and Retained Trees: The Project would encroach upon 24 trees and preserve 7 trees. As such, the recommendations provided in the Tree Protection Measures from the Arborist Report for the Palisade Santee Commerce Center Project (prepared by Dudek in April 2023) designed to mitigate impacts from construction encroachment into the protected zone of the preserved and encroached upon trees shall be implemented. These Tree Protection Measures are consistent with best management practices for tree protection on construction sites and would help minimize impacts to preserved and encroached trees. These measures shall be implemented prior to, during, and following construction. This includes measures such as exclusion fencing and worker training to avoid direct impacts to trees, and measures such as irrigation and monthly inspections by a certified arborist to promote the longterm health of retained trees.

Fish and Wildlife Service?
No direct impacts to riparian habitat would occur with Project implementation, and no mitigation measures are required. Direct impacts would occur to 0.27 acres of non-native grassland, which is considered a sensitive vegetation community under the Draft Santee MSCP Subarea Plan. However, because the impact area is minimal (0.27 acres) and the community within the Project site is highly disturbed and dominated by annual forb species, impacts to sensitive vegetation communities would be less than significant and no mitigation measures are required.

Indirect impacts to riparian habitat or other sensitive communities would be reduced to less than significant with implementation of MM-BIO-2 and MM-BIO-3.

D. Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
No direct impacts to wildlife corridors would occur with Project implementation, and no mitigation measures are required. Indirect impacts to wildlife corridors would be reduced to less than significant with implementation of MM-BIO-2 and MM-BIO-3.

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-27
E. Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
The proposed site plan would require removal of 109 trees, encroachment upon 24 trees, and preservation of 7 trees. As such, tree replacement would occur at a 1:1 mitigation ratio with 15-gallon trees, as directed by MM-BIO-4. The proposed Project would comply with the Urban Forestry Ordinance, and impacts would be less than significant with implementation of MM-BIO-4.

The proposed Project does not conflict with any objectives or policies as presented in the Conservation Element of the City of Santee General Plan (City of Santee 2003). Therefore, impacts to local policies and ordinances would be less than significant and no mitigation measures are required.

F. Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? MM-BIO-2 and MM-BIO-3 are proposed to prevent any indirect impacts to special-status species, sensitive vegetation communities, and jurisdictional aquatic resources associated with the San Diego River as identified in the Draft Santee MSCP Subarea Plan (City of Santee 2023). Furthermore, Project implementation would not conflict with the provisions of the MSCP Subregional Plan or Draft Santee MSCP Subarea Plan, nor would it prevent the Draft Santee MSCP Subarea Plan from being approved or compromise continued implementation of the MSCP in San Diego County. Therefore, impacts to HCPs would be less than significant and no mitigation measures are required.

4.3 – BIOLOGICAL RESOURCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.3-28

INTENTIONALLY LEFT BLANK

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-1

4.4 Cultural, Tribal Cultural, and
Paleontological Resources
This section describes the existing cultural (archaeological and built environment), tribal cultural, and paleontological resources conditions of the Palisade Santee Commerce Center Project (Project) site, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if needed to reduce or avoid significant impacts, related to implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7 of Chapter 2 of this EIR), the following analysis is based, in part, on the following sources:
▪ Archaeological Resources Inventory Report, prepared by Dudek in December 2023 (Appendix E) ▪ Historical Assessment Of The 10990 North Woodside Avenue Property Santee, California 92071 prepared by Scott A. Moomjian, Esq., Historic Property Consultant ("Historical Assessment") in March 2025 (Appendix F)
▪ Geotechnical Engineering Investigation, prepared by NorCal Engineering in March 2024 (Appendix G) ▪ Paleontological Resources Memorandum, prepared by Dudek in May 2024 (Appendix H)

4.4.1 Existing Conditions

4.4.1.1 Study Area
The Property contains a former drive-in theatre/motion picture (film) complex, previously known as the “Santee Drive-In Theatre,” (the “Former Drive-In Theatre “), which was originally built in 1962 and expanded in 1976. The site largely consists of eight (8) main components: two (2) drive-in motion picture screens (Screen #1 and Screen #2); one (1) Concessions Building; two (2) parking lots (one for each movie screen); two (2) Ticket Booths; and one (1) Entrance Sign.

The motion picture screens, and parking lots, are located along the northwest and southeast property elevations; the Concessions Building is located toward the center of the property, the Ticket Booths are located along the east elevation of the parcel, and the Entrance Sign is located toward the southeast elevation. Today, the site serves as an open, surface parking lot and site for the Santee Swap Meet, which operates on weekends.

The Property is located in a built, suburban environment along North Woodside Avenue, in the City of Santee, California. It is bounded by the San Diego River to the north, the former drive-in driveway to the east and west, and by Wheatlands Avenue to the west. The area in and around the Property includes industrial uses, while residential development exists just north of the San Diego River. State Route (SR) 67 is also located south of the Property.

The surrounding neighborhood was largely developed beginning around the 1960s. Such development has continued to the present day. The original neighborhood setting in and around the Property generally consisted of open, undeveloped land, as well some with agricultural uses. Over the years, the surrounding area has experienced substantial change, particularly with the construction of newer and larger residential development, as well as the remodeling of existing buildings. Commercial and industrial uses have also proliferated throughout the area.

Overall, architectural styles in and around the Property are generally Modern and/or Contemporary, expressed in a vernacular or utilitarian nature.

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-2

4.4.1.2 Historic Setting
Historical Overview of the City of Santee
The City of Santee is located in eastern San Diego County. As described in Appendix F, the area was called several different names before it became known as “Santee” in 1893. Originally, the land was inhabited by the Kumeyaay tribe of Native Americans who resided on the banks of the San Diego River in the village of “Sinyeweche” (the present-day area of “Santee”). The Kumeyaay dominated the land until the arrival of the Spanish in 1779. At the direction of Father Junipero Serra, the Kumeyaay constructed the Old Mission Dam for the nearby Mission de Alcala.

During this period, the land was divided among the Spanish soldiers as payment for their services, and the Native Americans were gathered to live at the Mission. In 1822, the Mission system was disbanded by the Mexican government and during the 1840s, American settlers arrived in California.

In 1870, George A. Cowles migrated to California from Florida. In 1877, he purchased 4,000 acres of land in the Santee area, in which he planted vineyards, pomegranate and magnolia trees. At this time, the Cuyamaca Railroad ran through the area and the local station became known as “Cowles Station” due to its proximity to the vineyard and orchards owned by Cowles. The surrounding area soon became known as “Cowleston.” After the death of George Cowles death in 1887, his wife, Jennie, married realtor and surveyor, Milton Santee.

Several years later, Jennie Cowles Santee named the early post office “Santee,” and by 1893, the town name was changed to Santee. Similarly, the Cowles School, established in 1891, and the Cowles School District subsequently changed their names to Santee as well.

In 1885, Hosmer P. McKoon purchased 9,543 acres of land in the Santee area for his “Fanita Ranch” (named after his wife, Fannie). However, over the next few years McKoon sold segments of the ranch to new arrivals, including 7,000 acres to the Scripps family in 1898. The Scripps used the ranch to raise cattle and built a country resort for their family. Like much of the rest of San Diego County during this period, Santee’s economy was based in agriculture and ranching. Farms, such as the Edgemoor Stock Farm (established in 1908), drove the local economy and contributed to the city’s rural identity. In 1914, the opening of the Panama Canal resulted in an increase in shipping ports in San Diego County that led to more growth in the surrounding areas. However, little growth came to San Diego during the early twentieth century.

In 1941, the United States’ entry into the Second World War increased military activity on the West Coast and brought new development to Santee during the 1940s. The federal government used 2,300 acres of the Fanita Ranch as military training grounds, and the Marine Corps Base, Camp Pendleton, was established north of Santee.

The wartime demand for manufacturing transformed San Diego County’s industry and it became home to various aircraft and ship manufacturing as well as military training.

During the mid-twentieth century, Santee’s economy increased, and the city became home to a variety of industries.

After the war, Santee’s agricultural industry had significantly decreased, and it began to suburbanize. Residential development in the area was built for military and worker housing during World War II, and the population rapidly increased. In 1967, the Las Colinas Detention Facility opened as a juvenile facility, and in 1979, it was converted to an adult women’s institution to serve as the primary facility for women prisoners in San Diego County. The establishment of the detention center introduced employment opportunities in the local area and served as a catalyst for further population growth. Such rapid growth created concern about the character of the community, so Santee residents created the San Diego County Santee Citizen’s Planning Committee. The committee was officially recognized by the San Diego County Board of Supervisors in December 1968, and it has continued to serve

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-3
as a local land-use and planning advisory board to the county planning commission and the Board of Supervisors.

In 1974, the Committee secured approval of the Santee Community Plan which acted as the area’s General Plan until the Santee General Plan was adopted in 1984. In 1980, the citizens of Santee voted to incorporate in order to gain local control over the development of their city, and the creation of the General Plan was their first goal.

Santee’s rapid population increase resulted in the need for more recreation and entertainment services. In 1974, two regional parks were established in the city-- Mission Trails Regional Park and Santee Lakes Regional Park.

Additionally, more commercial development and entertainment venues followed. During the late twenty-first century, much of Santee’s economy has focused upon the hospitality and entertainment sectors, as well as health care assistance, retail trade, and educational services. Since the 1980s, the City has continued to grow, reaching a population of approximately 54,000 residents in 2020. Since this time, Santee has worked toward protecting and enhancing the San Diego River, expanded its park system, and boasts major commercial centers.

Santee Drive-In Theater
As described in Appendix F (Historical Assessment Report), historical research indicates that the property on which the Former Drive-In Theatre is today was acquired by partners John Elliot Forte and Walt Long in 1958. Inspection of a 1953 historic aerial photograph of the property indicates that it was originally part of a larger agricultural area.

Forte and Long labored on the construction of the drive-in for approximately four years before its grand opening on September 26, 1962. The identities of the designer, architect, and/or builder could not be ascertained. The facility was advertised as “California’s Newest, Most Modern Drive-In Theatre” with an opening night that featured a sky diving exhibition before a screening of “The Horizontal Lieutenant” with Jim Hutton, Paula Prentiss, and Jack Carter, and “Ride The High Country” with Randolph Scott and Joel McCrea. Sometime between 1964-1967, the drive-in site also operated as the “Santee Swap Meet,” once a week (on Sunday) during the day. In addition, during the mid1970s, the Property became the subject of controversy by showing X-rated films to the public.

Inspection of a 1964 historic aerial photograph depicts the Property as a developed site with an unpaved driveway leading north from Woodside Avenue, then jogging west toward an unpaved, rectangular parking lot. A parking lot with semi-circular rows of sloped parking spaces and mounted speakers, and Screen #1, is visible at the northwest corner of the property. Similarly, the Entrance Sign is visible along the driveway, and a rectangular-shaped building, the Concessions Building, is visible at the center of the property. By 1966, no discernable changes are visible to the site. From 1966 onward, the Property and the surrounding area display no ascertainable changes until 1971.

In 1971, the southeastern half of the Property and the driveway leading from North Woodside Avenue appear to have been paved with sloping parking spots arranged in semi-circular rows, while the northwestern half of the property remained unpaved. By 1978, the Property had been entirely paved and the parking orientation divided and rearranged to accommodate the addition of Screen #2 at the southeastern corner of the Property. Parking for each screen was oriented in semi-circular rows of sloping parking spaces facing the direction of each respective screen. Fencing around the southwest side of the Property had delineated the parking lots for each of the screens.

In addition, the Property included an addition to the northern portion of the site, and a driveway with two ticket booths had been constructed along the east boundary of the parcel. The driveway and ticket booths support a new entry orientation, turning the previous entrance into an exit. Historic aerial photographs from 1978 onward indicate that the Property had not experienced any substantial modifications or alterations.

Between 1962-2020, Forte and Long owned the Property, although Long and his son, Mike, managed the drive-in together. In 2020, the Long family retired, and management of the Property was subsequently taken over by the Forte family. The Former Drive-In Theatre on the Property continued under the operation of the Forte family until it

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-4
closed on December 31, 2023. Historical research was unable to identify any further information related to the Long and Forte families.

4.4.1.3 Cultural Resources
This section presents information gathered during the cultural resources and paleontological resources inventory efforts in support of the Project (see Appendices E and H of this EIR for additional details). Section 4.4.2, Relevant Plans, Policies, and Ordinances, provides background information on the federal, state and local regulations and requirements related to these resources.

Previously Conducted Cultural Resources Studies
The records search results revealed that 82 previous cultural resources studies have been conducted within a onemile radius of the Project area. Of the 82 previous studies, four studies intersect the Project area. These studies consist of a regional archaeological survey, two archaeological resources inventory reports, and an extended phase I and phase II testing and evaluation report. Overall, approximately 10% of the Project area has been subject to previous cultural resources investigations. All intersecting studies have resulted in negative findings within the overlapping portions of the Project area. The results of this records search are attached as part of Confidential Appendix A of Appendix E.

Previously Recorded Cultural Resources
The SCIC records search did not identify any cultural resources within the Project area, though it did identify 20 cultural resources within a one-mile radius of the Project area. Of the 20 resources identified within the one-mile radius, twelve are prehistoric resources, six are historic resources, and two are multicomponent resources.

Additionally, two historic addresses, one with multiple historic structures, were recorded within the one-mile radius of the Project area, but do not intersect it. The results of this records search and all DPR forms are attached as part of Confidential Appendix A of Appendix E to this Draft EIR.

Archival Research
In addition to the SCIC records search, Dudek conducted an online review of Bureau of Land Management (BLM) General Land Office Records, historical topographic (topo) maps, and historic aerial photographs to understand the development of the Project area and surrounding properties over time. The Project area was first recorded within Lot No. 37 of The Rancho El Cajon Land Grant in an 1883 original survey for the BLM by William H. Brown (BLM 2023). Historic topo maps of the Project area are available from 1893 to 1996 (USGS 2023). The first historic topo from 1883 shows the Project area within the natural path of the San Diego River. South of the Project area there is an established roadway and railway running roughly parallel to the San Diego River on a northeast to southwest axis. The surrounding areas remain undeveloped. There is little change within the Project area and its immediate surroundings as depicted in the historic topos until 1939. By then, it appears that the San Diego River has been diverted to the north of the Project area. By 1955, an established dirt road is shown running through the center of the Project area on a north to south axis. Although additional development appears to the south, the Project area remains undeveloped. By 1964, the Project area has been developed into a drive-in theatre. The historic topo shows a single structure in the middle of the Project area with an established road leading up to it from Riverford Road (now Woodside Avenue N.). There are two additional structures to the east of the Project area, and a residential community to the southeast, across SR-67. Although there is additional development within the surrounding areas over the next 20 years as depicted in the historic topos, the Project area remains unchanged (USGS 2023).

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-5
Historic aerial photographs (historic aerials) of the Project area are available from 1953 to 2020 and provide more detail on the historic development of the subject property and surrounding properties through time (NETR 2023).

The earliest historic aerial from 1953 shows the Project area as irrigated cropland with an established dirt road running through it on a north to south axis. The San Diego Riverbed lies to the north of the Project area, and there are several structures to the south with frontage on Woodside Avenue N. By 1964, the Project area has been developed into a drive-in theatre and appears to be predominantly a dirt parking lot. There is a single structure in the middle of the Project area and a screen in the northwest corner of the Project area. Additionally, there appears to be a dirt road leading from the front of the Project area out to Woodside Avenue N. The northernmost portion of the project area abutting the San Diego Riverbank remains undeveloped. By 1968, an established pathway appears along the northern boundary of the Project area running parallel to the riverbank, while the remaining Project area remains unchanged. It is not until 1978 that the Project area appears to have been entirely paved over and the parking area has been rearranged to accommodate an additional screen, located opposite the first, in the southeast corner. There also appears to be another structure along the eastern boundary of the Project area. The Project area displays no discernible changes since the 1978 historical aerial photograph (NETR 2023).

Cultural Resources Pedestrian Survey
Dudek archaeologist Matthew DeCarlo and Red Tail Environmental Native American Monitor Natasha Eggan conducted a site visit of the proposed Project area on March 31, 2023. The site visit employed standard archaeological procedures and techniques consistent with the Secretary of the Interior Standards. When possible, 15-meter interval survey transects were conducted oriented in cardinal direction. Where the ground surface was visible, the ground surface was examined for prehistoric artifacts (e.g., flaked stone tools, tool-making debris, stone milling tools, ceramics, fire-affected rock), soil discoloration that might indicate the presence of a cultural midden, soil depressions, features indicative of the current or former presence of structures or buildings (e.g., standing exterior walls, post holes, foundations), and historic artifacts (e.g., metal, glass, ceramics, building materials).

Ground disturbances such as rodent/reptile burrows, cut banks, and drainages were also visually inspected for exposed subsurface materials.

The Project area is flat and almost completely developed, consisting predominantly of paved parking areas, structures associated with the Santee Drive-In Theatre, and some minor landscaping. Only the northernmost portion of the Project area along the San Diego Riverbank was unpaved. Within the unpaved portion of the Project area, ground visibility was high because the southern bank of the San Diego River had been terraced and is level with minimal vegetation. Modern debris (e.g., refuse, plastic fragments, irrigation pipes, glass fragments) were strewn throughout this northern portion of the Project area. The pedestrian survey did not identify any archaeological resources within the Project area. The Santee Drive-in Theatre and its associated structures were noted as existing within the Project area during the pedestrian survey.

Native American Coordination
Native American Heritage Commission Sacred Lands File Search Dudek requested an NAHC search of the Sacred Lands File (SLF) for the Project area on March 13, 2023. The SLF consists of a database of known Native American resources. These resources may not be included in the SCIC database. The NAHC replied via email on March 28, 2023, stating that the SLF search was completed with positive results. Positive results indicate the presence of Native American cultural resources within one-mile of the Project area, and not necessarily directly within the Project area. Additionally, the NAHC provided a list of 20 Native American tribes and individuals/organizations with traditional geographic associations that might have knowledge

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-6
of cultural resources in the area. Tribal outreach letters were mailed on April 5, 2023, to all Native American group representatives included on the NAHC contact list (Appendix B). These letters attempted to solicit information relating to Native American resources that may be impacted by Project implementation. Native American representatives were requested to define a general area where known resources intersect the Project area. To date, Dudek has received one response to this information request. This response is paraphrased below:

Bernice Paipa of the Sycuan Band of the Kumeyaay Nation Cultural Resource Center and Museum (Sycuan Band) responded on April 13, 2023. Ms. Paipa’s response indicated that the Project area is within the boundaries the Sycuan Band considers their Traditional Use Area and is near known locations of Kumeyaay cultural resources. No specific locational information or descriptions were provided. Ms. Paipa requests that a qualified Kumeyaay Cultural Monitor be on site for any surveys, site visits or ground disturbing activities.

Assembly Bill 52 Consultation
The Project is subject to compliance with Assembly Bill (AB) 52 (California Public Resources Code [PRC] Section 21074), which requires consideration of impacts to Tribal Cultural Resources (TCRs) as part of the CEQA process and requires the lead agency to notify any tribal groups (who have requested notification) of the proposed Project. Pursuant to AB 52, the City of Santee (City) sent Project notification letters on September 15, 2023, to tribal representatives of the Jamul Indian Village, Mesa Grande Band of Mission Indians, and Barona Band of Mission Indians inviting each tribe to engage in tribal consultation, if desired. The communications with the contacted tribes did not result in the identification of any TCRs. Because AB 52 is a government-to-government process including consultation regarding sensitive information, all records of correspondence related to AB 52 notification and any subsequent consultation are on file with the City.

Paleontological Setting
The paleontological resources memorandum (Appendix H) was prepared in July 2023 and revised in May 2024 to determine the paleontological conditions and sensitivity of the Project site. The Project site lies within the Peninsular Ranges Geomorphic Province (California Geological Survey 2002). This province extends from the tip of the Baja California Peninsula to the Transverse Ranges (the San Gabriel and San Bernardino Mountains) and includes the Los Angeles Basin, offshore islands (Santa Catalina, Santa Barbara, San Nicholas, and San Clemente), and continental shelf. The eastern boundary is the Colorado Desert Geomorphic Province (California Geological Survey 2002; Morton and Miller 2006). The ancestral Peninsular Ranges were formed by uplift of plutonic igneous rock resulting from the subduction of the Farallon Plate underneath the North American Plate during the latter portion of the Mesozoic era (approximately 90 to 125 million years ago [mya]) (Abbott 1999).

Todd (2004) mapped the geology of the El Cajon 7.5-minute Topographic Quadrangle map, which includes the Project site, at a scale of 1:24,000. According to this mapping, the Project site is mapped as Holocene to late Pleistocene (< 11,700 years ago to approximately 129,000 years ago; Cohen et al. [2023]) Quaternary alluvium and colluvium undivided deposits (map unit Qu), which generally consists of silty graded fine to medium grained sand with silt, and clay. The geotechnical report prepared for the Project, documented in their boring logs asphalt, fill, and the silty sand with occasional gravel for the first two feet and the alluvium and colluvium starting at a depth of three feet to approximately 50 feet below the ground surface, which was the maximum depth explored.

Holocene to Pleistocene alluvial and colluvial deposits generally have low paleontological sensitivity at the surface because of their young age; however, because the age of sediments increases with depth below the ground surface,

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-7
the paleontological sensitivity may increase from the surface to the subsurface, where middle Holocene (approximately 5,000 years ago) to Pleistocene sediments can be found.

A paleontological records search request covering the Project site and a one-mile radius buffer was sent to the San Diego Natural History Museum (SDNHM) on April 7, 2023, and the results were received on April 21, 2023.

According to the records search results, no paleontological localities are documented within the Project site boundaries and there were no documented localities within the one-mile buffer area surrounding the Project site.

The SDNHM indicated that the Holocene to late Pleistocene deposits present on the surface of the Project site are likely underlain by early Cretaceous (approximately 126 mya) intrusive igneous rocks that have no paleontological sensitivity. Therefore, a paleontological mitigation program was not recommended.

Geotechnical Report Review
The geotechnical report, Geotechnical Engineering Investigation Proposed Industrial Warehouse Development (Appendix G), was prepared in March 2024 to determine the geotechnical conditions of the Project area. The report details the results of subsurface explorations at nine locations that fall within the Project site to determine subsurface conditions. According to the report, 9 hollow-stem auger borings were completed to depths between 5 and 50 feet below ground surface. Artificial fill soils encountered during subsurface testing are described as brown, fine to coarse grained, silty sand with occasional small gravel. The native soils encountered during borings are described as light brown, medium to coarse grained, sand to a brown fine to coarse grained, slightly silty to silty sand. The report concludes that artificial fills soils were observed in depths ranging from 1 to 2 feet below ground surface and underlain by alluvium (Appendix G).

4.4.2 Relevant Plans, Policies, and Ordinances
Federal
National Historic Preservation Act
Federal protection of cultural resources is legislated by (a) the National Historic Preservation Act (NHPA) of 1966 as amended by 16 U.S. Code 470, (b) the Archaeological Resource Protection Act of 1979, and (c) the Advisory Council on Historical Preservation. These laws and organizations maintain processes for determination of the effects on historical properties eligible for listing in the National Register of Historic Places (NRHP).

Section 106 of the NHPA and accompanying regulations (36 Code of Federal Regulations [CFR] Part 800) constitute the main federal regulatory framework guiding cultural resources investigations and requires consideration of effects on properties that are listed in, or may be eligible for listing in the NRHP. The NRHP is the nation’s master inventory of known historic resources. It is administered by the National Park Service and includes listings of buildings, structures, sites, objects, and districts that possess historic, architectural, engineering, archaeological, and cultural districts that are considered significant at the national, state, or local level. ▪ The formal criteria (36 CFR 60.4) for determining NRHP eligibility are as follows:
▪ The property is at least 50 years old (however, properties under 50 years of age that are of exceptional importance or are contributors to a district can also be included in the NRHP); ▪ It retains integrity of location, design, setting, materials, workmanship, feeling, and associations; and

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-8
▪ It possesses at least one of the following criteria:

Association with events that have made a significant contribution to the broad patterns of history (events).

Association with the lives of persons significant in the past (persons).

Distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or represents a significant, distinguishable entity whose components may lack individual distinction (architecture).

Has yielded, or may be likely to yield, information important to prehistory or history (information potential).

Listing in the NRHP does not entail specific protection or assistance for a property but it does guarantee recognition in planning for federal or federally assisted projects, eligibility for federal tax benefits, and qualification for federal historic preservation assistance. Additionally, project effects on properties listed in the NRHP must be evaluated under CEQA.

The National Register Bulletin also provides guidance in the evaluation of archaeological site significance. If a heritage property cannot be placed within a particular theme or time period, and thereby lacks “focus,” it is considered not eligible for the NRHP. In further expanding upon the generalized National Register criteria, evaluation standards for linear features (such as roads, trails, fence lines, railroads, ditches, flumes, etc.) are considered in terms of four related criteria that account for specific elements that define engineering and construction methods of linear features: (1) size and length; (2) presence of distinctive engineering features and associated properties; (3) structural integrity; and (4) setting. The highest probability for NRHP eligibility exists within the intact, longer segments, where multiple criteria coincide.

State
California Register of Historical Resources
In California, the term “historical resource” includes but is not limited to “any object, building, structure, 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” (California Public Resources Code Section 5020.1(j)). In 1992, the California legislature established the CRHR “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change” (California Public Resources Code Section 5024.1(a)). The criteria for listing resources on the CRHR were expressly developed to be in accordance with previously established criteria developed for listing in the NRHP, enumerated below. According to California Public Resources Code Section 5024.1(c)(1–4), a resource is considered historically significant if it (i) retains “substantial integrity,” and (ii) meets at least one of the following criteria:

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.

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-9
In order to understand the historic importance of a resource, sufficient time must have passed to obtain a scholarly perspective on the events or individuals associated with the resource. A resource less than 50 years old may be considered for listing in the CRHR if it can be demonstrated that sufficient time has passed to understand its historical importance (see 14 CCR 4852(d)(2)).

The CRHR protects cultural resources by requiring evaluations of the significance of prehistoric and historic resources. The criteria for the CRHR are nearly identical to those for the NRHP, and properties listed or formally designated as eligible for listing in the NRHP are automatically listed in the CRHR, as are the state landmarks and points of interest. The CRHR also includes properties designated under local ordinances or identified through local historical resource surveys.

California Environmental Quality Act
As described further below, the following CEQA statutes and CEQA Guidelines are of relevance to the analysis of archaeological, historic, and cultural resources:
▪ California Public Resources Code Section 21083.2(g) defines “unique archaeological resource.” ▪ California Public Resources Code Section 21084.1 and CEQA Guidelines Section 15064.5(a) define “historical resources.” In addition, CEQA Guidelines Section 15064.5(b) defines the phrase “substantial adverse change in the significance of an historical resource.” It also defines the circumstances when a project would materially impair the significance of an historical resource. ▪ California Public Resources Code Section 5097.98 and CEQA Guidelines Section 15064.5(e) set forth standards and steps to be employed following the accidental discovery of human remains in any location other than a dedicated ceremony.
▪ California Public Resources Code Sections 21083.2(b)-(c) and CEQA Guidelines Section 15126.4 provide information regarding the mitigation framework for archaeological and historic resources, including examples of preservation-in-place mitigation measures; preservation-in-place is the preferred manner of mitigating impacts to significant archaeological sites because it maintains the relationship between artifacts and the archaeological context and may also help avoid conflict with religious or cultural values of groups associated with the archaeological site(s).

More specifically, under CEQA, a project may have a significant effect on the environment if it may cause “a substantial adverse change in the significance of an historical resource” (California Public Resources Code Section 21084.1; CEQA Guidelines Section 15064.5(b).) If a site is either listed or eligible for listing in the CRHR, or if it is included in a local register of historic resources or identified as significant in a historical resources survey (meeting the requirements of California Public Resources Code Section 5024.1(q)), it is a “historical resource” and is presumed to be historically or culturally significant for purposes of CEQA (California Public Resources Code Section 21084.1; CEQA Guidelines Section 15064.5(a)). The lead agency is not precluded from determining that a resource is a historical resource even if it does not fall within this presumption (California Public Resources Code Section 21084.1; CEQA Guidelines Section 15064.5(a)).

A “substantial adverse change in the significance of an historical resource” reflecting a significant effect under CEQA means “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (CEQA Guidelines

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-10
Section 15064.5(b)(1); California Public Resources Code Section 5020.1(q)). In turn, CEQA Guidelines Section 15064.5(b)(2) states the significance of an historical resource is materially impaired when a project:

1. Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or

2. Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or

3. Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.

Pursuant to these sections, the CEQA inquiry begins with evaluating whether a project site contains any “historical resources,” then evaluates whether that project will cause a substantial adverse change in the significance of a historical resource such that the resource’s historical significance is materially impaired.

If it can be demonstrated that a project will cause damage to a unique archaeological resource, the lead agency may require reasonable efforts be made to permit any or all of these resources to be preserved in place or left in an undisturbed state. To the extent that they cannot be left undisturbed, mitigation measures are required (California Public Resources Code Section 21083.2[a], [b], and [c]).

California Public Resources Code Section 21083.2(g) defines a unique archaeological resource as an archaeological artifact, object, or site about which it can be clearly demonstrated that without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:

1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information.

2. Has a special and particular quality such as being the oldest of its type or the best available example of its type.

3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

Impacts to non-unique archaeological resources are generally not considered a significant environmental impact (California Public Resources Code section 21083.2(a); CEQA Guidelines Section 15064.5(c)(4)). However, if a nonunique archaeological resource qualifies as tribal cultural resource (California Public Resources Code Section 21074(c), 21083.2(h)), further consideration of significant impacts is required.

CEQA Guidelines Section 15064.5 assigns special importance to human remains and specifies procedures to be used when Native American remains are discovered. These procedures are detailed in PRC Section 5097.98.

California Health and Safety Code
California law protects Native American burials, skeletal remains, and associated grave goods, regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains. California Health and Safety Code Section 7050.5 requires that if human remains are discovered in any place other than a dedicated cemetery,

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-11
no further disturbance or excavation of the site or nearby area reasonably suspected to contain human remains shall occur until the county coroner has examined the remains (Section 7050.5b). PRC Section 5097.98 also outlines the process to be followed in the event that remains are discovered. If the coroner determines or has reason to believe the remains are those of a Native American, the coroner must contact the Native American Heritage Commission (NAHC) within 24 hours (Section 7050.5c). The NAHC will notify the most likely descendant.

With the permission of the landowner, the most likely descendant may inspect the site of discovery. The inspection must be completed within 48 hours of being granted access to the site. The most likely descendant may recommend means of treating or disposing of, with appropriate dignity, the human remains and items associated with Native Americans.

California State Assembly Bill 52
Assembly Bill (AB) 52 of 2014 amended PRC Section 5097.94 and added PRC Sections 21073, 21074, 21080.3.1, 21080.3.2, 21082.3, 21083.09, 21084.2, and 21084.3. AB 52 established that TCRs must be considered under CEQA and also provided for additional Native American consultation requirements for the lead agency. Section 21074 describes a TCR as a site, feature, place, cultural landscape, sacred place, or object that is considered of cultural value to a California Native American Tribe and that is either:
▪ On or determined to be eligible for the California Register of Historical Resources or a local historic register; or
▪ A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1.

AB 52 formalizes the lead agency–tribal consultation process, requiring the lead agency to initiate consultation with California Native American groups that are traditionally and culturally affiliated with the Project site, including tribes that may not be federally recognized. Lead agencies are required to begin consultation prior to the release of a negative declaration, mitigated negative declaration, or environmental impact report.

Section 1 (a)(9) of AB 52 establishes that “a substantial adverse change to a tribal cultural resource has a significant effect on the environment.” Effects on TCRs should be considered under CEQA. Section 6 of AB 52 adds Section 21080.3.2 to the PRC, which states that parties may propose mitigation measures “capable of avoiding or substantially lessening potential significant impacts to a tribal cultural resource or alternatives that would avoid significant impacts to a tribal cultural resource.” Further, if a California Native American tribe requests consultation regarding Project alternatives, mitigation measures, or significant effects to tribal cultural resources, the consultation shall include those topics (PRC Section 21080.3.2[a]). The environmental document and the mitigation monitoring and reporting program (where applicable) shall include any mitigation measures that are adopted (PRC Section 21082.3[a]).

Local
City of Santee General Plan Conservation Element
The City of Santee does not maintain a local register of historic resources. As a result, the Property was not evaluated under local significance criteria. Nevertheless, the City of Santee General Plan serves to guide the City’s future development. This is accomplished through objectives and policies that serve as a long-term guide for physical, economic, and environmental growth. The Conservation Element of the Santee General Plan addresses water resources, land resources, archaeological and cultural resources, biological resources, and open space.

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-12
Section 4.3 of the Conservation Element discusses archaeological, cultural, and historic resources known to be within the City, and does not include the Former Drive-In Theatre on the Property. The goal of the Conservation Element is to conserve open space, natural, and cultural resources.

According to Conservation Element Objective 8.0 (Preserve significant cultural resources) and Policy 8.1, the City “shall require either the preservation of significant historic or prehistoric sites, or the professional retrieval of artifacts prior to the development of a site, consistent with the provisions of the California Environmental Quality Act. Preservation may include various measures including avoidance, preservation in place, incorporation into open space, or covering or capping. The type of preservation would depend upon the nature and significance of the archaeological resource and the practical requirements of the proposed land use.” In this manner, evaluation of the Property in accordance with National and California Register significance criteria, as well under CEQA with proposed mitigation measures, achieves consistency with the City of Santee General Plan.

In addition, the City of San Diego has published a San Diego Modernism Historic Context Statement (“Modernism Context Statement”). The Modernism Context Statement is used regionally to “assist in the identification, evaluation and preservation of significant historic buildings, districts, sites and structures associated with the Modernism movement in San Diego from 1935 to 1970.” Although the City of Santee has not formally adopted the Modernism Context Statement, it serves as a regional tool by which to evaluate Modernist resources within the City.

The Modernism Context Statement is appropriate for use in evaluating the potential historic significance of the Property because:

The Modernism Context Statement was intended to guide evaluations within the region rather than being restricted to San Diego City limits. The Modernism Context Statement was prepared by the City of San Diego utilizing Federal funds from the National Park Service, Department of the Interior, through the California Office of Historic Preservation (OHP) as a regional and local tool to evaluate Modern Architecture in the San Diego.

The Modernism Context Statement is the most regionally specific guide for evaluating Modern Architecture.

There are no alternative guides or documents that offer better or more specific guidance than this one for evaluating Modern Architecture in the San Diego region.

4.4.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to cultural, tribal cultural, and paleontological resources are based on CEQA Guidelines Appendix G. According to CEQA Guidelines Appendix, a significant impact related to cultural, tribal cultural, and paleontological resources would occur if the Project would:

Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.

Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Disturb any human remains, including those interred outside of dedicated cemeteries.

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-13
cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k).

Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

4.4.4 Impact Analysis
A. Would the Project cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5?
Significant and Unavoidable Impact. According to CEQA Guidelines §15064.5(a)(3), a lead agency can find a resource historic under CEQA if the resource has been determined to be significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California, provided that the determination is supported by substantial evidence in light of the whole record. CEQA Guidelines §15064.5(a)(3) provides 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 (California Public Resources Code §5024.1), including where the resource embodies the distinctive characteristics of a type, period, region, or method of construction. As explained in the Historic Assessment (Appendix F), the Former DriveIn Theatre has been determined to qualify as a historic resource because it embodies the distinctive characteristics of a type, period, and method of drive-in movie theatre construction during the 1960s-1970s while remaining largely unaltered since its original construction. It was not possible to identify any precedent indicating that a drive-in theater possessing the aforementioned elements and maintaining its original integrity would not qualify as such.

While it may be theoretically possible to find an alternative determination, the absence of relevant precedent necessitated a conservative finding that this Property does, in fact, constitute a historical resource under CEQA (CEQA Guidelines §15064.5(a)(3).)
A “substantial adverse change in the significance of an historical resource” reflecting a significant effect under CEQA means “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (CEQA Guidelines Section 15064.5(b)(1).) Based on the foregoing conservative assumptions, the demolition of the Former Drive-In Theatre would result in a substantial adverse change in the significance of an historic resource under CEQA.

Because the Project’s impact would not be reduced below significance threshold, even with implementation of MM-HIS-1, MM-HIS-2, MM-HIS-3, and MM-HIS-4, the Project’s historic resource impact would remain significant and unavoidable.

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-14
B. Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5?
Less-than-Significant Impact with Mitigation Incorporated. Dudek’s archaeological resources inventory of the Project site indicates that there is moderate potential for the inadvertent discovery of archaeological resources during Project implementation. Although the SCIC records search and the site visit did not identify any archaeological resources within the Project area, there are 20 cultural resources within a one-mile radius of the Project area. Additionally, the NAHC has indicated that known Native American cultural resources are in the vicinity of the Project area. Due to this and the Project’s proximity to the bank of the San Diego River, there is an increased potential that Project associated ground disturbance would have the potential to impact unanticipated archaeological resources. For this reason, the Project site should be treated as potentially sensitive for archaeological resources, and Mitigation Measures (MM-) MM-CUL-1 is required to reduce potential impacts to unanticipated archaeological resources. With incorporation of MM-CUL-1, impacts associated with archaeological resources would be less than significant.

C. Would the Project disturb any human remains, including those interred outside of formal cemeteries? Less-than-Significant Impact with Mitigation Incorporated. No prehistoric or historic burials were identified within or immediately adjacent to the Project site as a result of the CHRIS records search, NAHC Sacred Lands File search, or pedestrian survey. Moreover, the Project site is not part of a dedicated cemetery and as such, the likelihood of disturbing human remains is low. However, the possibility of encountering human remains within the Project site exists. In the unexpected event that human remains are unearthed during construction activities, impacts would be potentially significant. However, in the unlikely event that human remains are encountered, California Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to PRC Section 5097.98, pursuant to MM-CUL-2. The County Coroner must be notified of the inadvertent discovery immediately. If the remains are determined to be Native American, the County Coroner will notify the NAHC, which will determine and notify an MLD.

With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD shall complete the inspection within 48 hours of being granted access to the site. The MLD will have the opportunity to offer recommendations for the disposition of the remains. With incorporation of MM-CUL-2, impacts associated with human remains would be less than significant.

D. Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)? Less-than-Significant Impact. As part of the Archeological Resources Inventory Report (Appendix E), records of the California Historical Resources Information System (CHRIS) and Sacred Lands File (SLF) were reviewed in March 2023. The CHRIS records search included a review of previously identified prehistoric, historical, and builtenvironment resources; Department of Parks and Recreation (DPR) site records; technical reports; archival resources; and ethnographic references. Additional consulted sources include an online review of Bureau of Land Management (BLM) General Land Office Records, historical topographic (topo) maps, and historic aerial photographs to understand the development of the Project area and surrounding properties over time. The NAHC has indicated that known Native American cultural resources are in the vicinity of the Project area. However, no

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-15
TCRs have been identified by California Native American tribes as part of the City’s AB 52 notification and consultation process. Impacts are considered less than significant. No mitigation is required.

E. Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less-than-Significant Impact with Mitigation Incorporated. There are no resources on the Project site that have been determined by the City to be significant pursuant to the criteria set forth in PRC Section 5024.1. Further, no TCRs were identified in the Project site by California Native American tribes as part of the City’s AB 52 notification and consultation process.

No responses to the AB 52 outreach letters to tribal contacts were received by the City requesting consultation.

Although information regarding TCRs has been received by the City, the archaeological sensitivity of the Project site is considered to be moderate. For this reason, the Project site should be treated as potentially sensitive for archaeological resources, and Mitigation Measures (MM-) MM-CUL-1 is required to reduce potential impacts to unanticipated discovery of cultural resources and TCRs. Implementation of MM-CUL-1 would reduce the significance of impacts associated with any potential buried, currently unrecorded/unknown tribal cultural resources to a level of less than significant.

F. Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Less-than-Significant Impact with Mitigation Incorporated. No paleontological resources were identified within the Project site as a result of the institutional records search, and desktop geological and paleontological review, and the Project site is not anticipated to be underlain by unique geologic features (see Appendices G and H of this EIR). Areas of the Project site underlain by Holocene to Pleistocene alluvial and colluvial deposits have low paleontological sensitivity but may increase at depth. In the event that intact paleontological resources are located beneath the Project site, ground-disturbing activities associated with construction of the Project, such as grading during site preparation and large diameter drilling (more than 2 feet diameter), have the potential to destroy a unique paleontological resource or site. Without mitigation, the potential damage to paleontological resources during construction would be a potentially significant impact. With implementation of MM-CUL-3, impacts related to unanticipated discovery of paleontological resources would be reduced to less than significant.

4.4.5 Mitigation Measures and Level of Significance
After Mitigation
A. Would the Project cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5?
As a resource which has been conservatively determined to be significant on the basis of its design/construction, the Former Drive-In Theatre on the Property is conservatively determined herein to be eligible for listing in the National Register of Historic Places and the California Register of Historical Resources and is therefore

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-16
conservatively assumed to be a historical resource under CEQA for purposes of environmental review of the Project under CEQA. Since the Project proposes demolition of the Former Drive-In Theatre on the Property, including its structures and parking lots, this undertaking has been conservatively assumed to cause a substantial adverse change in the significance of a historical resource under CEQA.

The below feasible mitigation measures have therefore been recommended to preserve the history and architectural significance of the Former Drive-in Theatre. In this context, recordation of the history of the Former Drive-In Theatre serves a legitimate archival purpose. However, the following mitigation measures will not reduce the impact of the proposed demolition of the Former Drive-In Theatre on the Property to a less-than-significant level under CEQA. Therefore, the impact would remain significant and unavoidable under CEQA.

MM-HIS-1 Prior to the issuance of a demolition permit, the Applicant shall submit a Historic American Buildings Survey (HABS) Level II to the City of Santee for review and approval. This mitigation measure will provide an in-depth record of the Property’s current state, including high-resolution photographs, detailed architectural drawings, and text explaining the drawings and photographs.

The (HABS) Level II survey will help preserve a visual and documented history of the Property that may otherwise be lost after demolition. The submitted documentation not only serves to memorialize the Property for future generations but also allows for a future public appreciation of the Property’s significance within the community.

The HABS documentation shall explicitly illustrate the significance of the Santee Drive-In Theatre for archival purposes, as specified below. The HABS will be made available for archival storage to the San Diego County Public Library, the San Diego History Center, and the City of Santee. The HABS shall include the following:

Drawings. The HABS documentation shall include measured drawings, including Site Plan, Elevations, and known Construction Details prepared for the following structures/objects:

Entrance Sign; Concessions Building; Movie Screens; and Ticket Booths.

Photographs. The HABS documentation shall include professional-quality photographic documentation of the Entrance Sign; Concessions Building; Movie Screens; and Ticket Booths prior to any construction on the Property. The photographs should be 35-millimeter black-and-white photographs; 4x6-inch standard format; taken of all four structure/object exterior elevations; and be of archival quality and easily reproducible. Once the HABS documentation is deemed complete, one set of original HABS photographs shall be submitted for archival storage to the San Diego County Public Library, the San Diego History Center, and the City of Santee.

Written History and Description. The HABS documentation shall include a written history and description of the Santee Drive-In Theatre, developed in accordance with standards and format meeting the Department of the Interior’s National Park Service requirements. The history will begin with a statement of significance supported by the development of the architectural and historical context in which the site was originally constructed and subsequently evolved. The written history will also include an architectural description and bibliographic information. The written history and description will also include a methodology section specifying the name of the researcher, date of research, and sources consulted.

MM-HIS-2 Interpretative Display. Prior to the issuance of the certificate of occupancy for the Project, the Applicant shall work with the City of Santee to create an approximately 24-inch by 48-inch metal

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-17
plaque or display outlining the history of the Santee Drive-In Theatre, including events and activities associated with the site.

The Applicant shall submit a plan to the City showing the location, size and content of the Interpretive Display. Upon request, the interpretive material shall be made available to schools, museums, archives and curation facilities, libraries, nonprofit organizations, the public, and other interested agencies. Prior to issuance of the certificate of occupancy for the Project, the Interpretive Display shall be installed by the Applicant on the Property or at the new location of the Entrance Sign, as described below. If the Interpretive Display is located on the Property, the Applicant shall record a covenant indicating that the property owner is responsible for implementing the long-term management of the Interpretive Display. If, at the City’s discretion, the Interpretive Display is located on off-site property owned by the City, the City shall assume long-term management of the Interpretive Display.

The interpretive display is intended to be placed near the final location of the Entrance Sign, which, as described under Mitigation Measure MM-HIS-3, will either be preserved on-site or relocated to an off-site location. By situating the interpretative display in proximity to the Entrance Sign, the public will be able to gain a deeper understanding of the significance of the Santee Drive-In Theatre, its role in the community, and its history while enjoying the visual backdrop of the Entrance Sign.

The combination of the interpretive display and the Entrance Sign will provide visual interest to the community while providing a written context to serve as an educational resource for the community.

MM-HIS-3 Rehabilitation & Relocation of the Entrance Sign. The City and the Applicant may mutually agree to either preserve the Entrance Sign on the Property or relocate it to a City-owned property within the Arts and Entertainment neighborhood. Prior to the issuance of a demolition permit for the Project, the Applicant shall submit a plan to the City of Santee for approval to rehabilitate and temporarily store the Entrance Sign, which consists of the neon tubing outlining the word “Santee,” the neon star, and the marquee. The plan, which is to be approved by the City, shall include information and details related to the rehabilitation, temporary storage and ultimate location of the Entrance Sign.

Rehabilitation and storage of the Entrance Sign will be undertaken by the Applicant in a manner consistent with the Secretary of the Interior’s Standards or other applicable industry standards . If the Entrance Sign is located on the Property, the Applicant shall record a covenant indicating that the property owner is responsible for implementing the long-term management of the Entrance Sign. If the Entrance Sign is located on off-site property owned by the City, the City shall assume long-term management of the Entrance Sign. If the City elects to require the Applicant to place the Entrance Sign and/or interpretative display on a City-owned off-site property, and the City, despite the Applicant's commercially reasonable efforts and through no fault of the Applicant, fails to provide the necessary authorization for the Applicant to begin the relocation of the Entrance Sign prior to the issuance of a Certificate of Occupancy for the project, the City shall not withhold the issuance of the Project's Certificate of Occupancy. Prior the issuance of a Certificate of Occupancy, the City and the Applicant shall mutually determine to reinstall the rehabilitated Entrance Sign at an appropriate location on the project site that is visible to the public from Woodside Avenue with recordation of a covenant by the Applicant indicating that the property owner is responsible for implementing the long-term management of the Entrance Sign. Alternatively, the City and the Applicant shall mutually determine an extended temporary storage plan for the sign with a security

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-18
from the Applicant to complete the relocation after issuance of the Certificate of Occupancy or an Applicant provided funding mechanism for the City to complete this work.

The Entrance Sign is one of the most recognizable visual elements of the Santee Drive-In Theatre.

Preserving this sign as a tangible, physical object ensures that the history of the Drive-In Theatre remains in order to be appreciated and viewed by the public. The Entrance Sign will provide a direct nexus to the history of the Drive-in Theatre and as outlined in Mitigation Measure MM-HIS-2, and the Entrance Sign will be complemented by an Interpretive Display. Together, the Entrance Sign and the Interpretive Display will provide historical context, detailing the Drive-In Theatre’s history.

MM-HIS-4 Historical Preservation Funding. In the event the Interpretive Display and Entrance Sign are relocated to City property, the City will be responsible for the long-term management of the Interpretive Display and Entrance Sign. Accordingly, if the Interpretive Display and Entrance Sign are located on City property or moved off of the Project site, after the Applicant completes the rehabilitation, storage, and relocation, the Applicant shall provide a donation to the City of Santee in the amount of $7,500 (seven thousand five hundred dollars) which is intended to fund the long-term management of the interpretive display and Entrance Sign by the City.

B. Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5?
The Project would result in potentially significant impacts with regard to a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. With incorporation of MM-CUL-1, impacts associated with archaeological resources would be less than significant with mitigation incorporated.

MM-CUL-1 In order to mitigate impacts to cultural resources to a level that is less than significant, procedures for proper treatment of unanticipated archaeological finds must comply with the California Environmental Quality Act (CEQA) Guidelines. Adherence to the following requirements during initial earth-disturbing activities will assure the proper treatment of unanticipated archaeological or Native American cultural material:

1. An archaeological monitor and a Kumeyaay Native American monitor shall be present full-time during all initial ground-disturbing activities. If proposed project excavation later present evidence suggesting a decrease in cultural sensitivity, the monitoring schedule can be reduced pending archaeological, Native American, and City consultation.

2. In the event that there is an unanticipated discovery of potentially significant archaeological resources, the archaeological monitor, Native American monitor, construction or other personnel shall have the authority to divert or temporarily halt ground disturbance operations within at least 50 feet (dependent on characteristics of the discovery) in the area of the find.

Construction activities may continue in other areas but should be redirected a safe distance from the find. The archaeological monitor shall evaluate and minimally document isolates and clearly non-significant deposits in the field. If the discovery is evaluated and found to be significant under CEQA and avoidance is not feasible, additional work such as data recovery may be warranted. A data recovery plan shall be developed by the qualified archaeologist in consultation with the City and Native American representatives, if applicable. Ground

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-19
disturbance can continue only after the resources has been properly mitigated and with approval by the City.

C. Would the Project disturb any human remains, including those interred outside of formal cemeteries? The Project would result in potentially significant impacts associated with the disturbance of human remains, including those interred outside of formal cemeteries. With incorporation of MM-CUL-2, impacts associated with human remains would be less than significant with mitigation incorporated.

MM-CUL-2 In order to mitigate impacts to human remains to a level that is less than significant, procedures for proper treatment of unanticipated discoveries must comply with the California Environmental Quality Act (CEQA) Guidelines. In the event of discovery of unanticipated human remains, personnel shall comply with Public Resources Code Section 5097.98, CEQA Section 15064.5, and Health and Safety Code Section 7050.5 during earth-disturbing activities:

1. If any human remains are discovered, the construction personnel or the appropriate representative shall contact the County Coroner and the City. Upon identification of human remains, no further disturbance shall occur in the area of the find until the County Coroner has made the necessary findings as to origin. If the remains are determined to be of Native American origin, the Most Likely Descendant, as identified by the Native American Heritage Commission, shall be contacted by the property owner or their representative in order to determine proper treatment and disposition of the remains. The immediate vicinity where the Native American human remains are located is not to be damaged or disturbed by further development activity until consultation with the Most Likely Descendant regarding their recommendations as required by California Public Resources Code Section 5097.98 has been conducted. California Public Resources Code Section 5097.98, CEQA Section 15064.5 and Health & Safety Code Section 7050.5 shall be followed.

Incorporation of MM-CUL-1 would ensure impacts would be less than significant.

4.4 – CULTURAL, TRIBAL CULTURAL, AND PALEONTOLOGICAL RESOURCES EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.4-20
F. Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Incorporation of MM-CUL-3 would ensure impacts would be less than significant.

MM-CUL-3 Inadvertent Discovery. Prior to ground-disturbing activities, the qualified paleontologist shall be retained and prepare a WEAT (worker environmental awareness training). The paleontologist, or their designee, shall present the WEAT for the construction crew members informing them of the potential to inadvertently encounter paleontological resources and the proper procedures to be enacted in the event of an inadvertent discovery. The WEAT may be done during a pre-construction meeting or morning tailboard safety meeting as long as it is done prior to ground disturbance. A qualified project paleontologist is a person with a doctorate or master’s degree in paleontology or related field and who has knowledge of the County of San Diego paleontology and documented experience in professional paleontological procedures and techniques. The applicant shall ensure that construction personnel attend the training and sign an attendance acknowledgement form.

The applicant shall retain documentation demonstrating attendance. The qualified paleontologist shall observe all initial ground disturbing activities including grading and excavation. In the unlikely event that paleontological resources (i.e., fossils) are exposed during construction activities, all construction work occurring within 50 feet of the find shall immediately stop and the lead agency representative contacted. The qualified paleontologist shall review the unanticipated find to determine the significance. If the discovery proves potentially significant under CEQA as determined by the qualified paleontologist, and the area cannot be feasibly avoided, paleontological monitoring may be warranted at the discretion of the qualified paleontologist.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-1

4.5 Energy
This section describes the existing energy conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7 of Chapter 2 of this EIR), the following analysis is based, in part, on the following source:
▪ Air Quality and GHG Emissions Technical Report, prepared by Dudek in March 2025 (Appendix B).

4.5.1 Existing Conditions
Electricity
According to the U.S. Energy Information Administration, California used approximately 250,379 gigawatt-hours (GWh) of electricity in 2019 (EIA 2020a). Electricity usage in California for different land uses varies substantially by the types of uses in a building, type of construction materials used in a building, and the efficiency of all electricityconsuming devices in a building. By sector in 2017, commercial uses accounted for 46% of the state’s electricity use, followed by 35% for residential uses, and 19% for industrial uses (EIA 2019). Due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s electricity use per capita in the residential sector is lower than any other state except Hawaii (EIA 2020b).

San Diego Gas and Electric Company (SDG&E) provides electric services to 3.7 million customers through

1.49 million electric meters located in a 4,100-square-mile service area that includes San Diego County and southern Orange County (SDG&E 2022). According to the California Public Utilities Commission (CPUC), SDG&E customers consumed approximately 19,045 million kilowatt-hours (kWh) of electricity in 2020 (CPUC 2022).

SDG&E receives electric power from a variety of sources. In 2021, 55% of SDG&E’s power came from eligible renewable energy sources, including biomass/waste, geothermal, small hydroelectric, solar, and wind sources (CPUC 2022).

Updated electricity demand forecasts show that electricity consumption in California is increasing at an accelerating rate, fueled in part by California's efforts to decarbonize the transportation and building sectors by switching from fossil fuels to electricity. Statewide electricity sales were more than 290,000 GWh in 2021 and are forecasted to be just under 302,000 GWh in 2035 (CEC 2023).

In San Diego County, the California Energy Commission (CEC) reported an annual electrical consumption of approximately 7.4 billion kWh in 2020 for residential use (CEC 2020).

Natural Gas
CPUC regulates natural gas utility service for over 11 million customers who receive natural gas from Pacific Gas & Electric, Southern California Gas (SoCalGas), SDG&E, Southwest Gas, and several smaller natural gas utilities. CPUC also regulates independent storage operators Lodi Gas Storage, Wild Goose Storage, Central Valley Storage, and Gill Ranch Storage (CPUC 2022). SDG&E provides natural gas service to San Diego County and Orange County and would provide natural gas to the proposed project. SDG&E is a wholesale customer of SoCalGas and currently receives all of its natural gas from the SoCalGas system (CPUC 2023).

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-2
The majority of California’s natural gas customers are residential and small commercial customers (core customers). These customers accounted for approximately 35% of the natural gas delivered by California utilities.

Large consumers, such as electric generators and industrial customers (noncore customers), accounted for approximately 68% of the natural gas delivered by California utilities (CPUC 2023).

CPUC regulates California natural gas rates and natural gas services, including in-state transportation over transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used in California comes from out-of-state natural gas basins (CPUC 2023).

CEC reports that SDG&E consumed a total of approximately 50.5 trillion British thermal units (Btu) of natural gas in 2020, including 14.7 trillion Btu for commercial buildings, 2.2 trillion Btu for industrial buildings, and 30.2 trillion Btu for residential use (CEC 2022a). In San Diego County, total natural gas consumption was approximately 50.5 trillion Btu in 2020, with 20.2 trillion Btu for nonresidential use and 30.3 trillion Btu for residential use (CEC 2022b).

Petroleum
According to the U.S. Energy Information Administration, California used approximately 681 million barrels of petroleum in 2018, with the majority (584 million barrels) used for the transportation sector (EIA 2021). This total annual consumption equates to a daily use of approximately 1.9 million barrels of petroleum. There are 42 U.S. gallons in a barrel, so California consumes approximately 78.4 million gallons of petroleum per day, adding up to an annual consumption of 28.7 billion gallons of petroleum. By sector, transportation uses account for approximately 85.5% of the state’s petroleum use, followed by 11.1% from industrial uses, 2.5% from commercial uses, 0.9% from residential uses, and 0.01% from electric power uses (EIA 2018). Petroleum usage in California includes petroleum products such as motor gasoline, distillate fuel, liquefied petroleum gases, and jet fuel.

California has implemented policies to improve vehicle efficiency and to support use of alternative transportation, which are described in Section 4.5.2, below. As such, CEC anticipates an overall decrease of gasoline demand in the state over the next decade.

Existing Infrastructure
The approximately 13.5-acre Project site is developed with a drive-in theatre that includes two movie screens, two ticket booths, and a building containing restrooms and a snack bar. Electric service is currently provided by SDGE and several above ground and underground electrical lines are located adjacent to the Project site and adjacent streets. Several SDGE poles would be removed and replaced as part of the Project. There is currently no gas service to the Project site, and the Project does not include plans to install new gas service.

4.5.2 Relevant Plans, Policies, and Ordinances
Federal
Energy Policy and Conservation Act
In 1975, Congress enacted the federal Energy Policy and Conservation Act, which established the first fuel economy standards for on-road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration (NHTSA) is responsible for establishing additional vehicle standards. In 2012, new fuel economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 Federal Register [FR] 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-3
Intermodal Surface Transportation Efficiency Act of 1991 The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) promoted the development of intermodal transportation systems to maximize mobility and address national and local interests in air quality and energy.

ISTEA contained factors that metropolitan planning organizations were to address in developing transportation plans and programs, including some energy‐related factors. To meet the new ISTEA requirements, metropolitan planning organizations adopted policies defining the social, economic, energy, and environmental values guiding transportation decisions.

Transportation Equity Act for the 21st Century
The Transportation Equity Act for the 21st Century was signed into law in 1998 and builds on the initiatives established in the ISTEA legislation, discussed above. The act authorizes highway, highway safety, transit, and other efficient surface transportation programs. The act continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of transportation decisions. The act also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of intelligent transportation systems to help improve operations and management of transportation systems and vehicle safety.

Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In addition to setting increased Corporate Average Fuel Economy standards for motor vehicles, the EISA includes the following provisions related to energy efficiency:
▪ Renewable Fuel Standard (RFS) (Section 202)
▪ Appliance and Lighting Efficiency Standards (Sections 301–325) ▪ Building Energy Efficiency (Sections 411–441)
This federal legislation requires ever-increasing levels of renewable fuels (the RFS) to replace petroleum (EPA 2022). The U.S. Environmental Protection Agency (EPA) is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains a minimum volume of renewable fuel. The RFS program regulations were developed in collaboration with refiners, renewable fuel producers, and many other stakeholders.

The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel volume mandate in the United States. As required under the act, the original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the EISA, the RFS program was expanded in several key ways that lay the foundation for achieving significant reductions in greenhouse gas (GHG) emissions, including the use of renewable fuels, reducing petroleum importing, and encouraging the development and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:
▪ EISA expanded the RFS program to include diesel, in addition to gasoline. ▪ EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022.
▪ EISA established new categories of renewable fuel and set separate volume requirements for each one.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-4
▪ EISA required the EPA to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.

Federal Vehicle Standards
In 2007, the Bush Administration issued Executive Order (EO) 13432, directing the EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011. In 2010, the EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012–2016 (75 FR 25324–25728).

In 2010, President Barack Obama issued a memorandum directing the Department of Transportation, Department of Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017–2025 light-duty vehicles. The proposed standards projected to achieve 163 grams per mile of carbon dioxide (CO2) in model year 2025 on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017–2021 (77 FR 62624–63200).

On January 12, 2017, the EPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light-duty trucks (EPA 2022).

In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the EPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018 (76 FR 57106–57513). The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by 6% to 23% over the 2010 baselines.

In August 2016, the EPA and NHTSA announced the adoption of the final phase two program for fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018–2027 for certain trailers and model years 2021–2027 for semitrucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately

1.1 billion MT and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).

In August 2018, EPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light-duty trucks and establish new standards for model years 2021–2026. Compared to maintaining the post2020 standards now in place, the 2018 proposal would increase U.S. fuel consumption by about half a million barrels per day (2% to 3% of total daily consumption, according to the Energy Information Administration) and would impact the global climate by 3/1000th of 1 degree Celsius by 2100 (EPA and NHTSA 2018).

In 2019, the EPA and NHTSA published the Safer Affordable Fuel-Efficient Vehicles Rule Part One: One National Program (SAFE-1), which revoked California’s authority to set its own GHG emissions standards and set zeroemission vehicle mandates in California. In March 2020, Part Two was issued, which set CO2 emissions standards and corporate average fuel economy standards for passenger vehicles and light-duty trucks for model years 2021– 2026. In March 2022, EPA reinstated California’s authority under the federal Clean Air Act to implement its own GHG emission standards and zero-emission vehicle sales mandate. EPA’s March 2022 action concludes its

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-5
reconsideration of the 2019 SAFE-1 rule by finding that the actions taken under the previous administration as a part of SAFE-1 were decided in error and are now entirely rescinded.

State
California Environmental Quality Act
Appendix F of the California Environmental Quality Act (CEQA) Guidelines calls for discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy.

California Energy Commission
Senate Bill (SB) 1389 (Bowen, Chapter 568, Statutes of 2002) requires the Energy Commission to prepare an integrated energy report every two years. The report contains an integrated assessment of major energy trends and issues facing California’s electricity, natural gas, and transportation fuel sectors. The report provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety. CEC’s Integrated Energy Policy Report (IEPR) sets forth policies that would enable the state to meet its energy needs under the carbon constraints established in the 2006 Global Warming Solutions Act. The IEPR also provides a set of recommended actions to achieve these policies. The 2022 IEPR Update provides the following recommendations (CEC 2023):

Embedding Equity and Environmental Justice at CEC
▪ Open an informational proceeding on equity and environmental justice to continue formal dialogue with the public.
▪ Check CEC progress through future IEPR proceedings on embedding equity and environmental justice. ▪ Hold an annual equity and environmental justice summit. ▪ Provide more customized support to tribes and communities. ▪ Secure more workforce development expertise.
▪ Continue a regional approach and work more consistently with local government. ▪ Consider a supplier diversity program.

California Energy Planning Library
▪ Launch the California Energy Planning Library to ensure that key data and analysis developed by the CEC are timely, transparent, and readily accessible.
▪ Solicit stakeholder engagement and feedback on how to continue to improve the new platform. ▪ Provide adequate and consistent state funding to support further development and ongoing data updates for the California Energy Planning Library
Energy Reliability
▪ Enacted Strategic Electricity Reliability Reserve to make additional generation and load reduction available during extreme events, including through the Demand Side Grid Support program and the Distributed

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-6
Energy Backup Assets program. Components of the Strategic Reliability were implemented quickly enough to support summer 2022.
▪ Preserved the option to extend Diablo Canyon Power Plant for reliability needs. ▪ Initiated efforts to analyze opportunities for additional reliability investments and develop a Clean Energy Reliability Investment Plan.

Role of Hydrogen in California’s Clean Energy Future
▪ Develop an agreed-upon and standardized method to measure the climate benefits of hydrogen while accounting for varying feedstocks and production processes. ▪ Set targets for reducing GHG emissions from hydrogen production. ▪ Expand analysis of hydrogen supply adequacy and hydrogen demand for electricity. ▪ Fully engage in the federal Hydrogen Hub initiative.

Gasoline Cost Factors and Price Spikes
▪ Additional data is necessary to better understand the impact of planned and unplanned refinery outages and inventory levels on gasoline prices.
▪ CEC is developing a Transportation Fuels Transition Study to plan for and track progress on the state’s transition away from petroleum fuels and toward a reliable, safe, equitable, and affordable transportation fuels future.

Distributed Energy Resources [DER]
▪ Examine how to balance the roles of DER and grid assets in making the energy transition away from fossil fuels. ▪ Examine the role of interconnection and how utility process reform can increase the pace of DER deployment.

Warren–Alquist Act
The California Legislature passed the Warren–Alquist Act in 1974. The Warren–Alquist Act created CEC. The legislation also incorporated the following three key provisions designed to address the demand side of the energy equation:
▪ It directed CEC to formulate and adopt the nation’s first energy conservation standards for both buildings constructed and appliances sold in California.
▪ The act removed the responsibility of electricity demand forecasting from utilities, which had a financial interest in high demand projections, and transferred it to a more impartial CEC. ▪ CEC was directed to embark on an ambitious research and development program, with a particular focus on fostering what were characterized as non-conventional energy sources.

State of California Energy Action Plan
CEC and CPUC approved the first State of California Energy Action Plan in 2003. The plan established shared goals and specific actions to ensure that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and actions that are cost effective and environmentally

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-7
sound for California’s consumers and taxpayers. In 2005, CEC and CPUC adopted a second Energy Action Plan to reflect various policy changes and actions of the prior 2 years.

At the beginning of 2008, CEC and CPUC determined that it was not necessary or productive to prepare a new energy action plan. This determination was based in part on a finding that the state’s energy policies have been significantly influenced by the passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed below). Rather than produce a new energy action plan, CEC and CPUC prepared an “update” that examines the state’s ongoing actions in the context of global climate change.

Senate Bill 1078 (2002)
SB 1078 established the California Renewables Portfolio Standard (RPS) Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year, culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill relatedly required CEC to certify eligible renewable energy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover abovemarket costs of renewable energy.

Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018) SB 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 requires all California utilities to generate 33% of their electricity from eligible renewable energy resources by 2020. SB X1-2 sets a three-stage compliance period: by December 31, 2013, 20% shall come from renewables; by December 31, 2016, 25% shall come from renewables; and by December 31, 2020, 33% shall come from renewables.

SB 350 (2015) requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.

SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024; 52% by December 31, 2027; and 60% by December 31, 2030, be secured from qualifying renewable energy sources. SB 100 also states that it is the policy of the state that eligible renewable energy resources and zero-carbon resources eventually supply 100% of the retail sales of electricity to California. This bill requires that the achievement of 100% zero-carbon electricity resources does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.

Consequently, utility energy generation from nonrenewable resources is expected to be reduced based on implementation of the 60% RPS in 2030. Therefore, any project’s reliance on nonrenewable energy sources would also be reduced.

Assembly Bill 1007 (2005)
AB 1007 (2005) required CEC to prepare a statewide plan to increase the use of alternative fuels in California (State Alternative Fuels Plan). CEC prepared the plan in partnership with the California Air Resources Board (CARB) and in consultation with other state, federal, and local agencies. The plan assessed various alternative fuels and

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-8
developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in-state production of biofuels without causing a significant degradation of public health and environmental quality.

Assembly Bill 32 (2006) and Senate Bill 32 (2016)
AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32, which extended the horizon year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32, CARB prepares scoping plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing energy efficiency and the use of renewable resources and on reducing the consumption of petroleumbased fuels (such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits for energy-related resources. Additional information on AB 32 and SB 32 is provided in Section 4.7, Greenhouse Gases, of this EIR.

California Building Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Part 6 establishes energy efficiency standards for residential and nonresidential buildings constructed in California to reduce energy demand and consumption. Part 6 is updated periodically to incorporate and consider new energy efficiency technologies and methodologies.

The current Title 24, Part 6 standards, referred to as the 2019 Title 24 Building Energy Efficiency Standards, became effective on January 1, 2020. In general, single-family residences built to the 2019 standards are anticipated to use approximately 7% less energy due to energy efficiency measures than those built to the 2016 standards; once rooftop solar electricity generation is factored in, single-family residences built under the 2019 standards will use approximately 53% less energy than those under the 2016 standards (CEC 2018a).

Nonresidential buildings built to the 2019 standards are anticipated to use an estimated 30% less energy than those built to the 2016 standards (CEC 2018a).

Title 24 also includes Part 11, the California Green Building Standards (CALGreen). CALGreen establishes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interior air quality. The 2019 CALGreen standards are the current applicable standards. Title 24 categorizes residential buildings that are four or more habitable levels as high-rise residential rather than mid-rise.

High-rise residential is included in the nonresidential section of Title 24 and therefore is subject to the nonresidential code rather than the residential code. For nonresidential projects, some of the key mandatory CALGreen 2019 standards (which the project is subject to) involve requirements related to bicycle parking, designated parking for clean air vehicles, electric vehicle charging stations, shade trees, water-conserving plumbing fixtures and fittings, outdoor potable water use in landscaped areas, recycled water supply systems, construction waste management, excavated soil and land-clearing debris, and commissioning (24 California Code of Regulations Part 11).

The 2022 standards will improve upon the 2019 standards for new construction of, and additions and alterations to, residential and nonresidential buildings. CEC updates the Title 24 Energy Code every 3 years. CEC adopted the 2022 Title 24 Energy Code in August 2021, and the California Building Standards Commission approved incorporating the updated code into the California Building Standards Code (CALGreen) in December 2021. The

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-9
2022 Energy Code went into effect on January 1, 2023. When compared to the 2019 Title 24 Standards, the 2022 amendments include measures that will further reduce energy use in single-family, multifamily, and nonresidential buildings through the following strategies (CEC 2021):
▪ New prescriptive and performance standards for electric heat pumps for space conditioning and water heating, as appropriate for the various climate zones in California, ▪ Require PV [photovoltaic] and battery storage systems for newly constructed multifamily and selected nonresidential buildings,
▪ Updated efficiency measures for lighting, building envelope, HVAC [heating, ventilation, and air conditioning], and
▪ Improvements to reduce the energy loads of certain equipment covered by (i.e., subject to the requirements of) the Energy Code that perform a commercial process that is not related to the occupant needs in the building (such as refrigeration equipment in refrigerated warehouses, or air conditioning for computer equipment in data processing centers).

California’s Integrated Energy Policy Report
CEC is responsible for preparing integrated energy policy reports that identify emerging trends related to energy supply, demand, and conservation; public health and safety; and maintenance of a healthy economy. CEC’s 2018 IEPR discusses the state’s policy goals of decarbonizing buildings, doubling energy efficiency savings, and increasing flexibility in the electricity grid system to integrate more renewable energy (CEC 2018b). Specifically, for the decarbonizing of building energy, the goal would be achieved by designing future commercial and residential buildings to have their energy sourced almost entirely from electricity in place of natural gas. Regarding the increase in renewable energy flexibility, the goal would be achieved through increases in energy storage capacity within the state, increases in energy efficiency, and adjusting energy use to the time of day when the most amount of renewable energy is being generated. Over time, these policies and trends would serve to beneficially reduce the project’s GHG emissions profile and energy consumption.

Executive Order N-79-20.

EO N-79-20 sets the goal for the state that 100% of in-state sales of new passenger cars and trucks will be zeroemission by 2035. EO-N-79-20 also sets goals for transitioning to 100% zero-emission all medium- and heavy-duty vehicles by 2045, and zero-emission drayage trucks, off-road vehicles, and equipment by 2035, where feasible.

Among other directives to further this EO, for passenger cars and trucks, the governor directed CARB to develop and propose regulations requiring increasing volumes of new zero-emission vehicles sold in the state to progress toward the target of 100% of in-state sales by 2035. The governor also directed the Governor’s Office of Business and Economic Development to develop a Zero-Emissions Vehicle Market Development Strategy, which was completed in February 2021 (GO-Biz 2021). The EO also directs updates and assessments to ensure zero-emission vehicle infrastructure is in place to support the levels of electric vehicle adoption required by the order.

Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinates land use planning, regional transportation plans, and funding priorities to help California meet its GHG emissions reduction mandates.

As codified in the California Government Code, Section 65080, SB 375 requires metropolitan planning organizations (San Diego Association of Governments) to include a sustainable communities strategy in their

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-10
regional transportation plan. The main focus of the sustainable communities strategy is to plan for growth in a fashion that will ultimately reduce GHG emissions, but the strategy is also a part of a larger effort to address other development issues within the general vicinity, including transit and vehicle miles traveled, which influence the consumption of petroleum-based fuels.

Local
SDG&E Individual Integrated Resource Plan
SDG&E’s Conforming Portfolios identify a need for approximately 1,546 MW of new capacity in 2035, comprising new solar, storage, and wind resources (SDG&E 2022). SDG&E’s Conforming Portfolio demonstrates that the utility is well positioned to achieve the state’s climate and reliability goals, in part due to SDG&E’s early compliance with RPS requirements, with around 56% of its energy mix expected from renewable resources in Compliance Period 4 (2021–2024) (SDG&E 2022). SDG&E has aggressively adopted energy storage and does not use coal resources.

SDG&E is fully compliant with RPS and long-term contracting requirements. SDG&E continues its efforts to meet resource-specific renewable procurement mandates, as required, but does not expect to procure additional resources for RPS compliance purposes until after 2030.

Sustainable Santee Plan
The City adopted the Sustainable Santee Plan in December of 2019 (City of Santee 2019). The Sustainable Santee Plan serves as the City’s climate action plan (CAP) with the primary purpose or goals as follows:

Present the City’s plan for achieving sustainability by utilizing resources efficiently, reducing greenhouse gas emissions, and preparing for potential climate-related impacts.

Identify how the City will effectively implement this Sustainable Santee Plan by obtaining funding for program implementation and tracking and monitoring the progress of the Plan implementation over time.

Allow streamlined CEQA compliance for new development by preparing an Environmental Impact Report for the Plan and developing tools that provide clear guidance to developers and other project proponents Maintain economic competitiveness within the region.

The Sustainable Santee Action Plan Project Consistency Checklist (Checklist) is intended to be a tool for development projects to demonstrate consistency with Santee’s (City’s) Sustainable Santee Action Plan, which is a qualified greenhouse gas (GHG) emissions reduction plan in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183.5. This Checklist has been developed as part of the Sustainable Santee Action Plan implementation and monitoring process and will support the achievement of individual GHG reduction measures as well as the City’s overall GHG reduction goals. In addition, this Checklist will further the City’s sustainability goals and policies that encourage sustainable development and aim to conserve and reduce the consumption of resources, such as energy and water, among others.

4.5.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts on energy are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to energy would occur if the Project would:

Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-11
Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

4.5.4 Impacts Analysis
A. Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation? Construction
Less than Significant Impact. The proposed Project would require an approximately 15-month-long construction period. The construction phases anticipated to occur include demolition, grading, building construction and architectural coating, and paving. Heavy-duty construction equipment associated with construction activities would rely on diesel fuel, as would trucks associated with vendor and haul trips.

The amount of electricity used during construction would be minimal relative to the total power used in the region or state and typical of what is required to construct a development like the Project. Typical demand would stem from the use of electrically powered hand tools and several construction trailers by managerial staff during the hours of construction activities. Natural gas is not anticipated to be required during Project construction.

Heavy-duty construction equipment of various types would be used during each phase of construction. The CalEEMod analysis discussed in Appendix B to this EIRincludes the proposed construction schedule and equipment usage. Based on that analysis, over all phases of construction, diesel-fueled construction equipment would run for an estimated 19,510 hours, as summarized in Table 4.5-1.

Table 4.5-1. Total Hours of Operation for Construction Equipment Phase (Duration) Hours of Equipment Use
Demolition (25 days) 1,400
Grading (24 days) 1,344
Building Construction (202 days) 13,736
Paving (60 days) 2,880
Architectural Coating (25 days) 150
Total 19,510
Source: Table 5 in Appendix B of this EIR.

Fuel consumption from construction equipment was estimated based on the Project’s anticipated construction schedule by converting the total CO2 emissions from each construction phase to gallons using conversion factors for CO2 to gallons of diesel. Construction is estimated to occur over a 15-month period (2023-2024) 1 based on the
CalEEMod construction phasing schedule as described in Section 4.2, Air Quality. The conversion factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and the conversion factor for diesel is 10.21 kilograms per metric 1 At the time this Air Quality and Green House Gas modelling was initiated, the analysis assumed a construction start date of July 2023. While past, it represented the earliest date construction could have been initiated. It is assumed that the earliest start date for construction represents the worst-case scenario for criteria air pollutant and GHG emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road equipment and heavyduty trucks, as well as fleet turnover replacing older equipment and vehicles in later years. Therefore, the conclusions of the analysis are more conservative than analyses prepared for later years.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-12
ton CO2 per gallon (The Climate Registry 2019). The estimated diesel fuel use from construction equipment is shown in Table 4.5-2.

Table 4.5-2. Construction Equipment Diesel Demand
Phase
Pieces of
Equipment
Equipment CO2
(MT) kg CO2/Gallon Gallons
Demolition 7 45.60 10.21 4,466.21
Grading 8 63.10 10.21 6,180.22
Building Construction 9 219 10.21 21,449.56
Paving 6 41.30 10.21 4,045.05
Architectural Coating 1 1.52 10.21 148.87
Total 36,289.91
Sources: Appendix B (pieces of equipment and equipment CO); The Climate Registry 2019 (kg/CO/gallon).

Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.

Fuel consumption from worker and vendor trips is estimated by converting the total CO2 emissions from each construction phase to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. Worker vehicles are analyzed as being gasoline fueled, and vendor/hauling vehicles are analyzed as being diesel fueled.

Calculations for total (daily trips x construction phase duration) worker, vendor, and hauler fuel consumption are provided in Tables 4.5-3, 4.5-4, and 4.5-5, respectively.

Table 4.5-3. Construction Worker Vehicle Gasoline Demand Phase Trips Vehicle CO2 (MT) kg CO2/Gallon Gallons
Demolition 400 1.69 8.78 192.48
Grading 420 1.78 8.78 202.73
Building
Construction
25,452 106.66 8.78 12,148.06
Paving 960 3.99 8.78 454.44
Architectural
Coatings
650 2.70 8.78 307.52
Total 13,305.24
Sources: Appendix B (construction worker CO2); The Climate Registry 2019 (kg/CO2/gallon).

Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.

Table 4.5-4. Construction Vendor Truck Diesel Demand
Phase Trips Vehicle CO2 (MT) kg CO2/Gallon Gallons
Demolition 100 1.12 10.21 118.51
Grading 84 1.01 10.21 98.92
Building Construction 10,100 120.50 10.21 11,802.15
Paving 0 0 10.21 0
Architectural Coatings 0 0 10.21 0
Total 12,019.59
Sources: Appendix B (construction worker CO2); The Climate Registry 2019 (kg/CO2/gallon).

Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-13
Table 4.5-5. Construction Haul Truck Diesel Demand
Phase Trips Vehicle CO2 (MT) kg CO2/Gallon Gallons
Demolition 4600 160 10.21 15,670.91
Grading 0 0 10.21 0
Building Construction 0 0 10.21 0
Paving 0 0 10.21 0
Architectural Coatings 0 0 10.21 0
Total 15,670.91
Sources: Appendix B (construction worker CO); The Climate Registry 2019 (kg/CO/gallon).

Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.

As shown in Tables 4.5-2 through 4.5-5, the Project is estimated to consume a total of approximately 77,288 gallons of petroleum during the construction phase. By comparison, approximately 15.08 billion gallons of petroleum would be consumed in California over the course of the proposed Project’s construction period based on the California daily petroleum consumption estimate of approximately 52.9 million gallons per day (CEC 2016).

Additionally, the proposed Project would be required to comply with CARB’s Airborne Toxics Control Measure, which limits fuel use by restricting heavy-duty diesel vehicle idling time to 5 minutes. Based on the calculations above, the Project would not significantly affect the overall demand for petroleum considering the Project’s minimal contribution towards demand, as well as compliance with CARB’s Airborne Toxics Control Measure, and therefore would not create wasteful, inefficient, or unnecessary consumption of energy resources.

Temporary electric power for as-necessary lighting and electronic equipment such as computers inside temporary construction trailers would be nominal; however, electricity used for such activities would be less than that required for Project operation and would be typical of similar construction sites; would not create wasteful, inefficient, or unnecessary consumption of energy resources; and would have a minimal contribution to the Project’s overall energy consumption. Construction would comply with all relevant energy-related regulations by conserving energy and natural resources to the extent feasible. The energy demands due to diesel and gasoline use during construction would be small relative to statewide and local demands for fuel use, as discussed previously. The energy consumption during Project construction would be commensurate with typical construction projects and would not use energy wastefully or inefficiently. The Project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction. Impacts related to temporary energy consumption during construction of the Project would be less than significant.

Operation
Electricity
Less than Significant Impact. SDG&E provides electric services to 3.7 million customers through 1.49 million electric meters and 905,000 natural gas meters throughout a 4,100-square-mile service area in San Diego County and southern Orange County (SDG&E 2022). According to CPUC, SDG&E customers consumed approximately 19,045 million kWh of electricity in 2020 (CPUC 2022). Based on recent energy supply and demand projections in California, statewide per-capita consumption is expected to remain relatively constant at 7,200– 7,800 kWh per person (CEC 2015). More specifically, within the City, annual electricity consumption (encompassing both residential and nonresidential) was approximately 65,092,483 kWh in 2023 (SDG&E 2023).

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-14
CalEEMod estimates energy usage associated with building systems that are regulated under Title 24 (such as heating and cooling systems), lighting, and use of appliances, plug-ins, and other sources not covered by Title 24.

CalEEMod estimated that the Project would consume approximately 1,452,465 kWh of electricity annually.

Compared with the City’s annual electricity consumption, the anticipated increase in consumption associated with one year of Project operation is approximately 2.2% of the City’s use. Considering the Project would be consistent with the City’s General Plan and zoning for the site, the local and regional electricity demand planning would have included the Project. In addition, the Project would, per Sustainable Santee Action Plan Checklist, achieve LEED certification and meet or exceed CALGreen Tier 2 Standards in effect at the time of the building permit application, and would self-generate a portion of electric energy demand with a 450 kW on-site solar energy systems, providing evidence that the operation of the Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources.

Natural Gas
Less than Significant Impact. The CPUC regulates California natural gas rates and natural gas services, including in-state transportation over transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used in California comes from out-of-state natural gas basins. SDG&E provides natural gas service to San Diego and Orange Counties and would provide service to the Project site. CalEEMod estimated that the Project would consume approximately 4.4 million thousand Btu of natural gas annually (See Appendix B). By comparison, the City consumed approximately 2,065 million thousand Btu in 2023 (SDG&E 2023).

The anticipated increase in consumption associated with one year of Project operation is approximately 0.21% of the SDG&E existing demand for the City. Considering the proposed Project would be consistent with the City’s General Plan and zoning for the site, the local and regional natural gas demand planning would have included the Project. While natural gas for the Project would have been included in demand planning, it is important to note that this Project does not propose to use natural gas. In addition, the proposed Project would comply with Title 24 energy efficiency standards, providing evidence that the operation of the Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources.

Petroleum
Less than Significant Impact. There are more than 36 million registered vehicles in California, and those vehicles consume an estimated 1.45 billion gallons of fuel each year (CEC 2022a; DMV 2022). Petroleum currently accounts for approximately 92% of California’s transportation energy consumption (CEC 2019). However, technological advances, market trends, consumer behavior, and government policies could result in significant changes in fuel consumption. At the federal and state levels, various policies, rules, and regulations have been enacted to improve vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation‐source air pollutants and GHG emissions, and reduce vehicle miles traveled. Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible. Largely as a result of and in response to these multiple factors, gasoline consumption within the state has declined in recent years, and availability of other alternative fuels and energy sources has increased. The quantity, availability, and reliability of transportation energy resources have increased in recent years, and this trend may likely continue and accelerate (CEC 2019). Increasingly available and diversified transportation energy resources act to promote continuing reliable and affordable means to support vehicular transportation within the state.

CalEEMod estimated that the Project would generate approximately 3,828,488 vehicle miles traveled (VMT) per year including passenger and truck trips associated with the operation of warehouse and manufacturing modeled

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-15
land uses, see Appendix A: CalEEMod Section 5.9, of Appendix B: Air Quality and GHG Emissions Technical Report, prepared by Dudek in May 2024. The CalEEMod VMT number is an annual total, whereas VMT in the transportation section of the EIR is based on SANDAG requirements of a per capita metric. As such they can’t be compared directly, however, the CalEEMod program inputs were based on the SANDAG-required data used for the transportation analysis. As such the VMT data from the transportation analysis, is the basis for the project modeled for purposes of AQ, GHG, and energy.

Similar to construction worker and vendor trips, operational fuel consumption was estimated by converting the total CO2 emissions from each land use type to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. Where vehicle MT CO2 emissions are calculated in CalEEMod, see Appendix A: CalEEMod Section 4.1.2, of Appendix B: Air Quality and GHG Emissions Technical Report, prepared by Dudek in May 2024. See Section 2.4.2 of the Air Quality and GHG Emissions Technical Report for detailed discussion of operational vehicle trip analysis.

Based on the annual fleet mix provided in CalEEMod, calculations for annual mobile-source fuel consumption are provided in Table 4.5-6.

Table 4.5-6. Mobile Source Fuel Consumption – Operation Fuel Vehicle MT CO2 kg CO2/Gallon Gallons
Gasoline 778.50 8.78 88,667.43
Diesel 2,220.90 10.21 217,522.04
Total 306,189.46
Sources: Appendix B (mobile source CO2); The Climate Registry 2019 (kg/CO2/gallon).

Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.

As shown in Table 4.5-6, mobile sources from the proposed Project would result in approximately 88,667 gallons of gasoline per year and 217,522 gallons of diesel consumed per year beginning in 2024. By comparison, California as a whole consumed approximately 1.45 billion gallons of petroleum in 2018 (CEC 2019).

Over the lifetime of the Project, the fuel efficiency of the vehicles being used by residents, visitors, and employees is expected to increase. As such, the amount of petroleum consumed as a result of vehicular trips to and from the Project site during operation would decrease over time.

In summary, although the Project would increase electricity, natural gas, and petroleum use during operation, considering the size of the Project, estimated use of these resources would be minimal relative to existing statewide and local demands. Energy consumption during Project operation would be commensurate with typical commercial projects and would not use energy wastefully or inefficiently. Furthermore, the Project would include several sustainability design features to reduce potential energy and water usage, such as electric vehicle parking, LEED certification and meet or exceed CALGreen Tier 2 Standards in effect at the time of the building permit application, and would self-generate a portion of electric energy demand with a 450 kW on-site solar energy systems, and include drought-tolerant landscaping and water efficient irrigation systems.

As stated above, the proposed Project will include on-site solar PV systems. Other renewable energy systems including wind turbine generation, geothermal generation, energy storage, and other renewable energy generation features are not considered technically or economically feasible and/or demonstrated for a similar project.

Additionally, site constraints include limited land availability and incompatibility with land use for large-scale power generation facilities, as well as unknown interconnection feasibility and compatibility with utility provider systems.

For these reasons other on-site renewable energy systems are not considered feasible for the proposed Project.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-16
Given the considerations above, energy consumption associated with operation of the Project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources. Impacts would be less than significant.

B. Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less than Significant Impact. The Project would meet the Title 24 and CALGreen standards to reduce energy demand and increase energy efficiency. Title 24 of the California Code of Regulations contains energy efficiency standards for residential and nonresidential buildings based on a state mandate to reduce California’s energy demand. Specifically, Title 24 addresses a number of energy efficiency measures that impact energy used for lighting, water heating, heating, and air conditioning, including the energy impact of the building envelope including windows, doors, skylights, wall/floor/ceiling assemblies, attics, and roofs.

Title 24, Part 6. Title 24, Part 6 specifically establishes energy efficiency standards for residential and nonresidential buildings constructed in the State of California in order to reduce energy demand and consumption. The proposed Project would comply with Title 24, Part 6, per state regulations.

Title 24, Part 11. In addition to CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential, and state-owned buildings, as well as schools and hospitals.
2022 CALGreen. CALGreen standards are the current applicable standards. The 2022 standards improve upon the 2019 standards for new construction of, and additions and alterations to, residential and nonresidential buildings.

When compared to the 2019 Title 24 Standards, the 2022 amendments include measures that will further reduce energy use in single-family, multifamily, and nonresidential buildings, through the following strategies (CEC 2021):
▪ New prescriptive and performance standards for electric heat pumps for space conditioning and water heating, as appropriate for the various climate zones in California, ▪ Require PV and battery storage systems for newly constructed multifamily and selected nonresidential buildings, ▪ Updated efficiency measures for lighting, building envelope, HVAC, and ▪ Improvements to reduce the energy loads of certain equipment covered by (i.e., subject to the requirements of) the Energy Code that perform a commercial process that is not related to the occupant needs in the building (such as refrigeration equipment in refrigerated warehouses, or air conditioning for computer equipment in data processing centers).

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. CEC certifies an appliance based on a manufacturer’s demonstration that the appliance meets the 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 fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwashers; clothes washers and dryers; cooking products; electric motors; low-voltage dry-type distribution transformers; power supplies;

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-17
televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing 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.

Additionally, it is anticipated that operational vehicles would meet the applicable standards of AB 1493 (vehicles manufactured in 2009 or later), and as a result, would likely consume less energy as fuel efficiency standards increase and vehicles are replaced. SDG&E supplies natural gas and electricity to the Project site. The proposed Project would result in an increased use of natural gas and electricity. However, the Project would result in a nominal increase in natural gas and electricity over the City’s typical annual natural gas and electricity consumption.

Present the City’s plan for achieving sustainability by utilizing resources efficiently, reducing greenhouse gas emissions, and preparing for potential climate-related impacts.

Identify how the City will effectively implement the Sustainable Santee Plan by obtaining funding for program implementation and tracking and monitoring the progress of the Plan implementation over time.

Maintain economic competitiveness within the region.

While the Sustainable Santee Plan serves as the City’s CAP, many of the measures also relate to energy. As discussed in Section 4.6, Greenhouse Gas Emissions, of this EIR, the Project is consistent with the Sustainable Santee Action Plan Checklist adopted by the City to ensure that the emission targets identified in the Sustainable Santee Action Plan are achieved. The Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

4.5.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to energy would be less than significant. No mitigation is required.

4.5 – ENERGY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.5-18

INTENTIONALLY LEFT BLANK

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-1

4.6 Greenhouse Gas Emissions
This section describes the existing greenhouse gas (GHG) conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7 of Chapter 2 of this EIR), the following analysis is based, in part, on the following sources:
▪ Air Quality and Greenhouse Gas Emissions Technical Report prepared by Dudek in March 2025 (Appendix B)

4.6.1 Existing Conditions
Climate Change Overview
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth's temperature depends on the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun's energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere (EPA 2022b).

The greenhouse effect is the trapping and build-up of heat in the atmosphere (troposphere) near the Earth’s surface. The greenhouse effect traps heat in the troposphere through a threefold process as follows: Short-wave radiation emitted by the Sun is absorbed by the Earth; the Earth emits a portion of this energy in the form of longwave radiation; and GHGs in the upper atmosphere absorb this long-wave radiation and emit it into space and toward the Earth. The greenhouse effect is a natural process that contributes to regulating the Earth’s temperature and creates a pleasant, livable environment on the Earth. Human activities that emit additional GHGs to the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise.

The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time scales and that in general, climate changes prior to the Industrial Revolution in the 1700s can be explained by natural causes, such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations.

Recent climate changes, in particular the warming observed over the past century, however, cannot be explained by natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that warming since the mid-20th century and is the most significant driver of observed climate change (IPCC 2014; EPA 2022b). Human influence on the climate system is evident from the increasing GHG concentrations in the atmosphere, positive radiative forcing, observed warming, and improved understanding of the climate system (IPCC 2014). Continued emissions of GHGs will cause further warming and changes in all components of the climate system, which is discussed further below under Potential Effects of Climate Change.

Greenhouse Gases and other Climate Forcing Substances
A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere. GHGs include, but are not limited to, carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), ozone

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-2
(O3), water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6).1 Some GHGs, such as CO2, CH4, and N2O, occur naturally and are emitted to the atmosphere through natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Manufactured GHGs, which have a much greater heat-absorption potential than CO2, include fluorinated gases, such as HFCs, HCFCs, PFCs, and SF6, are associated with certain industrial products and processes. A summary of the most common GHGs and their sources is included in the following text.2 Also included is a discussion of other climate forcing substances.

Carbon Dioxide (CO2). CO2 is a naturally occurring gas and a by-product of human activities and is the principal anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO2 include respiration of bacteria, plants, animals, and fungus; evaporation from oceans; volcanic out-gassing; and decomposition of dead organic matter. Human activities that generate CO2 are from the combustion of fuels such as coal, oil, natural gas, and wood and changes in land use.

Methane (CH4). CH4 is produced through both natural and human activities. CH4 is a flammable gas and is the main component of natural gas. Methane is produced through anaerobic (without oxygen) decomposition of waste in landfills, flooded rice fields, animal digestion, decomposition of animal wastes, production and distribution of natural gas and petroleum, coal production, and incomplete fossil fuel combustion.

Nitrous Oxide (N2O). N2O is produced through natural and human activities, mainly through agricultural activities and natural biological processes, although fuel burning and other processes also create N2O. Sources of N2O include soil cultivation practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers, manure management, industrial processes (such as in nitric acid production, nylon production, and fossil-fuel-fired power plants), vehicle emissions, and using N2O as a propellant (such as in rockets, racecars, and aerosol sprays).

Fluorinated Gases. Fluorinated gases (also referred to as F-gases) are synthetic powerful GHGs emitted from many industrial processes. Fluorinated gases are commonly used as substitutes for stratospheric ozone-depleting substances (e.g., CFCs, HCFCs, and halons). The most prevalent fluorinated gases include the following:
▪ Hydrofluorocarbons: HFCs are compounds containing only hydrogen, fluorine, and carbon atoms. HFCs are synthetic chemicals used as alternatives to ozone-depleting substances in serving many industrial, commercial, and personal needs. HFCs are emitted as by-products of industrial processes and are used in manufacturing.
▪ Perfluorocarbons: PFCs are a group of human-made chemicals composed of carbon and fluorine only.

These chemicals were introduced as alternatives, with HFCs, to the ozone depleting substances. The two main sources of PFCs are primary aluminum production and semiconductor manufacturing. Since PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere, these chemicals have long lifetimes, ranging between 10,000 and 50,000 years. 1 California Health and Safety Code 38505 identifies seven GHGs that the California Air Resource Board is responsible to monitor and regulate to reduce emissions: CO2, CH4, N2O, SF6, HFCs, PFCs, and NF3. 2 The descriptions of GHGs are summarized from the Intergovernmental Panel on Climate Change (IPCC) Second Assessment Report (1995), IPCC Fourth Assessment Report (2007), California Air Resource Board’s Glossary of Air Pollution Terms (2015), and EPA’s Glossary of Climate Change Terms (2016).

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-3
▪ Sulfur Hexafluoride: SF6 is a colorless gas soluble in alcohol and ether and slightly soluble in water. SF6 is used for insulation in electric power transmission and distribution equipment, semiconductor manufacturing, the magnesium industry, and as a tracer gas for leak detection. ▪ Nitrogen Trifluoride: NF3 is used in the manufacture of a variety of electronics, including semiconductors and flat panel displays.

Chlorofluorocarbons (CFCs). CFCs are synthetic chemicals that have been used as cleaning solvents, refrigerants, and aerosol propellants. CFCs are chemically unreactive in the lower atmosphere (troposphere) and the production of CFCs was prohibited in 1987 due to the chemical destruction of stratospheric O3.

Hydrochlorofluorocarbons (HCFCs). HCFCs are a large group of compounds, whose structure is very close to that of CFCs—containing hydrogen, fluorine, chlorine, and carbon atoms—but including one or more hydrogen atoms. Like HFCs, HCFCs are used in refrigerants and propellants. HCFCs were also used in place of CFCs for some applications; however, their use in general is being phased out.

Black Carbon. Black carbon is a component of fine particulate matter, which has been identified as a leading environmental risk factor for premature death. It is produced from the incomplete combustion of fossil fuels and biomass burning, particularly from older diesel engines and forest fires. Black carbon warms the atmosphere by absorbing solar radiation, influences cloud formation, and darkens the surface of snow and ice, which accelerates heat absorption and melting. Black carbon is a short-lived species that varies spatially, which makes it difficult to quantify the global warming potential. Diesel particulate matter emissions are a major source of black carbon and are toxic air contaminates (TACs) that have been regulated and controlled in California for several decades to protect public health. In relation to declining diesel particulate matter from the California Air Resources Board’s (CARB’s) regulations pertaining to diesel engines, diesel fuels, and burning activities, CARB estimates that annual black carbon emissions in California have reduced by 70% between 1990 and 2010, with 95% control expected by 2020 (CARB 2014).

Water Vapor. The primary source of water vapor is evaporation from the ocean, with additional vapor generated by sublimation (change from solid to gas) from ice and snow, evaporation from other water bodies, and transpiration from plant leaves. Water vapor is the most important, abundant, and variable GHG in the atmosphere and maintains a climate necessary for life.

Ozone (O3). Tropospheric O3, which is created by photochemical reactions involving gases from both natural sources and human activities, acts as a GHG. Stratospheric O3, which is created by the interaction between solar ultraviolet radiation and molecular oxygen (O2), plays a decisive role in the stratospheric radiative balance. Depletion of stratospheric O3, due to chemical reactions that may be enhanced by climate change, results in an increased ground-level flux of ultraviolet-B radiation.

Aerosols. Aerosols are suspensions of particulate matter in a gas emitted into the air through burning biomass (plant material) and fossil fuels. Aerosols can warm the atmosphere by absorbing and emitting heat and can cool the atmosphere by reflecting light.

Global Warming Potential
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-4
atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo) (EPA 2022b). The Intergovernmental Panel on Climate Change (IPCC) developed the global warming potential (GWP) concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The GWP of a GHG is defined as the ratio of the time-integrated radiative forcing from the instantaneous release of 1 kilogram of a trace substance relative to that of 1 kilogram of a reference gas (IPCC 2014). The reference gas used is CO2; therefore, GWP-weighted emissions are measured in metric tons (MT) CO2 equivalent (CO2e).

The current version of the CalEEMod (version 2022.1.1.19) 3 assumes that the GWP for CH4 is 25 (so emissions of
1 MT of CH4 are equivalent to emissions of 25 MT of CO2), and the GWP for N2O is 298, based on the IPCC Fourth Assessment Report (IPCC 2007). The GWP values identified in CalEEMod were applied to the Project.

Sources of Greenhouse Gas Emissions
Global Inventory
Anthropogenic GHG emissions worldwide in 2019 (the most recent year for which data is available) totaled approximately 52,400 million metric tons (MMT) of CO2e, excluding land use change and forestry (PBL 2020). The top six GHG emitters include China, the United States, the Russian Federation, India, Japan, and the European Union, which accounted for approximately 62% of the total global emissions, or approximately 32,500 MMT CO2e (PBL 2020). Table 4.6-1 presents the top GHG-emissions-producing countries.

Table 4.6-1. Six Top GHG Producer Countries
Emitting Countries 2019 GHG Emissions (MMT CO2e)a,b
China 14,000
United States 6,600
European Union 4,300
India 3,700
Russian Federation 2,500
Japan 1,400
Total 32,500
Source: PBL 2020.

Notes: MMT CO2e = million metric tons of carbon dioxide equivalent. a Column may not add due to rounding.
b GHG emissions do not include land use change and forestry-related GHG emissions.

National Inventory
Per the EPA Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 to 2019 (EPA 2021), total United States GHG emissions were approximately 6,558.3 MMT CO2e in 2019 (EPA 2021). The primary GHG emitted by human activities in the United States was CO2, which represented approximately 80.1% of total GHG emissions (5,255.8 MMT CO2e). The largest source of CO2, and of overall GHG emissions, was fossil-fuel combustion, which accounted for approximately 92.4% of CO2 emissions in 2019 (4,856.7 MMT CO2e). Relative to 1990, gross United States 3 CalEEMod is a statewide land use emissions computer model designed to provide a uniform platform to calculate construction and operational emissions from land use development projects. The model was developed for the California Air Pollution Control Officers Association in collaboration with multiple air districts across the state. Numerous lead agencies in the state, including SDAPCD, use CalEEMod to estimate greenhouse gas emissions in accordance with CEQA Guidelines Section 15064.4(a)(1).

CalEEMod Version 2022.1.1.19 was used for project analysis.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-5
GHG emissions in 2019 were 1.8% higher; however, the gross emissions were down from a high of 15.6% above 1990 levels in 2007. GHG emissions decreased from 2018 to 2019 by 1.7% (113.1 MMT CO2e) and overall, net emissions in 2019 were 13% below 2005 levels (EPA 2021).

State Inventory
According to California’s 2000–2019 GHG emissions inventory (2021 edition), California emitted approximately 418 MMT CO2e in 2019, including emissions resulting from out-of-state electrical generation (CARB 2022a). The sources of GHG emissions in California include transportation, industry, electric power production from both in-state and out-of-state sources, residential and commercial activities, agriculture, high-GWP substances, and recycling and waste. Table 4.6-2 presents California GHG emission source categories and their relative contributions to the emissions inventory in 2019.

Table 4.6-2. GHG Emissions Sources in California
Source Category
Annual GHG Emissions
(MMT CO2e) Percent of Total*
Transportation 166.1 39.7%
Industrial 88.2 21.1%
Electric power 58.8 14.1%
Commercial and residential 43.8 10.5%
Agriculture 31.8 7.6%
High global-warming potential
substances

20.6 4.9%
Recycling and waste 8.9 2.1%
Total 418.2 100%
Source: CARB 2022a.

Notes: GHG = greenhouse gas; MMT CO2e = million metric tons of carbon dioxide equivalent. * Column may not add due to rounding.

Between 2000 and 2019, per-capita GHG emissions in California have dropped from a peak of 14.0 MT CO2e per person in 2001 to 10.5 MT CO2e per person in 2019, representing an approximate 25% decrease. In addition, total GHG emissions in 2019 were approximately 7 MMT CO2e lower than 2018 emissions (CARB 2022a).

Local Inventories
According to the GHG inventory data compiled by the Energy Policy Initiative Center, in 2012, the County (as defined to include all cities therein and unincorporated County areas) emitted 34.7 MMT CO2e (EPIC 2015). As outlined in Table 4.6-3, San Diego County GHG Emissions by Sectors, on-road transportation generated 37% of these emissions.

Table 4.6-3. San Diego County GHG Emissions by Sectors
Source Category
Annual GHG Emissions
(MMT CO2e) Percent of Total
On-road transportation 13.14 37.2
Electricity generation 7.97 22.6
Natural gas end uses 2.84 8.0
Heavy Duty Trucks & Vehicles 1.89 5.4

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-6
Table 4.6-3. San Diego County GHG Emissions by Sectors
Source Category
Annual GHG Emissions
(MMT CO2e) Percent of Total
Solid Waste 1.75 4.9
Other Fuels 1.64 4.6
Industrial 1.43 4.1
Aviation 1.37 3.9
Off-Road 0.92 2.6
Wildfire 0.81 2.3
Other – Thermal Cogeneration 0.64 1.8
Water 0.52 1.5
Wastewater 0.16 0.5
Rail 0.11 0.3
Agriculture 0.08 0.2
Marine Vessels 0.05 0.1
Development and Sequestration (0.65) N/A
Total 34.67 100
Source: EPIC 2015.

Notes: GHG = greenhouse gas; MMT CO2e = million metric tons of carbon dioxide equivalent per year The 2013 emissions inventory for the City is shown in Table 4.6-4 below.

Table 4.6-4. City of Santee Community-Wide GHG Emissions by Sectors for 2013 Source Category
Annual GHG Emissions
(MT CO2e) Percent of Total
On-Road Transportation 242,499 60.24
Residential Energy 78,651 19.54
Commercial Energy 48,025 11.93
Solid Waste 11,151 2.77
Water 6,578 1.63
Off-Road Source 14,699 3.65
Wastewater 971 0.24
Total 402,574 100
Source: City of Santee 2019.

Notes: GHG emissions for each category are rounded. Sums may not add up to totals due to rounding.

Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through uncertain impacts related to future air temperatures and precipitation patterns. The 2014 IPCC Synthesis Report indicated that warming of the climate system is unequivocal and since the 1950s, many of the observed changes are unprecedented over decades to millennia. Signs that global climate change has occurred include warming of the atmosphere and ocean, diminished amounts of snow and ice, and rising sea levels (IPCC 2014).

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-7
In California, climate change impacts have the potential to affect sea-level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, frequency of severe weather events, and electricity demand and supply.

The primary effect of global climate change has been a rise in average global tropospheric temperature. Reflecting the long-term warming trend since pre-industrial times, observed global mean surface temperature for the decade 2006–2015 was 0.87°C (1.6°F) (likely between 0.75°C [1.4°F] and 0.99°C [1.8°F]) higher than the average over the 1850–1900 period (IPCC 2018). Scientific modeling predicts that continued emissions of GHGs at or above current rates would induce more extreme climate changes during the twenty-first century than were observed during the twentieth century. Human activities are estimated to have caused approximately 1.0°C (1.8°F) of global warming above pre-industrial levels (pre-industrial base period being years 1850–1900), with a likely range of 0.8°C to 1.2°C (1.4°F to 2.2°F) (IPCC 2018). Global warming is likely to reach 1.5°C (2.7°F) between 2030 and 2052 if it continues to increase at the current rate (IPCC 2018).

Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The Office of Environmental Health Hazard Assessment identified various indicators of climate change in California, which are scientifically based measurements that track trends in various aspects of climate change. Many indicators reveal discernible evidence that climate change is occurring in California and is having significant, measurable impacts in the state. Changes in the state’s climate have been observed, including an increase in annual average air temperature with record warmth from 2012 to 2016, more frequent extreme heat events, more extreme drought, a decline in winter chill, an increase in cooling degree days and a decrease in heating degree days, and an increase in variability of statewide precipitation (OEHHA 2018).

Warming temperatures and changing precipitation patterns have altered California’s physical systems—the ocean, lakes, rivers, and snowpack—upon which the state depends. Winter snowpack and spring snowmelt runoff from the Sierra Nevada and southern Cascade Mountains provide approximately one-third of the state’s annual water supply.

Impacts of climate on physical systems have been observed such as high variability of snow-water content (i.e., amount of water stored in snowpack), decrease in snowmelt runoff, glacier change (loss in area), rise in sea levels, increase in average lake water temperature and coastal ocean temperature, and a decrease in dissolved oxygen in coastal waters (OEHHA 2018).

Impacts of climate change on biological systems, including humans, wildlife, and vegetation, have also been observed, including climate change impacts on terrestrial, marine, and freshwater ecosystems. As with global observations, species responses include those consistent with warming: elevational or latitudinal shifts in range, changes in the timing of key plant and animal life cycle events, and changes in the abundance of species and in community composition. Humans are better able to adapt to a changing climate than plants and animals in natural ecosystems. Nevertheless, climate change poses a threat to public health as warming temperatures and changes in precipitation can affect vector-borne pathogen transmission and disease patterns in California as well as the variability of heat-related deaths and illnesses. In addition, since 1950, the area burned by wildfires each year has followed an increasing trend overall.

The CNRA has released four California Climate Change Assessments (2006, 2009, 2012, and 2018), which have addressed the following: acceleration of warming across the state, more intense and frequent heat waves, greater riverine flows, accelerating sea level rise, more intense and frequent drought, more severe and frequent wildfires, more severe storms and extreme weather events, shrinking snowpack and less overall precipitation, and ocean acidification, hypoxia, and warming. A summary of current and future climate change impacts to resource areas in California, as discussed in the Safeguarding California: Reducing Climate Risk (CNRA 2014), is provided in the following text.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-8
Agriculture. The impacts of climate change on the agricultural sector are far more severe than the typical variability in weather and precipitation patterns that occur year to year. Some of the specific challenges faced by the agricultural sector and farmers include more drastic and unpredictable precipitation and weather patterns; extreme weather events that range from severe flooding to extreme drought, to destructive storm events; significant shifts in water availably and water quality; changes in pollinator lifecycles; temperature fluctuations, including extreme heat stress and decreased chill hours; increased risks from invasive species and weeds, agricultural pests and plant diseases; and disruptions to the transportation and energy infrastructure supporting agricultural production.

These challenges and associated short-term and long-term impacts can have both positive and negative effects on agricultural production. Nonetheless, it is predicted that current crop and livestock production will suffer long-term negative effects resulting in a substantial decrease in the agricultural sector if not managed or mitigated.

Biodiversity and Habitat. The state’s extensive biodiversity stems from its varied climate and assorted landscapes, which have resulted in numerous habitats where species have evolved and adapted over time. Specific climate change challenges to biodiversity and habitat include species migration in response to climatic changes, range shift, and novel combinations of species; pathogens, parasites and disease; invasive species; extinction risks; changes in the timing of seasonal life-cycle events; food web disruptions; and threshold effects (i.e., a change in the ecosystem that results in a “tipping point” beyond which irreversible damage or loss has occurs). Habitat restoration, conservation, and resource management across California and through collaborative efforts amongst public, private and nonprofit agencies has assisted in the effort to fight climate change impacts on biodiversity and habitat. One of the key measures in these efforts is ensuring species’ ability to relocate as temperature and water availability fluctuate as a result of climate change, based on geographic region.

Energy. The energy sector provides California residents with a supply of reliable and affordable energy through a complex integrated system. Specific climate change challenges for the energy sector include temperature, fluctuating precipitation patterns, increasing extreme weather events and sea level rise. Increasing temperatures and reduced snowpack negatively impact the availability of a steady flow of snowmelt to hydroelectric reservoirs.

Higher temperatures also reduce the capacity of thermal power plants since power plant cooling is less efficient at higher ambient temperatures. Natural gas infrastructure in coastal California is threatened by sea level rise and extreme storm events.

Forestry. Forests occupy approximately 33% of California’s 100 million acres and provide key benefits such as wildlife habitat, absorption of CO2, renewable energy and building materials. The most significant climate change related risk to forests is accelerated risk of wildfire and more frequent and severe droughts. Droughts have resulted in more large-scale mortalities and combined with increasing temperatures have led to an overall increase in wildfire risks. Increased wildfire intensity subsequently increases public safety risks, property damage, fire suppression and emergency response costs, watershed and water quality impacts and vegetation conversions.

These factors contribute to decreased forest growth, geographic shifts in tree distribution, loss of fish and wildlife habitat and decreased carbon absorption. Climate change may result in increased establishment of non-native species, particularly in rangelands where invasive species are already a problem. Invasive species may be able to exploit temperature or precipitation changes, or quickly occupy areas denuded by fire, insect mortality or other climate change effects on vegetation.

Ocean and Coastal Ecosystems and Resources. Sea level rise, changing ocean conditions and other climate change stressors are likely to exacerbate long-standing challenges related to ocean and coastal ecosystems in addition to threatening people and infrastructure located along the California coastline and in coastal communities. Sea level rise in addition to more frequent and severe coastal storms and erosion are threatening vital infrastructure such as roads, bridges, power plants, ports and airports, gasoline pipes, and emergency facilities, as well as negatively

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-9
impacting the coastal recreational assets such as beaches and tidal wetlands. Water quality and ocean acidification threaten the abundance of seafood and other plant and wildlife habitats throughout California and globally.

Public Health. Climate change can impact public health through various environmental changes and is the largest threat to human health in the twenty-first century. Changes in precipitation patterns affect public health primarily through potential for altered water supplies, and extreme events such as heat, floods, droughts, and wildfires.

Increased frequency, intensity and duration of extreme heat and heat waves is likely to increase the risk of mortality due to heat related illness as well as exacerbate existing chronic health conditions. Other extreme weather events are likely to negatively impact air quality and increase or intensify respiratory illness such as asthma and allergies.

Additional health impacts that may be impacted by climate change include cardiovascular disease, vector-borne diseases, mental health impacts, and malnutrition injuries. Increased frequency of these ailments is likely to subsequently increase the direct risk of injury and/or mortality.

Transportation. Residents of California rely on airports, seaports, public transportation and an extensive roadway network to gain access to destinations, goods and services. While the transportation industry is a source of GHG emissions it is also vulnerable to climate change risks. Particularly, sea level rise and erosion threaten many coastal California roadways, airports, seaports, transit systems, bridge supports, and energy and fueling infrastructure.

Increasing temperatures and extended periods of extreme heat threaten the integrity of the roadways and rail lines.

High temperatures cause the road surfaces to expand which leads to increased pressure and pavement buckling.

High temperatures can also cause rail breakages, which could lead to train derailment. Other forms of extreme weather events, such as extreme storm events, can negatively impact infrastructure which can impair movement of people and goods, or potentially block evacuation routes and emergency access roads. Increased wildfires, flooding, erosion risks, landslides, mudslides, and rockslides can all profoundly impact the transportation system and pose a serious risk to public safety.

Water. Water resources in California support residences, plants, wildlife, farmland, landscapes and ecosystems and bring trillions of dollars in economic activity. Climate change could seriously impact the timing, form, amount of precipitation, runoff patterns, and frequency and severity of precipitation events. Higher temperatures reduce the amount of snowpack and lead to earlier snowmelt, which can impact water supply availability, natural ecosystems and winter recreation. Water supply availability during the intense dry summer months is heavily dependent on the snowpack accumulated during the wintertime. Increased risk of flooding has a variety of public health concerns including water quality, public safety, property damage, displacement and post-disaster mental health problems.

Prolonged and intensified droughts can also negatively affect groundwater reserves and result in increased overdraft and subsidence. Droughts can also negatively impact agriculture and farmland throughout the state. The higher risk of wildfires can lead to increased erosion, which can negatively impact watersheds and result in poor water quality. Water temperatures are also prone to increase, which can negatively impact wildlife that rely on a specific range of temperatures for suitable habitat.

In addition to the potential statewide effects of climate change, to address local and regional governments need for information to support action in their communities, the CNRA Fourth Assessment includes reports for nine regions of the state, including the San Diego Region, where the Project is located. Key projected climate changes for the San Diego Region include the following (CNRA 2019):
▪ Temperature is projected to increase substantially, along with mean temperature, heat wave frequency will increase, with more intensity and longer duration.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-10
▪ Precipitation will remain highly variable but will change in character, with wetter winters, drier springs, and more frequent and severe droughts punctuated by more intense individual precipitation events. ▪ Wildfire risk will increase in the future as climate warms. The risk for large catastrophic wildfires driven by Santa Ana wind events will also likely increase as a result of a drier autumns leading to low antecedent precipitation before the height of the Santa Ana wind season. ▪ The sea level along San Diego County is expected to rise. High tides combined with elevated shoreline water levels produced by locally and distantly driven wind-driven waves will drive extreme events. Longer-term sea level will increase rapidly in the second half of the century and will be punctuated by short periods of storm-driven extreme sea levels that will imperil existing infrastructure, structures, and ecosystems with increasing frequency.

4.6.2 Relevant Plans, Policies, and Ordinances
Federal
Massachusetts v. EPA. In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the EPA administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In December 2009, the administrator signed a final rule with the following two distinct findings regarding GHGs under Section 202(a) of the federal Clean Air Act (CAA):
▪ Endangerment Finding: The Administrator found that elevated concentrations of GHGs—CO2, CH4, N2O, HFCs, PFCs, and SF6—in the atmosphere threaten the public health and welfare of current and future generations. ▪ Cause or Contribute Finding: The Administrator further found the combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare.

These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the CAA.

Energy Independence and Security Act. The Energy Independence and Security Act of 2007 mandates the following measures to reduce national GHG emissions:

Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel by 2022.

Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct the National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.

Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.

Federal Vehicle Standards. 2007, the Bush Administration issued Executive Order (EO) 13432 directing the EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and in

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-11
2010, the EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012–2016 (75 FR 25324–25728).

In 2010, President Barack Obama issued a memorandum directing the Department of Transportation, Department of Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, the EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017–2025 light-duty vehicles. The proposed standards projected to achieve 163 grams per mile of CO2 by model year 2025 on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency.

The final rule was adopted in 2012 for model years 2017–2021 (77 FR 62624–63200). On January 12, 2017, the EPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light trucks (EPA 2022c).

In August 2016, the EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018 through 2027 for certain trailers, and model years 2021 through 2027 for semi-trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately 1.1 billion MT and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).

In August 2018, the EPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light trucks and establish new standards for model years 2021 through 2026. Compared to maintaining the post-2020 standards in place at the time, the 2018 proposal would increase U.S. fuel consumption by about half a million barrels per day (2%–3% of total daily consumption, according to the Energy Information Administration) and would impact the global climate by 3/1000th of 1°C by 2100 (EPA and NHTSA 2018).

In 2019, the EPA and NHTSA published the Safer Affordable Fuel-Efficient Vehicles Rule Part One: One National Program (SAFE-1), which revoked California’s authority to set its own GHG emissions standards and set zeroemission vehicle (ZEV) mandates in California. In March 2020, Part Two was issued which set CO2 emissions standards and corporate average fuel economy standards for passenger vehicles and light-duty trucks for model years 2021 through 2026. In March 2022, EPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate. EPA’s March 2022 action concludes its reconsideration of the 2019 SAFE-1 rule by finding that the actions taken under the previous administration as a part of SAFE-1 were decided in error and are now entirely rescinded.

The Inflation Reduction Act was signed into law by President Biden in August 2022. The bill includes specific investment in energy and climate reform and is projected to reduce GHG emissions within the U.S. by 40 percent as compared to 2005 levels by 2030. The bill allocates funds to boost renewable energy infrastructure (e.g., solar panels and wind turbines), includes tax credits for the purchase of electric vehicles, and includes measures that will make homes more energy efficient.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-12
State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other state regulations and goals. The following describes executive orders, legislation, regulations, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues.

State Climate Change Targets
Executive Order S-3-05. EO S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to 2000 levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be reduced to 80% below 1990 levels by 2050.

EO S-3-05 also directed the California EPA to report biannually on progress made toward meeting the GHG targets and the impacts to California due to global warming, including impacts to water supply, public health, agriculture, the coastline, and forestry. The Climate Action Team (CAT) was formed, which subsequently issues CAT Report Cards, with the most recent being issued in year 2023 including year 2022 emissions (CAT 2024).

Assembly Bill 32. In furtherance of the goals established in EO S-3-05, the legislature enacted AB 32 (Núñez and Pavley).

The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive multiyear program to limit California’s GHG emissions to 1990 levels by 2020 and initiate the transformations required to achieve the state’s long-range climate objectives.

Assembly Bill 1279. The Legislature enacted AB 1279, the California Climate Crisis Act, in September 2022. The bill declares the policy of the state to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emissions thereafter. Additionally, the bill requires that by 2045, statewide anthropogenic GHG emissions be reduced to at least 85% below 1990 levels.

Assembly Bill 1757. AB 1757 (September 2022) requires the CNRA to determine a range of targets for natural, carbon sequestration, and for nature-based climate solutions that reduce GHG emissions for future years 2030, 2038, and 2045. These targets are to be determined by no later than January 1, 2024, and are established to support the state’s goals to achieve carbon neutrality and foster climate adaptation and resilience.

Executive Order B-55-18. EO B-55-18 (September 2018) establishes a statewide policy to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net-negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the state’s GHG emissions. CARB will work with relevant state agencies to ensure that future scoping plans identify and recommend measures to achieve the carbon neutrality goal.

California Air Resources Board’s Climate Change Scoping Plan. One specific requirement of AB 32 was for CARB to prepare a scoping plan for achieving the maximum technologically feasible and cost-effective GHG emission reductions by 2020 (Health and Safety Code Section 38561[a]), and to update the plan at least once every 5 years.

In 2008, CARB approved the first scoping plan. The Climate Change Scoping Plan: A Framework for Change (Scoping Plan) included a mix of recommended strategies that combined direct regulations, market-based approaches, voluntary measures, policies, and other emission reduction programs calculated to meet the 2020 statewide GHG

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-13
emissions limit and initiate the transformations needed to achieve the state’s long-range climate objectives. The key elements of the Scoping Plan include the following (CARB 2008):

Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards.

Achieving a statewide renewable energy mix of 33%.

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.

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

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 (17 CCR 95480 et seq.).

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.

The Scoping Plan also identified local governments as essential partners in achieving California’s goals to reduce GHG emissions because they have broad influence and, in some cases, exclusive authority over activities that contribute to significant direct and indirect GHG emissions through their planning and permitting processes, local ordinances, outreach and education efforts, and municipal operations. Specifically, the Scoping Plan encouraged local governments to adopt a reduction goal for municipal operations, and for community emissions to reduce GHGs by approximately 15% from 2008 levels by 2020. Many local governments developed community-scale local GHG reduction plans based on this Scoping Plan recommendation.

In 2014, CARB approved the first update to the Scoping Plan. This document, The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update), defined the state’s GHG emission reduction priorities for the next 5 years, and laid the groundwork to start the transition to the post-2020 goals set forth in EO S-3-05 and EO B-16-2012. The First Update concluded that California is on track to meet the 2020 target but recommended a 2030 mid-term GHG reduction target be established to ensure a continuum of action to reduce emissions. The First Update recommended a mix of technologies in key economic sectors to reduce emissions through 2050, including 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, from 427 MMT CO2e to 431 MMT CO2e (CARB 2014).

In 2015, as directed by EO B-30-15, CARB began working on an update to the Scoping Plan to incorporate the 2030 target of 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the longterm goal of reducing GHG emissions to 80% below 1990 levels by 2050 as set forth in EO S-3-05. The governor called on California to pursue a new and ambitious set of strategies, in line with the five climate change pillars from his inaugural address, to reduce GHG emissions and prepare for the unavoidable impacts of climate change. In the summer of 2016, the legislature affirmed the importance of addressing climate change through passage of SB 32 (see below).

In December 2017, CARB adopted California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan) for public review and comment (CARB 2017). The 2017 Scoping Plan builds on the successful framework established in the initial Scoping Plan and First Update while identifying new, technologically feasible and cost-effective strategies that will serve as the framework to achieve the 2030 GHG target as established by SB 32 and define the state’s climate

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-14
change priorities to 2030 and beyond. The strategies’ commitments include implementing renewable energy and energy efficiency strategies (including the mandates of SB 350), increasing stringency of the Low Carbon Fuel Standard, implementing measures identified in the Mobile Source and Freight Strategies, implementing measures identified in the proposed Short-Lived Climate Pollutant Reduction Strategy, and increasing stringency of SB 375 targets. To fill the gap in additional reductions needed to achieve the 2030 target, it recommends continuing the Cap-and-Trade Program and a measure to reduce GHGs from refineries by 20%.

For local governments, the 2017 Scoping Plan replaced the initial Scoping Plan’s 15% reduction goal with a recommendation to aim for a community-wide goal of no more than 6 MT CO2e per capita by 2030, and no more than 2 MT CO2e per capita by 2050, which are consistent with the state’s long-term goals. These goals are also consistent with the Under 2 Memorandum of Understanding (Under 2 2016) and the Paris Agreement, which are developed around the scientifically based levels necessary to limit global warming to below 2°C. The 2017 Scoping Plan recognized the benefits of local government GHG planning (e.g., through CAPs) and provided more information regarding tools CARB was developing in support those efforts. It also recognized the CEQA streamlining provisions for project-level review where there is a legally adequate CAP.4 The most recent CARB 2022 Scoping Plan Update outlines the state’s plan to reduce emissions and achieve carbon neutrality by 2045 in alignment with AB 1279 and assesses progress toward the 2030 SB 32 target (CARB 2022b). As such, given that SB 32 and AB 1279 are the relevant GHG emission targets, the CARB 2017 and 2022 Scoping Plan Updates that outline the strategy to achieve those targets, are the most applicable to the Project. The 2022 Scoping Plan Update builds upon and accelerates programs currently in place, including moving to zero-emission transportation; phasing out use of fossil 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; and displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines) (CARB 2022b). A project is considered consistent with the statutes and executive orders if it meets the general policies in reducing GHG emissions to facilitate the achievement of the state’s goals and does not impede attainment of those goals. A project would be consistent if it will further the objectives and not obstruct their attainment.

Executive Order B-30-15. EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO 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 B-30-15 calls for an update to CARB’s Scoping Plan to express the 2030 target in terms of MMT CO2e. The executive order also calls for state agencies to continue to develop and implement GHG emissions reduction programs in support of the reduction targets. Sector-specific agencies in transportation, energy, water, and forestry were required to prepare GHG reduction plans by September 2015, followed by a report on action taken in relation to these plans in June 2016. 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 and 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 4 Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490; San Francisco Tomorrow et al. v. City and County of San Francisco (2015) 229 Cal.App.4th 498; San Franciscans Upholding the Downtown Specific Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 719.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-15
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 to provide ongoing oversight over implementation of the state’s climate policies. AB 197 also 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 TACs from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.

Senate Bill 605 and Senate Bill 1383. SB 605 (2014) required CARB to complete a comprehensive strategy to reduce emissions of short-lived climate pollutants in the state, and SB 1383 (2016) required CARB to approve and implement that strategy by January 1, 2018. The Short-Lived Climate Pollutants Reduction Strategy was approved by CARB in March 2017, and lays out a range of options to reduce short-lived climate pollutant emissions in California, including regulations, incentives, and other market-supporting activities. SB 1383 also establishes specific targets for the reduction of short-lived climate pollutants (40% below 2013 levels by 2030 for CH4 and HFCs, and 50% below 2013 levels by 2030 for anthropogenic black carbon) and provides direction for reductions from dairy and livestock operations and landfills. Accordingly, and as mentioned above, CARB adopted its ShortLived Climate Pollutant Reduction Strategy in March 2017. This strategy establishes a framework for the statewide reduction of emissions of black carbon, CH4, and fluorinated gases.

Senate Bill 1020. SB 1020 (September 2022) revises the standards from SB 100, requiring the following percentage of retail sales of electricity to California end-use customers come from eligible renewable energy resources and zero-carbon resources:
▪ 90% by December 31, 2035
▪ 95% by December 31, 2040
▪ 100% by December 31, 2045
Building Energy
Title 24, Part 6. Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Although not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every few years by the Building Standards Commission and California Energy Commission (CEC) and revised if necessary (California Public Resources Code [PRC] Section 25402[b][1]). The regulations receive input from members of industry and the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.

The 2019 Title 24 standards became effective on January 1, 2020. The 2019 Title 24 Building Energy Efficiency Standards further reduce energy used and associated GHG emissions compared to prior standards. In general, single-family residences built to the 2019 standards are anticipated to use approximately 7% less energy due to energy efficiency measures than those built to the 2016 standards; once rooftop solar electricity generation is factored in, single-family residences built under the 2019 standards will use approximately 53% less energy than those under the 2016 standards (CEC 2018). Nonresidential buildings built to the 2019 standards are anticipated to use an estimated 30% less energy than those built to the 2016 standards (CEC 2018).

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-16
The 2022 Title 24 standards improve upon the 2019 standards for new construction of, and additions and alterations to, residential and nonresidential buildings. The CEC adopted the 2022 Title 24 Energy Code in August 2021 and the California Building Standards Commission approved incorporating the updated code into the California Building Standards Code (CALGreen) in December 2021. The 2022 Energy Code went into effect on January 1, 2023. The 2022 Energy Code focuses on four key areas in newly constructed homes and businesses:
▪ Encouraging electric heat pump technology for space and water heating, which consumes less energy and produces fewer emissions than gas-powered units.
▪ Establishing electric-ready requirements for single-family homes to position owners to use cleaner electric heating, cooking, and electric vehicle (EV) charging options whenever they choose to adopt those technologies. ▪ Expanding solar photovoltaic (PV) system and battery storage standards to make clean energy available onsite and complement the state’s progress toward a 100% clean electricity grid. ▪ Strengthening ventilation standards to improve indoor air quality.

Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as California’s Green Building Standards (CALGreen) and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential and state-owned buildings, schools, and hospitals. The CALGreen 2019 standards, which are the current standards, became effective January 1, 2020.

The 2022 standards improve upon the 2019 standards for new construction of, and additions and alterations to, residential and nonresidential buildings. The CEC updates the Title 24 Energy Code every 3 years. The CEC adopted the 2022 Title 24 Energy Code in August 2021 and the California Building Standards Commission approved incorporating the updated code into the California Building Standards Code (CALGreen) in December 2021. The 2022 Energy Code went into effect on January 1, 2023. When compared to the 2019 Title 24 Standards, the 2022 amendments include measures that will further reduce energy use in single family, multifamily, and nonresidential buildings, through the following strategies (CEC 2021):
▪ New prescriptive and performance standards for electric heat pumps for space conditioning and water heating, as appropriate for the various climate zones in California, ▪ Require PV and battery storage systems for newly constructed multifamily and selected nonresidential buildings, ▪ Updated efficiency measures for lighting, building envelope, HVAC, and Improvements to reduce the energy loads of certain equipment covered by (i.e., subject to the requirements of) the Energy Code that perform a commercial process that is not related to the occupant needs in the building (such as refrigeration equipment in refrigerated warehouses, or air conditioning for computer equipment in data processing centers).

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

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-17
conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing 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.

Assembly Bill 1109. Enacted in 2007, AB 1109 required the CEC to adopt minimum energy efficiency standards for general-purpose lighting to reduce electricity consumption by 50% for indoor residential lighting and by 25% for indoor commercial lighting.

Senate Bill 1. SB 1 (Murray) (August 2006) established a $3 billion rebate program for the installation of rooftop solar energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the Public Resources Code, including Chapter 8.8 (California Solar Initiative), that require building projects applying for ratepayer-funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance requirements. Section 25780 established that it is a goal of the state to establish a self-sufficient solar industry.

The goals included establishing solar energy systems as a viable mainstream option for homes and businesses within 10 years of adoption and placing solar energy systems on 50% of new homes within 13 years of adoption.

Assembly Bill. This bill established the Solar Water Heating and Efficiency Act of 2007. AB 1470 makes findings and declarations of the Legislature relating to the promotion of solar water heating systems and other technologies that reduce natural gas demand. AB 1470 defines several terms for purposes of the act. The bill required a commission to evaluate the data available from a specified pilot program, and to design and implement a program of incentives for the installation of 200,000 solar water heating systems in homes and businesses throughout the state by 2017.

Renewable Energy and Energy Procurement
Senate Bill 1078 (2002) established the Renewables Portfolio Standard (RPS) program, which requires an annual increase in renewable generation by the utilities. Initially, the RPS required utilities to obtain 20% of their power from renewable sources by 2010. SB X1-2 (2011) subsequently expanded the RPS by establishing that 33% of the total electricity sold to retail customers in California per year by December 31, 2020, and in subsequent years, be secured from qualifying renewable energy sources. SB 350 (2015) further expanded the RPS by establishing that 50% of the total electricity sold to retail customers in California per year by December 31, 2030, be secured from qualifying renewable energy sources. And SB 100 (2018) further accelerated the RPS, requiring achievement of a 50% RPS by December 31, 2026, and a 60% RPS by December 31, 2030. SB 100 also established a new state policy goal that calls for eligible renewable energy resources and zero-carbon resources to supply 100% of electricity retail sales and 100% of electricity procured to serve all state agencies by December 31, 2045.

Under the program, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation of 30 megawatts or less, digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-18
Mobile Sources
State Vehicle Standards. Assembly Bill 1493 (July 2002) was enacted in response to the transportation sector accounting for more than one-half of California’s CO2 emissions. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for noncommercial personal transportation in the state. AB 1493 required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. EO B-16-12 (March 2012) required that state entities under the governor’s direction and control support and facilitate the rapid commercialization of zero-emissions vehicles. It ordered CARB, CEC, the California Public Utilities Commission, and other relevant agencies to work with the Plug-In Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve goals by 2015, 2020, and 2025. On a statewide basis, EO B-16-12 established a target reduction of GHG emissions from the transportation sector equaling 80% less than 1990 levels by 2050. This directive did not apply to vehicles that have special performance requirements necessary for the protection of public safety and welfare.

Executive Order S-1-07. Issued on January 18, 2007, EO S-1-07 sets a declining Low Carbon Fuel Standard for GHG emissions measured in CO2e grams per unit of fuel energy sold in California. The initial target of the Low Carbon Fuel Standard was to reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020.

The Low Carbon Fuel Standard was subsequently amended in 2018 to require a 20% reduction in carbon intensity by 2030. This new requirement aligns with California’s overall 2030 target of reducing climate changing emissions to 40% below 1990 levels by 2030, set by SB 32. CARB has adopted implementing regulations for both the 10% and 20% carbon intensity reduction targets.

Senate Bill 375. SB 375 (2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035. Regional metropolitan planning organizations (MPO) are then responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a forecasted development pattern for the region that, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.

Pursuant to California Government Code Section 65080(b)(2)(K), an SCS does not regulate the use of land; supersede the land use authority of cities and counties; or require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the state-mandated housing element process.

In 2010, CARB adopted the SB 375 targets for the regional MPOs. The targets adopted for SANDAG in 2010 are a 7% reduction in per-capita passenger-vehicle GHG emissions by 2020 and a 13% reduction by 2035, measured relative to 2005 GHG emissions. In 2018, CARB adopted the second round of SB 375 reduction targets, and increased SANDAG’s 2020 target to a 15% reduction in per-capita passenger-vehicle GHG emissions, and the 2035 target to a 19% reduction using the same 2005 baseline.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-19
SANDAG completed and adopted its 2050 RTP/SCS in October 2011. In November 2011, CARB, by resolution, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region.

After SANDAG’s 2050 RTP/SCS was adopted, a lawsuit was filed challenging EO S-3-05’s 2050 goal of an 80% reduction in GHG emissions from 1990 levels. The Supreme Court of California held that the Environmental Impact Report at issue was sufficient to inform the public, based on the information available at the time, about the regional plan’s GHG impacts and its potential inconsistency with state climate change goals without including an explicit analysis of the consistency of projected 2050 GHG emissions with the goals in the executive order. (Cleveland National Forest Foundation v. San Diego Association of Governments (2017) 3 Cal. 5th 497.) In 2015, SANDAG adopted the next iteration of its RTP/SCS in accordance with statutorily mandated timelines and no subsequent litigation challenge was filed. More specifically, in October 2015, SANDAG adopted San Diego Forward: The Regional Plan (Regional Plan) (SANDAG 2015). Like the 2050 RTP/SCS, San Diego Forward: Regional Plan meets CARB’s 2020 and 2035 reduction targets for the region (SANDAG 2015). In December 2015, CARB, by resolution, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region. The Regional Plan was updated in 2021, which was the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies (SANDAG 2021).

On February 26, 2021, SANDAG’s Board of Directors adopted the final 2021 Regional Transportation Improvement Program (RTIP). The 2021 RTIP covers five fiscal years (FY 2021 through FY 2025) and incrementally implements the SANDAG 2019 Federal Regional Transportation Plan. The 2021 RTIP is designed to implement the region’s overall strategy for providing mobility and improving the safety, condition, and efficiency of the transportation system while reducing transportation related air pollution. The 2021 RTIP incrementally implements San Diego Forward: The 2019 Federal Regional Transportation Plan (2019 Federal RTP), the long-range transportation plan for the San Diego region approved by the SANDAG Board of Directors on October 25, 2019.

Advanced Clean Cars Program. The Advanced Clean Cars program (January 2012) is an emissions-control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide fuels for clean cars. To improve air quality, CARB implemented new emission standards to reduce smog-forming emissions beginning with 2015 model year vehicles.

It is estimated that by 2025, cars will emit 75% less smog-forming pollution than the average new car sold in 2012.

To reduce GHG emissions, CARB, in conjunction with the EPA and NHTSA, adopted new GHG standards for model year 2017 to 2025 vehicles; the new standards are estimated to reduce GHG emissions by 34% in 2025. The zeroemissions vehicle (ZEV) program will act as the focused technology of the Advanced Clean Cars program by requiring manufacturers to produce increasing numbers of ZEVs and plug-in hybrid electric vehicles in the 2018 to 2025 model years.

Assembly Bill 1236. AB 1236 (October 2015) (Chiu) directs cities and/or counties to approve an application for the installation of electric vehicle charging stations, as defined, through the issuance of specified permits unless the city or county makes specified written findings based on substantial evidence in the record that the proposed installation would have a specific, adverse impact upon the public health or safety, and there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact. AB 1236 provided for appeal of that decision to the planning commission, as specified. The bill provided that the implementation of consistent statewide standards to

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-20
achieve the timely and cost-effective installation of electric vehicle charging stations is a matter of statewide concern. The bill required electric vehicle charging stations to meet specified standards. AB 1236 required a city, county, or city and county with a population of 200,000 or more residents to adopt an ordinance, by September 30, 2016, that created an expedited and streamlined permitting process for electric vehicle charging stations. The bill also required a city, county, or city and county with a population of fewer than 200,000 residents to adopt this ordinance by September 30, 2017.

Executive Order B-16-12. EO B-16-12 (2012) directs state entities to support and facilitate development and distribution ZEVs. On a statewide basis, EO B-16-12 also establishes a GHG emissions reduction target from the transportation sector equaling 80% less than 1990 levels by 2050. In furtherance of this executive order, the Governor convened an Interagency Working Group on ZEVs that has published multiple reports regarding the progress made on the penetration of ZEVs in the statewide vehicle fleet.

Senate Bill 350. In 2015, SB 350 – the Clean Energy and Pollution Reduction Act – was enacted into law. As one of its elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is required for achievement of the state’s 2030 and 2050 reduction targets (see California Public Utilities Code, Section 740.12).

Solid Waste
Assembly Bill 939, Assembly Bill 341, and Assembly Bill 1826. In 1989, AB 939, known as the Integrated Waste Management Act (PRC Sections 40000 et seq.), was passed because of the increase in waste stream and decrease in landfill capacity. The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed of where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by 2000.

AB 341 amended the California Integrated Waste Management Act to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle published a discussion document titled AB 341 Report to the Legislature, which identified five priority strategies that CalRecycle believed would assist the state in reaching the 75% goal by 2020, legislative and regulatory recommendations, and an evaluation of program effectiveness (CalRecycle 2015).

AB 1826 (requires businesses to recycle their organic waste (i.e., food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food-soiled paper waste that is mixed in with food waste) depending on the amount of waste they generate per week. This law also requires local jurisdictions across the state to implement an organic waste recycling program to divert organic waste generated by businesses, including multi-family residential dwellings that consist of five or more units. The minimum threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.

Water
Executive Order B-29-15. (April 2015) Sets a goal of achieving a statewide reduction in potable urban water usage of 25% relative to water use in 2013. The term of the executive order extended through February 28, 2016, although

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-21
many of the directives have since become permanent water-efficiency standards and requirements. The executive order includes specific directives that set strict limits on water usage in the state. In response to EO B-29-15, the California Department of Water Resources modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increased the requirements for landscape water use efficiency and broadened its applicability to include new development projects with smaller landscape areas.

Executive Order B-37-16. Issued May 2016, EO B-37-16 directed the State Water Resources Control Board to adjust emergency water conservation regulations through the end of January 2017 to reflect differing water supply conditions across the state. The State Water Resources Control Board also developed a proposal to achieve a mandatory reduction of potable urban water usage that builds off the mandatory 25% reduction called for in EO B29-15. The State Water Resources Control Board and Department of Water Resources will develop new, permanent water use targets that build on the existing state law requirements that the state achieve a 20% reduction in urban water usage by 2020. EO B-37-16 also specifies that the State Water Resources Control Board permanently prohibit water-wasting practices such as hosing off sidewalks, driveways, and other hardscapes; washing automobiles with hoses not equipped with a shut-off nozzle; using non-recirculated water in fountains and other decorative water features; watering lawns in a manner that causes runoff, or within 48 hours after measurable precipitation; and irrigating ornamental turf on public street medians.

Other State Regulations and Goals
Senate Bill 97. (Dutton) (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines under CEQA for the mitigation of GHG emissions. In 2008, the Governor’s Office of Planning and Research issued a technical advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The advisory indicated that the lead agency should identify and estimate a project’s GHG emissions, including those associated with vehicular traffic, energy consumption, water usage, and construction activities (OPR 2007). The advisory further recommended that the lead agency determine significance of the impacts and impose all mitigation measures necessary to reduce GHG emissions to a level that is less than significant. The CNRA adopted the CEQA Guidelines amendments in December 2009, which became effective in March 2010.

Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a quantitative or qualitative analysis or apply performance standards to determine the significance of GHG emissions resulting from a particular project (14 CCR § 15064.4[a]). The CEQA Guidelines require a lead agency to consider the extent to which a project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR § 15064.4[b]). The CEQA Guidelines also allow a lead agency to consider feasible means of mitigating the significant effects of GHG emissions, including reductions in emissions through the implementation of project features or off-site measures. The adopted amendments do not establish a GHG emissions threshold, instead allowing a lead agency to develop, adopt, and apply its own thresholds of significance or those developed by other agencies or experts. The CNRA also acknowledged that a lead agency may consider compliance with regulations or requirements implementing AB 32 in determining the significance of a project’s GHG emissions (CNRA 2009a).

With respect to GHG emissions, the CEQA Guidelines state in Section 15064.4(a) that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions. The CEQA Guidelines note that an agency may identify emissions by either selecting a “model or methodology” to quantify the emissions or by relying on “qualitative analysis or other performance-based standards” (14 CCR § 15064.4[a]). Section 15064.4(b) states that the lead agency should consider the following when assessing the significance of impacts from GHG emissions on the environment: the extent a project may

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-22
increase or reduce GHG emissions as compared to the existing environmental setting; whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).

Executive Order S-13-08. EO Order S-13-08 (November 2008) Directs state agencies to take specified actions to assess and plan for global climate change impacts. The final 2009 California Climate Adaptation Strategy report was issued in December 2009 (CNRA 2009b), and an update, Safeguarding California: Reducing Climate Risk, followed in July 2014 (CNRA 2014). To assess the state’s vulnerability, the report summarizes key climate change impacts to the state for the following areas: agriculture, biodiversity and habitat, emergency management, energy, forestry, ocean and coastal ecosystems and resources, public health, transportation, and water.

Local
Sustainable Santee Plan
The City adopted the Sustainable Santee Plan in December of 2019 (City of Santee 2019). The Sustainable Santee Plan serves as the City’s climate action plan (CAP) with the primary purpose or goals as follows:
▪ Present the City’s plan for achieving sustainability by utilizing resources efficiently, reducing greenhouse gas emissions, and preparing for potential climate-related impacts. ▪ Identify how the City will effectively implement the Sustainable Santee Plan by obtaining funding for program implementation and tracking and monitoring the progress of the Plan implementation over time. ▪ Allow streamlined CEQA compliance for new development by preparing an Environmental Impact Report for the Plan and developing tools that provide clear guidance to developers and other project proponents ▪ Maintain economic competitiveness within the region.

4.6.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to greenhouse gases/climate change are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to greenhouse gas emissions would occur if the Project would:

Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-23
With respect to GHG emissions, the CEQA Guidelines Section 15064.4(a) states that lead agencies “shall make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions resulting from a project. The CEQA Guidelines note that an agency has the discretion to either quantify a project’s GHG emissions or rely on a “qualitative analysis or performance-based standards” (14 CCR 15064.4[a]). A lead agency may use a “model or methodology” to estimate greenhouse gas emissions and has the discretion to select the model or methodology it considers “most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change” (14 CCR 15064.4[c]). The CEQA Guidelines provide that the lead agency should consider the following when determining the significance of impacts from GHG emissions on the environment (14 CCR 15064.4[b]):
▪ The extent a project may increase or reduce GHG emissions as compared to the existing environmental setting. ▪ Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
▪ The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

In addition, the CEQA Guidelines specify that “[w]hen adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence” (14 CCR 15064.7[c]).

Approaches to Determining Significance
As discussed above, The Sustainable Santee Action Plan Project Consistency Checklist (Checklist) is intended to be a tool for development projects to demonstrate consistency with the City’s Sustainable Santee Action Plan, which is a qualified GHG emissions reduction plan in accordance with CEQA Guidelines Section 15183.5. Therefore, the Checklist is used to determine significance in accordance with CEQA Guidelines Section 15183.5 and the Checklist was used to evaluate the Project’s significance with respect to GHG emissions. Construction and operational GHG emissions are quantified herein for informational purposes only.

Methodology
Construction
Construction of the Project would result in emissions of GHG emissions primarily associated with use of off-road construction equipment, on-road haul and vendor (material delivery) truck trips, and worker vehicle trips. As discussed previously in Section 4.2, Air Quality, emissions from the construction phase of Project components were estimated using the CalEEMod Version 2022.1.1.4. Per preliminary Project details, it is assumed that construction of the Project would begin in June 2024 and would last approximately 15 months. A detailed depiction of the construction schedule—including information regarding phasing, equipment used during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Section 4.2, Air Quality, and complete details of the emissions calculations are provided in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, of Appendix B to this EIR. Con-related GHG emissions were amortized over 30 years and added to operational emissions to assess significance.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-24
Operation
Project operations would generate CO2, CH4, and N2O emissions. Primary emissions sources would include:
▪ Area Source (landscape and site maintenance activities) ▪ Energy Source (combustion emissions associated with natural gas and electricity) ▪ Mobile Source (vehicles)
▪ On-Site Equipment Emissions
▪ Solid Waste
▪ Water Supply, Treatment, and Distribution
Area
Landscape maintenance equipment would generate emissions from fuel combustion and evaporation of unburned fuel. Equipment in this category would include lawnmowers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers used to maintain the landscaping of the Project. The emissions associated with landscape maintenance equipment were calculated based on assumptions provided in CalEEMod. For San Diego County, CalEEMod assumes that landscaping equipment would operate 180 days per year.

Energy
As represented in CalEEMod, energy sources include emissions associated with building electricity and natural gas usage (non-hearth). CalEEMod default values for energy consumption were applied to each land use. GHGs are emitted from buildings as a result of activities for which electricity and natural gas are typically used as energy sources. Combustion of any type of fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered direct emissions associated with a building; the building energy use emissions do not include street lighting.5The energy use from non-residential land uses is based on various studies and assessments as described in Section 7.3, Estimating Energy Use from Other Land Uses, of Appendix B of the CalEEMod User’s Guide (CAPCOA 2021).

Annual natural gas and electricity emissions were estimated in CalEEMod using default values for emissions factors for San Diego Gas and Electric (SDG&E), which would be the energy source provider for the Project.

Mobile Sources (Motor Vehicles)
All details for criteria air pollutants discussed in Section 4.2, Air Quality, are also applicable for the estimation of operational mobile source GHG emissions. It was assumed that the warehouse would operate 7 days per week; therefore, 365 days of vehicle emissions were assumed. Regulatory measures related to mobile sources include AB 1493 (Pavley) and related federal standards. AB 1493 required that CARB establish GHG emission standards for automobiles, light-duty trucks, and other vehicles determined by CARB to be vehicles that are primarily used for noncommercial personal transportation in the state. In addition, the National Highway Traffic Safety Administration and EPA have established corporate fuel economy standards and GHG emission standards, respectively, for automobiles and light-, medium-, and heavy-duty vehicles. Implementation of these standards and fleet turnover (replacement of older vehicles with newer ones) will gradually reduce emissions from the Project’s motor vehicles. 5 The CalEEMod emissions inventory model does not include indirect emission related to street lighting. Indirect emissions related to street lighting are expected to be negligible and cannot be accurately quantified at this time as there is insufficient information as to the number and type of street lighting that would occur.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-25
The effectiveness of fuel economy improvements was evaluated to the extent it was captured in the EMFAC2021 emission factors for motor vehicles in 2025.

On-Site Equipment Source Emissions.

It is common for industrial buildings to require cargo handling equipment to move empty containers and empty chassis to and from the various pieces of cargo handling equipment that receive and distribute containers. The most common types of cargo handling equipment are forklifts, pallet jacks and yard trucks which are designed for moving cargo containers. Yard trucks are also known as yard goats, utility tractors, hustlers, yard hostlers, and yard tractors. The cargo handling equipment is assumed to have a horsepower (hp) range of approximately 175 hp to 215 hp. Based on the maximum square footage of proposed building space, on-site modeled operational equipment includes a total of 36, Tier4i or better diesel fueled forklifts (forklifts and pallet jacks) and 1 Tier4i or better diesel fueled yard tractors operating at 8 hours a day for 365 days of the year. See Appendix B of this EIR for detailed calculations.

Solid Waste
The Project would generate solid waste, and therefore, result in CO2e emissions associated with landfill off-gassing.

CalEEMod default values for solid waste generation were used to estimate GHG emissions associated with solid waste.

Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the Project require the use of electricity, which would result in associated indirect GHG emissions. Similarly, wastewater generated by the Project requires the use of electricity for conveyance and treatment, along with GHG emissions generated during wastewater treatment.

For additional details see Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, within Appendix B of this EIR.

4.6.4 Impacts Analysis
A. Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
B. Would the Project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less-than-Significant Impact.

As discussed above in Section 4.6.3, Methodology, the Sustainable Santee Action Plan Project Consistency Checklist (Checklist) is intended to be a tool for development projects to demonstrate consistency with the City’s Sustainable Santee Action Plan, which is a qualified GHG emissions reduction plan in accordance with CEQA Guidelines Section 15183.5. This Checklist has been developed as part of the Sustainable Santee Action Plan implementation and monitoring process and will support the achievement of individual GHG reduction measures as well as the City’s overall GHG reduction goals. Project-generated GHG emissions were estimated per the methodology described in Section 4.6.3, Methodology, and are discussed for construction and operation below.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-26
Project GHG Emissions
Construction
Table 4.6-5 shows the estimated annual GHG construction emissions associated with the Project. Additional information about methodology and approach are provided above in Section 4.6.3, Methodology. Complete details of the construction emissions calculations are provided in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, of Appendix B of this EIR.

Table 4.6-5. Estimated Annual Construction GHG Emissions Year
CO2 CH4 N2O R CO2e
Metric Tons
2024 499 0.02 0.04 0.32 511
2025 257 0.01 0.01 0.16 261
Total 756 0.03 0.05 0.48 772
Amortized Emissions (30 years) 25.73
Source: CalEEMod Version 2020.4.0.

Notes: GHG = greenhouse gas; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent; R = refrigerants.

See Appendix B of this EIR for complete results. <0.01 = reported value is less than 0.01.

As shown in Table 4.6-5, the estimated total GHG emissions from construction of the Project would be 772MT CO2e.

When amortized over 30 years, the estimated annual GHG emissions from construction of the Project would be approximately 26 MT CO2e per year.

Operation
Table 4.6-6 shows the estimated annual GHG operational emissions associated with the Project. As discussed above, total annual operational emissions were combined with amortized (30 years) construction emissions and provided for informational purposes only. As shown in Table 4.6-6, implementation of the Project would result in approximately 4,573.78 MT CO2e per year including amortized construction emissions. Complete details of the construction emissions calculations are provided in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, of Appendix B of this EIR.

Table 4.6-6. Summary of Estimated Annual GHG Emissions
Emissions Source MT CO2 MT CH4 MT N2O R MT CO2e
Area 4.38 <0.005 <0.005 — 4.40
Energy 565.00 0.04 <0.005 — 567.00
Mobile 2,895.00 0.12 0.33 3.76 2,999.00
Off-road (Cargo Handling) 665 0.03 0.01 — 668
Stationary 9.52 <0.005 <0.005 0 9.55
Waste 25.20 2.52 0 — 88.10
Water 139.00 2.27 0.05 — 212.00
Amortized Construction Emissions (30 years) 25.73
Total Project Emissions 4,573.78
Source: See Appendix B of this EIR for complete results.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-27
Notes: GHG = greenhouse gas; MT = metric tons; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent; R = refrigerants. <0.01 = reported value is less than 0.01.

Sustainable Santee Action Plan Project Consistency Checklist (Checklist) The Checklist is used to determine significance in accordance with CEQA Guidelines Section 15183.5; therefore, the Checklist was used to evaluate the Project’s significance with respect to GHG emissions. The City’s General Plan designates the Project site for Light Industrial uses and the site is zoned for Light Industrial, per the City’s Zoning Code. The proposed Project would be consistent with Chapter 13.14 of the City’s Municipal Code, which states that allowed industrial and related uses including warehousing/distribution, assembly and light manufacturing, repair facilities, and business parks, including corporate offices (City of Santee 2017, 2020). This zoning is consistent with the Light Industrial land use designation of the General Plan (City of Santee 2017, 2020).

Table 4.6-7 includes the applicable Checklist items and the related project consistency analysis. Please see Appendix C, Sustainable Santee Action Plan Project Checklist, of Appendix B to this EIR for complete details.

Table 4.6-7. Sustainable Santee Action Plan Project Checklist Check List Item Project Consistency
Measure 4.1. New commercial units meet or exceed
California Green Building Standards Tier 2 Voluntary
Measures such as obtain green building ratings including:

LEED, Build it Green, or Energy Star Certified buildings certification in scoring development and explain the
measures implemented.

Consistent. The Project will meet or exceed
CALGreen Tier 2 Standards in effect at the time
of the building permit application.

Documentation shall be provided to the City
demonstrating that the Project meets this
requirement prior to the issuance of the building
permit.

Measure 5.1 Project utilizes tree planting for shade and energy efficiency such as tree planting in parking lots and streetscapes.

Consistent. Landscaping will be installed in the
passenger parking area and around portions of
the buildings as well as site frontages, including
trees, shrubs and cover. See Figure 3-9 of the
Landscape Plan.

Measure 5.2. Project uses light-reflecting surfaces such as enhanced cool roofs on commercial buildings.

Consistent. Roof structures shall be designed to
include “cool roofs” materials with a minimum
aged reflectance and thermal emittance values
equal to or greater than the current CALGreen
Table A5.106.11.3, Tier 1.

Measure 6.1 Proposed project streets include sidewalks, crosswalks, and other infrastructure that promotes nonmotorized transportation options.

Consistent. The Project would include street,
sidewalk, and landscape improvements, as
shown on Figure 3-7, Conceptual Site Plan
Measure 7.1 Install electric vehicle chargers in all new residential and commercial developments.

Consistent. The Project includes 16 EVCS (EV
Capable Stall with EVSE). See site plan.

Measure 7.1 d. For new industrial and other Land Uses
employing 200 or more employees, install e-chargers for 5 percent of the total parking spaces.

Consistent. The Project includes 301 total
parking spaces. 301 x 0.05 = 15 spaces. The
Project includes 16 EVCS with EVSE.

Measure 8.1 Implement traffic flow improvement program Consistent. See Traffic Impact Analysis Section

9.2. The Project will install a stop-controlled (not
free) southbound right turn lane at the N.

Woodside Avenue/S. Woodside Avenue - SR-67
SB Off-Ramp intersection. to improve traffic flow.

Measure 9.1. Reduce waste at landfills. Consistent. The Project will include storage areas for recyclables and green waste as well as food
waste.

4.6 – GREENHOUSE GAS EMISSIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.6-28
Table 4.6-7. Sustainable Santee Action Plan Project Checklist Check List Item Project Consistency
Measure 10.1 c. On commercial buildings, install at least 2 kW per square foot of building area (e.g., 2,000 sqft = 3kW) unless the installation is infeasible due to poor solar resources.

Consistent. As stated in Project Design Feature
PDF-GHG-1 (see Section 3.3.3 of Chapter 3,
Project Description), the Project will include 450
kW of solar PV based on 300,145 SF /
(2,000SF/3kW)
Source: Appendix C, CAP Consistency Checklist, of Appendix B to this Draft EIR As shown in Table 4.6-7, the Project is consistent with the Sustainable Santee Action Plan Checklist adopted by the City to ensure that the emission targets identified in the Sustainable Santee Action Plan are achieved. The Sustainable Santee Action Plan determined that a project consistent with the Checklist would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Therefore, the Project would not generate GHG emissions that may have a significant impact on the environment; impacts would be less than significant.

4.6.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts to greenhouse gas emissions would be less than significant. No mitigation is required.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-1

4.7 Hazards and Hazardous Materials
This section describes the existing hazards and hazardous materials conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to the implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7 of Chapter 2 of this EIR), the following analysis is based, in part, on the Phase I Environmental Site Assessment (ESA) prepared by Hazard Management Consulting, Inc. on October 17, 2022, and included as Appendix I of this EIR.

4.7.1 Existing Conditions
Project Site Conditions
The approximately 13.5-acre Project site is currently developed with a two-screen drive-in theatre, including paved theatre parking lots, a building containing restrooms and a snack bar (concessions building), and two ticket booths.

The drive-in theatre has closed, but the Santee Swap Meet utilizes the site on the weekends.

The Project site boundary extends beyond the paved drive-in into an undeveloped area just north of the property and south of the San Diego River. The site is relatively flat with an elevation of approximately 355 feet above mean sea level with a regional slope to the west southwest. The site is located in the City of Santee, San Diego County and is set in an industrial use area located off of North Woodside Avenue.

Phase I Environmental Site Assessment Findings
A Phase I ESA was conducted to identify potential or existing environmental contamination on the site. The Phase I ESA was prepared for the Project in October 2022 by Hazard Management Consulting and included: documentation of a site walk of current conditions and neighboring facilities; a review of the regulatory database report; review of previously prepared reports for the site; submittal of questionnaires to the current owner and user of the site; review of historical references including aerial photographs, city directories, Sanborn Maps and topographic maps; on-line research and file review requests concerning the site and suspect off-site sources at the State of California Regional Water Quality Control Board (RWQCB) and Department of Toxic Substances Control (DTSC) websites; public records requests submitted to the City of Santee; public records requests submitted to the San Diego County Department of Environmental Health; public records submitted to the San Diego County Air Pollution Control District; and preparation of the findings (Appendix I).

Project Site
The site was first seen to have been agricultural land as late as the 1950s until the drive-in theatre was developed at the site in the mid-1960s. There is a low likelihood of a vapor intrusion condition at the site. Given the age of the building on site, asbestos-containing materials (ACM) and/or lead based paint (LBP) may be present at the site (Appendix I).

As part of the Phase I ESA, a database search report was obtained from Environmental Data Resources Inc. (EDR) and found that the Project site was not identified in an environmental records/regulatory database search, and no evidence of recognized environmental conditions (RECs) was found in connection to the Project site. The site

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-2
reconnaissance did not identify RECs, historical RECs, or controlled RECs on-site. Various chemicals were observed onsite including cleaning supplies, asphalt resurfacing material, gasoline, lubricants, and paint. Additionally, staining was observed on the asphalt surfaces at the site, likely from leaking vehicles parked at the facility as well as food and drink spills. However, per the Phase I ESA, these features are not considered RECs, and no evidence of RECs was found in connection to the Project site, including in the Project site vicinity (Appendix I).

Surrounding Areas
Since the 1960’s, the site is located in an area with a history of industrial uses. Facilities in the site vicinity were noted to use and store chemicals without evidence of release with the exception of a closed case for a release of oil from the adjacent facility to the east known as Western Construction Components and Circle K #2959 located approximately 0.20 miles to the south of the Project site. Additionally, the DTSC’s Envirostor Database identified one site within the vicinity of the Project site: Ketema Process Equipment Co., C/O Baker Process located adjacent to the Project site approximately 0.03 miles to the east. The case was closed in 1997 (Appendix I).

Specific land uses located in the immediate vicinity of the Project site include the following:
▪ North: San Diego River, with residential uses beyond
▪ East: Industrial and manufacturing uses, and Mission Park Court ▪ South: Manufacturing and commercial uses, North Woodside Avenue, and SR-67 ▪ West: Industrial and manufacturing uses, and Wheatlands Court Schools
The closest schools to the Project site include Hill Creek Elementary School, located approximately 0.25 miles north of the Project site, and Santana High School, located approximately 0.65 miles northeast of the Project site.

Airports
The closest airport to the Project site is Gillespie Field Airport, located approximately 1.5 miles southwest of the Project site. The Project site is located within the Gillespie Field Airport Influence Area (AIA), Review Area 2, and the FAA Height Notification Boundary. The Project site is located outside of safety and noise zones for the Gillespie Field Airport (SDCRAA 2010).

Wildfire Risk
The Project site is designated as a Local Responsibility Area (LRA) CAL FIRE and not located within any Fire Hazard Severity Zones (FHSZ). However, properties directly adjacent to the Project site to the north and to the east are designated as Very High Fire Hazard Severity Zones (VHFHSZ) in LRA (CAL FIRE 2023). The City of Santee General Plan Safety Element describes the City as a medium fire hazard area due to the significant amount of vacant land and brush-covered hills (City of Santee 2003). Wildfire risks associated with the Project are discussed in Section 4.14, Wildfire, of this EIR.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-3

4.7.2 Relevant Plans, Policies, and Ordinances
Federal
Federal Toxic Substances Control Act of 1976
The Federal Toxic Substances Control Act of 1976 tasked the U.S. Environmental Protection Agency (EPA) with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. The Federal Toxic Substances Control Act addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls, asbestos, radon, and lead-based paint (EPA 2022a).

Resource Conservation and Recovery Act of 1976
The objectives of the Resource Conservation and Recovery Act (RCRA) of 1976 are to protect human health and the environment from the potential hazards of waste disposal, conserve energy and natural resources, reduce the amount of waste generated, and ensure that wastes are managed in an environmentally sound manner. The Resource Conservation and Recovery Act affirmed and extended the “cradle-to-grave” system of regulating hazardous wastes. The use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by the Hazardous and Solid Waste Act. The Hazardous and Solid Waste Amendments of 1984 also added Subtitle I, which governs underground storage tanks (EPA 2022b).

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as “Superfund,” was enacted by Congress on December 11, 1980. This law provided broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA established requirements concerning closed and abandoned hazardous waste sites, provided for liability of persons responsible for releases of hazardous waste at these sites, and established a trust fund to provide for cleanup when no responsible party could be identified. CERCLA also enabled the revision of the National Contingency Plan. The National Contingency Plan provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The National Contingency Plan also established the National Priorities List, which is a list of contaminated sites warranting further investigation by EPA. CERCLA was amended by the Superfund Amendments and Reauthorization Act on October 17, 1986 (EPA 2023a).

Superfund Amendments and Reauthorization Act
The Superfund Amendments and Reauthorization Act amended CERCLA on October 17, 1986. The Superfund Amendments and Reauthorization Act had several changes and additions, including the following:
▪ Stressed the importance of permanent remedies and innovative treatment technologies in cleaning up hazardous waste sites
▪ Required Superfund actions to consider the standards and requirements found in other State and Federal environmental laws and regulations
▪ Provided new enforcement authorities and settlement tools ▪ Increased State involvement in every phase of the Superfund program

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-4
▪ Increased the focus on human health problems posed by hazardous waste sites ▪ Encouraged greater citizen participation in making decisions on how sites should be cleaned up ▪ Increased the size of the trust fund to $8.5 billion
The Superfund Amendments and Reauthorization Act also required the EPA to revise the Hazard Ranking System to ensure that it accurately assessed the relative degree of risk to human health and the environment posed by uncontrolled hazardous waste sites that may be placed on the National Priorities List (EPA 2023b).

Hazardous Materials Transportation Act
The U.S. Department of Transportation regulates hazardous materials transportation between states under the Code of Federal Regulations, Title 49, Chapter 1, Parts 100–185. In California, the California Department of Transportation (Caltrans) and the California Highway Patrol enforce federal law related to the transport of hazardous materials. Together, these agencies determine driver training requirements, load labelling procedures, and specifications for container types.

Occupational Safety and Health Act of 1970 and Occupational Safety and Health Administration The Occupational Safety and Health Act of 1970 was passed to prevent workers from being killed or seriously harmed at work. The Occupational Safety and Health Act created the Occupational Safety and Health Administration (OSHA), which sets and enforces protective workplace safety and health standards. OSHA also provides information, training, and assistance to employers and workers. Under the Occupational Safety and Health Act, employers have the responsibility to provide a safe workplace (OSHA 2014).

Federal Aviation Administration Functions
The Federal Aviation Administration (FAA) has primary responsibility for the safety of civil aviation. The FAA’s major functions regarding hazards include (1) developing and operating a common system of air traffic control and navigation for both civil and military aircraft, (2) developing and implementing programs to control aircraft noise and other environmental effects of civil aviation, (3) regulating U.S. commercial space transportation, (4) researching and developing the National Airspace System and civil aeronautics, (5) regulating civil aviation to promote safety, and (6) encouraging and developing civil aeronautics, including new aviation technology (FAA 2023a).

Federal Response Plan
The Federal Response Plan of 1999 (FEMA 1999) is a signed agreement among 27 federal departments and agencies, including the American Red Cross, that (1) provides the mechanism for coordinating delivery of federal assistance and resources to augment efforts of state and local governments overwhelmed by a major disaster or emergency; (2) supports implementation of the Robert T. Stafford Disaster Relief and Emergency Act, as well as individual agency statutory authorities; and (3) supplements other federal emergency operations plans developed to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant event likely to result in a need for federal assistance or in response to an actual event requiring federal assistance under a presidential declaration of a major disaster or emergency.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-5
State
Hazardous Materials Management Act
Requires that businesses handling or storing certain amounts of hazardous materials prepare a hazardous materials business plan, which includes an inventory of hazardous materials stored on site (above specified quantities), an emergency response plan, and an employee training program.

Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) Requires the governor to publish and update, at least annually, a list of chemicals known to the state to cause cancer, birth defects, or other reproductive harm and to inform citizens about exposures to such chemicals.

Hazardous Waste Management Planning and Facility Siting, also known as the Tanner Act (Assembly Bill 2948, 1986)
Requires counties to prepare, for California Department of Toxic Substance Control (DTSC) approval, hazardous waste management plans and prescribes specific public participation activities, which must be carried out during the local land use permit process for siting new or expanding off-site commercial treatment, storage, and disposal facilities.

California Environmental Protection Agency
The boards, departments, and offices that make up the California Environmental Protection Agency (CalEPA) include the California Air Resources Board, the Department of Pesticide Regulation, the Department of Resources Recycling and Recovery, DTSC, the Office of Environmental Health Hazard Assessment, and the State Water Resources Control Board. These boards, departments, and offices were placed within the CalEPA “umbrella” to create a cabinet-level voice for the protection of human health and the environment (such as clean air, clean water, clean soil, safe pesticides, and waste recycling and reduction) to assure the coordinated deployment of state resources (CalEPA 2023a).

Cortese List/Government Code Section 65962.5
Pursuant to Government Code, Section 65962.5, environmental regulatory database lists are compiled to identify and locate properties with known hazardous substance contamination (California Government Code, Section 65960 et seq.). Four state agencies are required to provide lists of facilities that have contributed to, harbor, or are responsible for environmental contamination within their jurisdiction. The four state agencies that are required to provide these lists to the Secretary for Environmental Protection include DTSC, the State Department for Health Services, the State Water Resources Control Board, and the California Integrated Waste Management Board. The Secretary for Environmental Protection then takes each of the four respective agency lists and forms one list, referred to as the Hazardous Waste and Substances Site List – Site Cleanup (Cortese List), which is made available to every city and/or county in California (CalEPA 2023b).

California Occupational Safety and Health Administration Cal/OSHA is the primary agency responsible for worker safety in the handling and use of chemicals in the workplace.

Cal/OSHA standards are generally more stringent than federal regulations. The employer is required to monitor worker exposure to listed hazardous substances and notify workers of exposure (8 California Code of Regulations [CCR], Sections 337–340). The regulations specify requirements for employee training, availability of safety equipment, accident prevention programs, and hazardous substance exposure warnings.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-6
California Hazardous Waste Control Law
The California Hazardous Waste Control Law (California Health and Safety Code, Division 20, Chapter 6.5) is administered by CalEPA to regulate the management of hazardous wastes. While the California Hazardous Waste Control Law is generally more stringent than the Resource Conservation and Recovery Act, until EPA approves the California Hazardous Waste Control Program (which is charged with regulating the generation, treatment, storage, and disposal of hazardous waste), both the state and federal laws apply in California. The Hazardous Waste Control Law lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills.

California Accidental Release Prevention Program
Similar to the Federal Risk Management Program, the California Accidental Release Prevention Program includes additional state requirements and an additional list of regulated substances and thresholds. The regulations of the program are contained in California Code of Regulations Title 19, Division 2, Chapter 4.5. The intent of the California Accidental Release Prevention Program is to prevent accidental releases of substances that can cause serious harm to the public and the environment, minimize the damage if releases do occur, and satisfy community right-toknow laws.

California Health and Safety Code
The handling and storage of hazardous materials is regulated by Division 20, Chapter 6.95, of the California Health and Safety Code. Under Sections 25500–25543.3, facilities handling hazardous materials are required to prepare a hazardous materials business plan. Hazardous materials business plans contain basic information on the location, type, quantity, and health risks of hazardous materials stored, used, or disposed of in the state. Chapter

6.95 of the California Health and Safety Code establishes minimum statewide standards for hazardous materials business plans.

In addition, in the event that a facility stores quantities of specific acutely hazardous materials above the thresholds set forth by the California Health and Safety Code, facilities are also required to prepare a risk management plan and California accidental release plan. The risk management plan and California accidental release plan provide information on the potential impact zone of a worst-case release and require plans and programs designed to minimize the probability of a release and mitigate potential impacts (California Health and Safety Code, Chapter 6.95).

Title 24 California Building Standards Code
California Building Code
California Building Standards Code Title 24, Part 2 contains the California Building Code. California Building Code Chapter 7A regulates building materials, systems, and/or assemblies used in the exterior design and construction of new buildings located within a fire hazard area. Fire hazard areas as defined by the California Building Code include areas identified as a Fire Hazard Severity Zone (FHSZ) within a State Responsibility Area or a wildland– urban interface fire area. The purpose of Chapter 7A is to establish minimum standards for the protection of life and property by increasing the ability of structures located in a fire hazard area to resist the intrusion of flames or burning embers projected by a wildfire, and to contribute to a systematic reduction in structural losses from a

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-7
wildfire. New buildings located in such areas must comply with the ignition-resistant construction standards outlined in Chapter 7A.

California Fire Code
California Building Standards Code Title 24, Part 9 contains the California Fire Code (CFC), which incorporates by adoption the International Fire Code with necessary California amendments. The purpose of the CFC is to establish the minimum requirements to safeguard the public health, safety, and general welfare from the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises, and to provide safety and assistance to firefighters and emergency responders during emergency operations. CFC, Chapter 49 contains minimum standards for development in the wildland–urban interface and fire hazard areas.

The CFC and Office of the State Fire Marshal provide regulations and guidance for local agencies in the development and enforcement of fire safety standards. The CFC is updated and published every 3 years by the California Building Standards Commission. The 2022 CFC took effect on January 1, 2023, and the City adopted the 2022 CFC with local amendments in November 2022.

California Code of Regulations, Title 14, Division 1.5
California Code of Regulations Title 14, Division 1.5, establishes the regulations for the California Department of Forestry and Fire Protection (CAL FIRE) and is applicable in all State Responsibility Areas—areas where CAL FIRE is responsible for wildfire protection. Most of the unincorporated area of San Diego County is a State Responsibility Area, and any development in State Responsibility Areas must comply with these regulations. Among other things, Title 14 Section 1270, et seq. establishes minimum standards for emergency access, fuel modification, setback to property line, signage, and water supply. The County of San Diego’s (County) most recent adoption of the Consolidated Fire Code (2020) was certified by the State Board of Forestry, indicating that its code requirements meet or exceed Title 14 Section 1270 et seq., and with that certification, the County Consolidated Fire Code supersedes Title 14 Section 1270 et seq. in the unincorporated areas of the County.

California Emergency Services Act
Under the Emergency Services Act (California Government Code, Section 8550 et seq.), the State of California developed an emergency response plan to coordinate emergency services provided by federal, state, and local agencies. Rapid response to incidents involving hazardous materials or hazardous waste is an integral part of the plan, which is administered by the Governor’s Office of Emergency Services. The Office of Emergency Services coordinates the responses of other agencies, including the EPA, California Highway Patrol, Regional Water Quality Control Boards (RWQCBs), air quality management districts, and county disaster response offices.

California Code of Regulations Title 5, Division 1, Chapter 13, Subchapter 1 – School Facilities Construction
California Code of Regulations Title 5, Division 1, Chapter 13, Subchapter 1 establishes minimum standards for siting of schools and school construction to provide safety for students and staff. The regulation establishes minimum distances that schools can be located from potential hazards such as power line easements and sets screening distances for other hazards that would require a safety study, such as a railroad track easement.

Section 14010(h) states that schools shall not be located near an above-ground water or fuel storage tank or within 1,500 feet of the easement of an above-ground or underground pipeline that can pose a safety hazard as

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-8
determined by a risk analysis study. Section 14010(t) states that if the proposed site is on or within 2,000 feet of a significant disposal of hazardous waste, the school district shall contact DTSC for a determination of whether the property should be considered a hazardous waste property or border zone property and unsuitable for school development.

South Coast Air Quality Management District – Rule 1403 The purpose of this rule is to specify work practice requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of asbestos-containing materials (ACM). The requirements for demolition and renovation activities include asbestos surveying, notification, ACM removal procedures and time schedules, ACM handling and clean-up procedures, and storage, disposal, and landfilling requirements for asbestos-containing waste materials (ACWM). All operators are required to maintain records, including waste shipment records, and are required to use appropriate warning labels, signs, and markings.

Local
San Diego County Department of Environmental Health
The San Diego County Department of Environmental Health (DEH) serves to protect the environment and enhance public health by preventing disease, promoting environmental responsibility and, when necessary, enforcing environmental and public health laws. Within DEH, the Hazardous Materials Division (HMD) protects human health and the environment by ensuring that hazardous materials, hazardous waste, medical waste and underground storage tanks are properly managed. To accomplish this goal, HMD regulates facilities that handle or store hazardous materials, are part of the California Accidental Release Prevention Program, generate or treat hazardous wastes or medical waste, store at least 1320 gallons of aboveground petroleum, and own or operate underground storage tanks. DEH identifies disposal locations for household hazardous waste as well as scheduled household waste collection events (DEH 2023).

Regional Water Quality Control Board
The Regional Water Quality Control Board (RWQCB) implements the California Water Code, which regulates waste discharges to land. If a discharge of waste threatens a water of the state, a report of waste discharge or an application for a waiver of a report of waste discharge must be filed with the RWQCB. The RWQCB accomplishes its permitting responsibility by issuing either a general or site-specific permit (Waste Discharge Permit) or a waiver of a permit.

County of San Diego Emergency Operations Plan
The San Diego County Emergency Operations Plan is a comprehensive emergency management system that provides for a planned response to disaster situations associated with natural disasters, technological incidents, and nuclear defense operations. The Emergency Plan includes operational concepts relating to various emergency situations, identifies components of the Emergency Management Organization and describes the overall responsibilities for protecting life and property and assuring the overall well-being of the population. The plan also identifies the sources of outside support that might be provided (through mutual aid and specific statutory authorities) by other jurisdictions, state and federal agencies, and the private sector (County of San Diego 2022).

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-9
County of San Diego, Consolidated Fire Code
The County, in collaboration with the local fire protection districts, created the first Consolidated Fire Code in 2001.

The Consolidated Fire Code contains the County and fire protection districts amendments to the California Fire Code. The purpose of consolidation of the County and local fire districts’ adoptive ordinances is to promote consistency in the interpretation and enforcement of the fire code for the protection of the public health and safety.

The ordinances include permit requirements for the installation, alteration, or repair of new and existing fire protection systems, and penalties for violations of the Consolidated Fire Code. The Consolidated Fire Code provides the minimum requirements for access, water supply and distribution, construction type, fire protection systems, and vegetation management. Additionally, the Consolidated Fire Code regulates hazardous materials and associated measures to ensure that public health and safety are protected from incidents relating to hazardous substance releases. San Diego County’s 2020 Consolidated Fire Code (the most recent adoption) was certified by the State Board of Forestry, resulting in its superseding California Code of Regulations Title 14, Section 1270 et seq., as it would otherwise apply within San Diego County (County of San Diego 2020).

San Diego County Multi-Jurisdictional Hazard Mitigation Plan The San Diego County Multi-Jurisdiction Hazard Mitigation Plan was originally prepared in July 2010 and updated in October 2017 to meet federal and state requirements for disaster preparedness to make the County eligible for funding and technical assistance from state and federal hazard mitigation programs. The plan includes a risk assessment to enable local jurisdictions to identify and prioritize appropriate mitigation actions to reduce losses from potential hazards, including flooding, earthquakes, fires, and man-made hazards. To address potential hazards, the plan then incorporates mitigation goals and objectives, mitigation actions and priorities, an implementation plan, and documentation of the mitigation planning process for each of the 22 participating jurisdictions, including Santee (County of San Diego 2017).

California Disaster and Civil Defense Master Mutual Aid Agreement As provided for in the California Emergency Services Act, the California Disaster and Civil Defense Master Mutual Aid Agreement was developed in 1950 and adopted by all 58 California counties. This statewide mutual aid system is designed to ensure that adequate resources, facilities, and other support is provided to jurisdictions whenever their own resources prove to be inadequate to cope with a given situation. San Diego County is located in Mutual Aid Region 6 of the state system, which also includes Imperial, Riverside, San Bernardino, Inyo, and Mono Counties (OES 2017).

Airport Land Use Compatibility Plan- Gillespie Field
The San Diego County Regional Airport Authority, designated as the Airport Land Use Commission for all public airports in the County of San Diego, adopted the Gillespie Field Airport Land Use Compatibility Plan (ALUCP) January 25, 2010 (last amended December 20, 2010). The ALUCP assists in achieving compatible land use development in the area surrounding Gillespie Field airport. Gillespie Field is a general aviation reliever airport located within the City of El Cajon. The ALUCP designates the airport influence area and contains projected noise contours, flight activity zones, a land use compatibility matrix, and plan recommendations for areas surrounding Gillespie Field.

The airport influence area is delineated by using the projected 60-decibel (dB) Community Noise Equivalent Level (CNEL) contour and is generally the area in which current and future airport-related noise, overflight, safety, and/or airspace protection factors may affect land uses or necessitate restrictions on uses. The airport influence area is divided into Review Area 1 and Review Area 2.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-10
The composition of each area is determined as follows (SDCRAA 2010):
▪ Review Area 1 consists of locations where noise or safety concerns may necessitate limitations on the types of land use actions. Specifically, Review Area 1 encompasses locations exposed to aircraft noise levels of 60 dB CNEL or greater together with all of the safety zones identified in the ALUCP. ▪ Review Area 2 consists of locations beyond Review Area 1 but within the airspace and/or overflight notification areas. Limits on the heights of structures, particularly in areas of high terrain, are the only restrictions on land uses within Review Area 2.

The Project site is within the Gillespie Field Airport Influence Area Review Area 2, overflight notification area, and the FAA Height Notification Boundary (SDCRAA 2010). The Project site is located outside of the noise exposure ranges and safety zones for the airport (SDCRAA 2010).

City of Santee Hazard Mitigation Plan
The purpose of the Hazard Mitigation Plan is to identify risks and ways to mitigate damage from natural and humancaused disasters. Goal 7 of the Plan, Hazardous Materials Release, outlines objectives and actions to monitor and prevent the release of hazardous materials, along with educational awareness to the public about the dangers (City of Santee 2023).

Santee General Plan
The City’s General Plan contains objectives and policies aimed at minimizing potential risks associated with hazards and hazardous materials. The Safety Element of the General Plan aims to reduce loss of life, injuries, and damage to property resulting from natural and human-caused public safety hazards including flooding, geologic and seismic hazards, fire, traffic hazards and crime. Related objectives and policies of the Safety Element are listed below (City of Santee 2003).

Objective 3.0 Minimize the risk of damage to persons, property and the environment caused by hazardous materials.

Policy 3.1 The City shall continue to implement the County’s Hazardous Waste Management Plan or develop and implement an equivalent plan.

Policy 3.2 The City shall continue to participate in the Hazardous Materials Incident Response Team in dealing with hazardous materials incidents.

Policy 3.3 The City shall require that any potential hazardous materials issues be fully investigated at the environmental review stage prior to project approval.

Policy 3.4 The City shall review any proposed uses involving the use, transport, storage or handling of hazardous waste to ensure that such uses will not represent a significant risk to surrounding uses or the environment.

Policy 3.5The City shall continue to provide for a household hazardous waste collection program for City residents as part of the contract with the City trash franchisee.

Policy 3.6The City shall control the location, manufacture, storage or use of hazardous materials in Santee through Zoning Ordinance implementation and the Development Review process.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-11
Policy 3.7Encourage safe and proper disposal of household hazardous waste.

Objective 4.0 Minimize injuries, loss of life and property damage resulting from fire hazards.

Policy 4.2 The City should ensure that all new development meets established response time standards for fire and life safety services.

Policy 4.4The City shall require emergency access routes in all developments to be adequately wide to allow the entry and maneuvering of emergency vehicles.

Policy 4.8Encourage and support the delivery of a high level of emergency services through cooperation with other agencies and use of available financial opportunities.

Policy 4.9All proposed development shall satisfy the minimum structural fire protection standards contained in the adopted edition of the Uniform Fire and Building Codes; however, where deemed appropriate the City shall enhance the minimum standards to provide optimum protection.

Policy 4.10Encourage the continued development, implementation and public awareness of fire prevention programs.

Policy 4.11 In order to minimize fire hazards, the Santee Fire and Life Safety Department shall routinely be involved in the review of development applications. Considerations shall be given to adequate emergency access, driveway widths, turning radii, fire hydrant locations and needed fire flow requirements.

Policy 4.12The timing of additional fire station construction or renovation, or new services shall relate to the rise of service demand in the City and surrounding areas.

Policy 4.13Support mutual aid agreements and communications links with County and the other municipalities participating in the Unified San Diego County Emergency Service Organization Objective 7.0 Minimize injuries, loss of life, and property damage resulting from airport hazards.

Policy 7.1 The City should review all development proposed within the Gillespie Field Airport Influence Area to ensure that design features are incorporated into the site plan to address identified aircraft safety and noise hazards.

Santee Municipal Code
The Santee Municipal Code (SMC) is a compilation of the Santee City Charter and all regulatory and penal ordinances and certain administrative ordinances adopted by the City Council. The SMC includes Chapter 11.04, California Building Code, Chapter 11.18, California Fire Code, and Chapter 11.24, Construction and Improvement Standards (City of Santee 2023c).

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-12

4.7.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to hazards, hazardous materials, and wildfire are based on California Environmental Quality Act (CEQA) Guidelines Appendix G. According to CEQA Guidelines Appendix G, a significant impact related to the Project would occur if the Project would:

A. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

B. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

C. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

D. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment.

E. Be located within an airport land use plan, be within two miles of a public airport, and would result in a safety hazard or excessive noise for people residing or working in the Project area.

F. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

G. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

4.7.4 Impacts Analysis
A. Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Construction Impacts
Less than Significant Impact. Construction of the proposed Project would involve the transport of commonly used hazardous substances, such as gasoline, diesel fuel, lubricating oil, grease, and solvents. However, hazardous materials are highly regulated in California, including the methods by which they are transported, used, and stored.

All such uses of these substances would be subject to applicable and required regulatory controls as described above under Section 4.7.2. The proposed Project would be required to comply with all applicable federal, state, and local standards related to hazardous materials and wastes, such as controls on use, handling, storage, transportation, and disposal. Specifically, handling and storage of hazardous materials is regulated by Division 20, Chapter 6.95, of the California Health and Safety Code. Additionally, construction is temporary and use of these materials would cease upon completion. The use of these materials for their intended purpose would not pose a significant risk to the public or environment. Therefore, impacts would be less than significant during construction.

Operational Impacts
Less than Significant Impact. Upon completion of Project construction, the Project would involve the operation and maintenance of the industrial/warehouse facilities. The precise user/occupant of the warehouse is not known at this time. Operation of the Project could involve the use of industrial-grade chemicals and commercially available

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-13
cleaning products, landscaping chemicals and fertilizers, and various other commercially available products during the day-to-day operation of the facilities. While these materials could be stored on the Project site, storage would be required to comply with the guidelines established by the manufacturer’s recommendations. Consistent with federal, state, and local requirements, the transport, removal, and disposal of hazardous materials from the Project site would be conducted by a permitted and licensed service provider. Any handling, transport, use, or disposal must comply with all applicable federal, state, and local agencies and regulations, including the EPA, Department of Toxic Substances Control, CAL/OSHA, RCRA, and the Santee Fire Protection District.

As mentioned in the General Plan, the City is under the jurisdiction of the Hazardous Material Division of the County of San Diego’s Department of Environmental Health, which assists regulated businesses in the City in developing their business plans, as well as developing an area plan for hazardous material emergency response coordination in the City and County (City of Santee 2003). Although the proposed Project could result in the increase in routine transport, use and disposal of hazardous materials and/or wastes, all hazardous materials would be transported and handled in accordance with all federal, state, and local laws regulating the management and use of hazardous materials. Therefore, impacts would be less than significant during operation.

B. Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Construction Impacts
Less than Significant Impact. As discussed under Threshold A, construction of the Project could involve the transport of commonly used hazardous substances, such as gasoline, diesel fuel, lubricating oil, grease, and solvents. Construction materials would be used and stored in designated construction staging areas within the Project site boundaries and materials would be transported and handled in accordance with all federal, state, and local laws regulating the management and use.

The Phase I ESA notes that due to the age of the on-site buildings and structures, it is likely that asbestos-containing materials (ACM) were used in their construction. Demolition of these buildings and structures can cause encapsulated ACM to become friable and, once airborne, would be considered a carcinogen. A carcinogen is a substance that causes cancer or helps cancer grow. Such releases could pose significant risks to persons living and working in and around the project area, as well as to project construction workers. Due to this likelihood of ACMs being present in existing on-site buildings, as required by the National Emission Standards for Hazardous Air Pollutants (NESHAP) For Asbestos a pre-demolition ACM survey would be conducted prior to any disturbance of suspected ACMs (EPA 2024).

Abatement of all ACM encountered during any future building demolition activities would be required to be conducted in accordance with all applicable laws and regulations, including those of the EPA (which regulates disposal), OSHA, U.S. Department of Housing and Urban Development, Cal/OSHA (which regulates employee exposure), and SCAQMD.

For example, the EPA requires that all asbestos work performed within regulated areas be supervised by a person who is trained as an asbestos supervisor (EPA Asbestos Hazard Emergency Response Act, 40 CFR 763). SCAQMD’s Rule 1403 requires that buildings undergoing demolition or renovation be surveyed for ACM prior to any demolition or renovation activities. Should ACM be identified, Rule 1403 requires that ACM be safely removed and disposed of at a regulated disposal site, if possible. If it is not possible to safely remove ACM, Rule 1403 requires that safe procedures be used to demolish the building with asbestos in place without resulting in a significant release of

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-14
asbestos to the environment. Additionally, during demolition, grading, and excavation, all construction workers would be required to comply with the requirements of Title 8 of the California Code of Regulations, Section 1529 (Asbestos), which provides the exposure limits, exposure monitoring, respiratory protection, and good working practices by workers exposed to asbestos.

Due to the age of on-site buildings, the Phase 1 ESA also noted lead-based paint (LBP) was likely used in construction of onsite structures. Proposed demolition of existing structures may pose a risk of exposure of workers to lead-based paint present in building materials. In compliance with Cal/OSHA regulations, surveys for indicators of lead-based coatings, and flakes in soil, would be conducted before demolition to further characterize the presence of lead on the project site. Loose or peeling paint may be classified as a hazardous waste if concentrations exceed total threshold limits. Cal/OSHA regulations require air monitoring, special work practices, and respiratory protection during demolition and paint removal where even small amounts of lead have been detected.

Mandatory compliance with these regulatory requirements would ensure that construction workers and the public are not exposed to ACM and LBP health hazards during demolition. Therefore, impacts associated with reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment during construction of the Project would be less than significant.

Operational Impacts
Less than Significant Impact. Once Project construction is complete, the transport, use, or disposal of hazardous materials could include industrial-grade chemicals and commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially available products associated with industrial/warehouse uses. As previously discussed, all hazardous materials would be transported and handled in accordance with all federal, state, and local laws regulating the management and use of hazardous materials. Therefore, impacts associated with reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment during operation of the Project would be less than significant.

C. Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Less than Significant Impact. The only existing school located within one-quarter mile of the site is Hill Creek Elementary School, located approximately 0.25 miles north of the Project site. The next closest existing school near the Project site is Santana High School, located approximately 0.65 miles northeast of the Project site. As discussed in Section 4.2, Air Quality of this Draft EIR, construction, and operation of the project would also result in less than significant impacts to air quality. As discussed in Thresholds A and B, above, construction materials would be used and stored in designated construction staging areas within the Project site boundaries and materials would be transported and handled in accordance with all federal, state, and local laws regulating the management and use.

Additionally, all hazardous materials used during operation of the Project would be transported and handled in accordance with all federal, state, and local laws regulating the management and use of hazardous materials. As discussed above under Threshold A, the proposed Project would result in less-than-significant impacts related to the routine transport, use, or disposal of hazardous materials, and discussed above under Threshold B, the proposed Project would result in less-than-significant impacts related to the reasonably foreseeable upset and accident conditions involving the release of hazardous materials. Therefore, impacts to schools within one-quarter mile of the project site would be less than significant.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-15
D. Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment?
Less than Significant Impact. As outlined in Section 4.7.1, Existing Conditions, a database search report was obtained from EDR, which documents findings of various federal, state, and local regulatory database searches regarding properties with known or suspected releases of hazardous materials. The results of the database search found that the Project site was not identified by EDR on any government list of hazardous materials (Appendix I).

However, the State Water Resources Control Board’s GeoTracker Database identified two listed sites within the vicinity of the Project site: Western Construction Component (T0608164832), located adjacent to the Project site approximately 0.03 miles to the east, and Circle K #2959 (T0608102609), located approximately 0.20 miles to the south of the Project site. The Western Construction Component Cleanup Program Site is a completed case, as of 1997, with waste oil/ motor/ hydraulic/ lubricating potential contaminants of concern. The Circle K #2959 Cleanup Program Site is a completed case as of 1999, with gasoline potential contaminants of concern (SWRCB 2023). Additionally, the DTSC’s Envirostor Database identified one site within the vicinity of the Project site: Ketema Process Equipment Co., C/O Baker Process (71003382), located adjacent to the Project site approximately

0.03 miles to the east. Ketema Process Equipment Co., C/O Baker Process is a Tiered Permit Cleanup Site with no action required as of 1998 (DTSC 2023).

Although some facilities located near the project site have been previously included in government databases related to hazardous materials, as discussed above, these facilities are closed cases and would not have adverse impacts on the Project (for further information regarding databases refer to Appendix I). Therefore, impacts associated with the Project being located on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 would be less than significant.

E. Would the Project be located within an airport land use plan, be within two miles of a public airport, and result in a safety hazard or excessive noise for people residing or working in the Project area? Less than Significant Impact. The nearest airport to the Project site is the Gillespie Field Airport, which is located approximately 1.5 miles southwest of the Project site. As discussed in Section 4.7.1, the Project site is located outside of the noise exposure ranges and safety zones for the airport (SDCRAA 2010).

The Project site falls within Gillespie Field Review Area 2, which requires limitations on the height of structures (i.e., any proposed object in an area of terrain penetration to airspace surface which has a height greater than 35 feet above ground level). The Project site also falls within the FAA Height Notification Boundary. Within this boundary, the Federal Aviation Administration (FAA) shall be notified of any proposed construction or alteration having a height greater than an imaginary surface extending 100 feet outward and 1 foot upward (slope of 100 to 1) from the runway elevation. Review Area 2 also requires overflight notification documents for residential uses; however, no residential uses are proposed so no conflict would occur. To ensure compliance with Gillespie Field Review Area 2 requirements and FAA Height Notification boundaries, ALUC review and FAA Notification of the Project would be required. The Project applicant has received documentation from the FAA stating that the structure does not exceed obstruction standards and would not be a hazard to air navigation provided certain conditions are included in the Project (FAA 2023b). Therefore, implementation of the proposed project would result in a less than significant impact related to airspace safety hazards or conflicts with the Gillespie Airport Land Use Compatibility Plan.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-16
F. Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less than Significant Impact. The proposed Project may result in a temporary increase in traffic on roadways surrounding the Project site due to increased truck loads or the transport of construction equipment to and from the Project site during the construction period. All construction activities including staging would occur in accordance with City requirements which would ensure that adequate emergency access would be provided during construction of the Project.

Emergency response to the Project site would be serviced by the Santee Fire Department, San Diego County Sheriff’s Department, and other responsible agencies. Furthermore, the City is part of San Diego County Emergency Operations Plan (EOP), which discusses evacuation procedures in the event of an emergency. As stated in the Emergency Operations Plan, primary evacuation routes consist of the major interstates and prime arterials. As previously stated, all construction activities including staging would occur in accordance with City requirements, which would ensure that adequate emergency access would be provided during construction of the Project.

Additionally, Project construction would not require the road closures. Construction of the Project is not anticipated to interfere with an adopted emergency response plan or evacuation plan, nor would it substantially impede public access or roadway circulation.

Direct access to the Project site would be provided via N. Woodside Avenue. The existing driveway currently bordering the east and south side of the Project site would be extended to loop around the entire project site in order to allow fire lane access from all sides of the building. Consistent with the Santee Fire Department access requirements, all Project driveways have been designed to allow for minimum turning radii. Signage and striping would be provided to demarcate fire lanes and clear spaces throughout the site. All gated entryways would include rapid-access Knox boxes to provide emergency access to gated areas. Additionally, road improvements would be constructed to current Fire Codes and City of Santee standards for public and private roads.

Therefore, the Project would not interfere with an adopted emergency response or emergency evacuation plan during construction or operation activities; impacts would be less than significant.

G. Would the Project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
As discussed in Section 4.7.1, above, the California Department of Forestry and Fire Protection’s (CAL FIRE) Fire Hazard Severity maps indicate that the Project site is not classified as a VHFHSZ in LRA, however the Project site is bordered to the north and east by land classified as very high under the LRA. Additionally, there is State Responsibility Area land classified as very high less than one mile northeast of the project site. The Project site is bordered to the north by Open Space and the San Diego River. This area is comprised of various vegetation communities and land covers, described in Section 4.3 Biological Resources, that may exacerbate fire risk.

Construction
Less than Significant Impact. The Project would involve the demolition of all existing on-site structures and the construction of a 300,145 square foot industrial/warehousing building. The Project would include 290,145 square feet of warehouse space and 10,000 square feet of office space, as well as associated improvements including loading docks, trailer stalls, passenger vehicle parking spaces, and street, sidewalk, and landscape improvements.

Construction of the Project would introduce potential ignition sources to the Project site, including the use of heavy

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-17
machinery and the potential for sparks during welding activities or other hot work. However, the Project would be required to comply with the California Fire Code (CFC) and California Building Code (CBC) standards to reduce the possibility of fires during construction activities. The Project would comply with CFC Section 3304 for precautions against fire during construction activities. Access for firefighting would be maintained throughout construction per CFC Section 3310.1. Any motorized equipment within the site would comply with fire protection regulations outlined in CFC Section 3316. Adherence to City and state regulatory standards during Project construction would reduce the risk of wildfire ignition and spread during construction activities. In the case of accidental ignition, the site is required to have no less than one portable extinguisher at each level where combustible materials have accumulated, in every storage or construction shed, and where any additional hazards exist (CFC Section 3315).

Therefore, short-term construction impacts associated with exposing people or structures to a significant risk of loss, injury, or death involving wildland fires would be less than significant.

Operation
Less than Significant Impact. During operation, the Project would adhere to the City’s Municipal Code and the CFC. The Project would be required to have and maintain fire protection and life safety systems (CFC Chapter 9).

The Project would not facilitate wildfire spread or exacerbate wildfire risk or expose people or structures, indirectly or directly, to significant wildfire risk. It is not anticipated that the Project, due to slope, prevailing winds, and other factors, would exacerbate wildfire risks or expose Project occupants to pollutant concentrations from a wildfire, the uncontrolled spread of a wildfire, or significant risks associated with wildfires. Therefore, long-term operational impacts associated with exposing people or structures to a significant risk of loss, injury, or death involving wildland fires would be less than significant.

4.7.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to hazards and hazardous materials would be Iess than significant. No mitigation is required.

4.7 – HAZARDS AND HAZARDOUS MATERIALS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.7-18

INTENTIONALLY LEFT BLANK

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-1

4.8 Hydrology and Water Quality
This section describes the existing hydrology and water quality conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7, Documents Incorporated by Reference, of Chapter 2, Introduction, of this Draft EIR), the following analysis is based, in part, on the following sources:
▪ Preliminary Hydrology Study for Palisade Santee Business Center, prepared by DRC Engineering, Inc. in January 2024 (Appendix J-1)
▪ City of Santee Priority Development Project (PDP), Storm Water Quality Management Plan (SWQMP), prepared by DRC Engineering, Inc. in March 2023 (Appendix J-2) ▪ Letter to City of Santee regarding the 100-Year Floodplain, by DRC Engineering, Inc. in July 2023 (Appendix J-3)

4.8.1 Existing Conditions
Regional Watershed
The U.S. Geological Survey Watershed Boundary Dataset delineates watersheds according to hydrologic units, which are nested within one another according to the scale of interest. The U.S. Geological Survey identifies hydrologic units by name and by hydrologic unit code (HUC). For example, at a statewide scale, hydrologic units consist of large regions and sub-regions draining to a common outlet. At a statewide scale, the proposed Project is within the 11,100-square-mile “Southern California Coastal” subregion (HUC 1807), which identifies areas that eventually drain to the Pacific Ocean versus those that drain to the interior deserts of California. At the highest level of detail for the Watershed Boundary Dataset, the Project site is located within the San Diego River Watershed Management Area (WMA) (Figure 4.8-1, San Diego River Watershed) (County of San Diego 2023).

More specifically, the Project site is located in U.S. Geological Survey-designated San Diego Hydrologic Unit (907), Lower San Diego Hydrologic Area (907.1), Santee Subwatershed (907.12) (Appendix J-2). The San Diego River Watershed originates in the mountains of east San Diego County, near Julian, and drains to the Pacific Ocean in Ocean Beach. The watershed encompasses 434 square miles, making it the second largest watershed management area in San Diego County. The watershed borders Los Penasquitos and San Dieguito River Watersheds to the north and San Diego Bay watershed management area to the south. Currently, about 44% of the San Diego Watershed is undeveloped; 23% consists of open space and park; 19% is residential; 6% transportation uses; and 2% other uses. The San Diego Watershed supplies approximately 760,000 individuals with potable water sourced from one of five reservoirs, including Lake Murray, Lake Jennings, San Vicente, El Capitan, and Cuyamaca Reservoirs. The majority of these reservoirs are located in the eastern half of the San Diego Watershed, upstream from the Lower San Diego Hydrologic Area (Project Clean Water 2022).

Topography and Drainage
The Project site is located on relatively flat to gently sloping topography, immediately south of the San Diego River.

The topography slopes toward the river, from south to north, with a change in topography of a few feet (Appendix G). Drainage on-site occurs as sheet flow towards the northwest portion of the site and into the San Diego River

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-2
over natural terrain, with no on-site storm drains (Figure 4.8-2, Existing Hydrology Map). Approximately 3.5 acres of offsite run-on currently flows onto the site. An existing 24-inch culvert located under Interstate 67 outlets at the entrance of the site, off of Woodside Avenue. This culvert collects approximately 2.8 acres from the freeway as well as the southern portion of Woodside Drive. An additional 0.7 acres covering the northern portion of Woodside Drive collects in the curb and gutter, from south of Wheatlands Drive, and outlets at the existing entrance of the site. In total, approximately 16.8 acres of tributary area, including on-site runoff and run-on, flows to the northwest portion of the Project site (Appendix J-1, Hydrology Study).

Beneficial Uses and Total Maximum Daily Loads
The State Water Resources Control Board (SWRCB) establishes statewide water quality control policy and regulation. The SWRCB also oversees the nine Regional Water Quality Control Boards (RWQCBs) in California, which are responsible for designating beneficial uses, establishing water quality objectives to protect those uses, and identifying programs of implementation to meet objectives through the preparation of a basin plan. The Water Quality Control Plan for the San Diego Basin (Basin Plan) (San Diego RWQCB 2021) lists beneficial uses of major water bodies within the region. San Diego River is an inland surface water body with designated beneficial uses in the Basin Plan. Existing beneficial uses are summarized in Table 4.8-1, Basin Plan Beneficial Uses, Surface Water, and descriptions of the beneficial use categories are as follows:
▪ AGR: Agricultural supply waters used for farming, horticulture, or ranching. ▪ COLD: Freshwater Habitat that support cold water ecosystems including the preservation or enhancement of aquatic habitats, vegetation, fish or wildlife, and invertebrates. ▪ IND: Industrial activities that do not depend primarily on water quality. ▪ MUN: Community, military, or individual water supply systems including, but not limited to, drinking water supply. ▪ PROC: Industrial process supplies that includes the use of water for industrial activities that depend primarily on water quality.
▪ RARE: Waters that support habitats necessary, at least in part, for the survival and successful maintenance of plant or animal species established under state or federal law as rare, threatened, or endangered. ▪ REC1: Water contact recreation involving body contact with water and ingestion is reasonably possible. ▪ REC2: Non-contact water recreation for activities in proximity to water, but not involving body contact. ▪ WARM: Warm freshwater habitat to support water ecosystems. ▪ WILD: Wildlife habitat water that support terrestrial or wetland ecosystems.

Table 4.8-1. Basin Plan Beneficial Uses, Surface Water
Water Body
Beneficial Uses
MUN AGR IND PROC REC1 REC2 WARM COLD WILD RARE
San Diego River X X X X X X X X X X
Source: Table 2-2 of San Diego RWQCB 2021.

Ä67
Ä125
Ä52
Ä56
Ä75
Ä163
Ä54
Ä94
§¨805
§¨8
§¨15
§¨5

S A N D I E G U I T O

C A R L S B A D

S A N D I E G O

P E N A S Q U I T O S

S W E E T W A T E R

P U E B L O

S A N D I E G O
S A N

D I E G O B A Y

O T A Y

T I J U A N A
San Diego River Watershed
Palisade Santee Commerce Center Project
SOURCE: ESRI 2022, Open Street Maps 2019, Project Clean Water 2022 Date: 5/14/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx 0 2 4
n Miles
Watersheds
Carlsbad
Otay
Penasquitos
Pueblo San Diego
San Diego
San Diego Bay
San Dieguito
Sweetwater
Tijuana
Project Site
!(^
FIGURE 4.8-1

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-4

INTENTIONALLY LEFT BLANK
'DWH
/DVWVDYHGE\
NEDUURZ3DWK
=
?3URMHFWV?M?0$3'2&?'2&80(17?'UDIWB(,5
),*85( 4..8-2
Existing Hydrology Map
3DOLVDGH6DQWHH&RPPHUFH&HQWHU3URMHFW
6285&(
DRC Engineering 2024

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-6

INTENTIONALLY LEFT BLANK

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-7
The Project site is located adjacent to the Upper San Diego River, per classification by the SWRCB. Based on the 2014/2016 California Integrated Report, Clean Water Act (CWA) Section 303(d) List/305(b) Report, pollutants in this stretch of the river include indicator bacteria and dissolved oxygen. Total maximum daily loads (TMDLs) have been established for both of these pollutants (SWRCB 2023a).

General Watershed Water Quality
Of the hydrologic areas located within the San Diego River Watershed, the Lower San Diego Hydrologic Area is the most urbanized and suffers from the most pronounced water quality problems. At approximately 110,000 acres, this hydrologic area is the largest and represents approximately 40% of the watershed. Due to its geographic extent, oversight of the storm drain systems within the Lower San Diego Hydrologic Area falls on a number of Co-permittees, including the County of San Diego, in combination with the Cities of Santee, El Cajon, La Mesa, and San Diego. At the point where the San Diego River meets the Pacific Ocean in Ocean Beach, lies a 37-acre wetland, Famosa Slough, which is managed by the City of San Diego (Project Clean Water 2022).

Water quality data were collected along the lower San Diego River from 2004 through 2018 for several pollutants of concern including conventional parameters, nutrients, metals, pathogen indicators, and municipal supply constituents. The selected general constituents examined include dissolved oxygen (DO), turbidity, total dissolved solids (TDS), total suspended solids (TSS), and oil and grease. DO is a measure of the amount of gaseous oxygen dissolved in the water. Turbidity is a measure of suspended matter that interferes with the passage of light through the water or in which visual depth is restricted. TDS measures the dissolved cations and anions in water, primarily inorganic salts (calcium, magnesium, potassium, sodium, chlorides, and sulfates). High TDS levels can impair agricultural, municipal supply, and groundwater recharge beneficial uses. TSS measures the particulate matter suspended in water. Oil and grease is a measure of fats, oils, waxes, and other related constituents in water (Geosyntec 2019; SDSU 2020).

The data collected along the lower San Diego River indicate that the lower San Diego River may not be meeting water quality standards for DO over the study period (2004–2018) during the dry season. The Basin Plan objective states that the annual mean DO concentration should not be less than 7 milligrams per liter (mg/L) more than 10% over the study period. All of the DO measurements collected were less than 7 mg/L; however, only six measurements were collected over the 11-year span. Water quality data for turbidity indicate that the Basin Plan standard of 20 Nephelometric Turbidity Units (NTU) is being met along the lower San Diego River for the wet season and the dry season. Average turbidity measures during the wet season and the dry season are 4.63 NTU and 3.72 NTU, respectively. The Basin Plan does not identify a numeric standard for TSS, and the available TSS data do not indicate that TSS is a cause of “nuisance or adverse effects to beneficial waters.” Oil and grease data were collected on four occasions between 2013 and 2014. All oil and grease results were below the reporting limit, indicating that concentrations are not at levels that would “cause nuisance or which otherwise adversely affect beneficial uses” (Geosyntec 2019; SDSU 2020).

Water Supply
As discussed in more detail in Section 4.13, Utilities and Service Systems, domestic water service is provided to the Project area by the Padre Dam Municipal Water District (PDMWD). The primary potable water supply source within the PDMWD’s service area is imported water from the San Diego County Water Authority, through three connections. The potable water supply is imported from the California State Water Project and the Colorado River by Metropolitan Water District of Southern California. In addition, the San Diego County Water Authority purchases up to 50,000 acre-feet per year from the Carlsbad Desalination Plant. The PDMWD’s water supplies also include

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-8
recycled water and a very small amount of groundwater from one well in the Santee Basin, which supplements the recycled water system. The well is unreliable; therefore, groundwater supplies from the well are assumed to not be available as a future supply and the PDMWD has no plans for other groundwater supplies in the future (PDMWD 2021). In 2022, groundwater comprised 6% of the water supplies from the San Diego County Water Authority. By 2045, groundwater is expected to comprise 4% of their water supply (PDMWD 2023).

Groundwater
All major watersheds in the San Diego region contain groundwater basins, which are defined as a hydrogeologic unit containing one large aquifer, as well as several connected and interrelated aquifers. The San Diego River WMA contains three groundwater basins: Mission Valley, San Diego River Valley, and El Cajon Valley. The Project site overlies the San Diego River Valley Groundwater Basin, which consists of alluvium deposited by the San Diego River and its tributaries. The basin is surrounded by contacts with semi-permeable rocks of the Eocene Poway Group, impermeable Cretaceous crystalline rock, and impermeable Jurassic to Cretaceous Santiago Peak volcanic rocks.

The Quaternary alluvium forms the principal water-bearing unit within the basin (California DWR 2004).

The San Diego River Valley Groundwater Basin is classified as a very low priority basin with respect to the Sustainable Groundwater Management Act (SGMA). Overall, groundwater only accounts for about 5% of the San Diego region’s water supply portfolio. Local groundwater supplies are limited by several factors, including little recharge due to sparse rainfall (San Diego County Water Authority 2023; SWRCB 2023b). The San Diego River Valley Groundwater Basin only includes five water supply wells and groundwater only accounts for approximately 4% of the water supply in the basin. With respect to SGMA, groundwater supply in the San Diego River Valley Basin is within the jurisdiction of the San Diego River Valley Groundwater Sustainability Agency (Groundwater Exchange 2023; SWRCB 2023b).

Groundwater Quality
Groundwater in the alluvial aquifer of the San Diego River Valley Groundwater Basin varies in character. The eastern portion of the basin contains water of a bicarbonate character, while the western portion contains water of a chloride character. TDS content ranges from 260 to 2,870 mg/L, with higher values to the west and lower values to the east. The Department of Health Services data for two wells show the TDS concentration ranging from 591 to 870 mg/L (California DWR 2004).

The Basin Plan designates existing or potential beneficial uses for the San Diego River Valley Groundwater Basin beneath the Project site. Existing beneficial uses are summarized in Table 4.8-2, Basin Plan Beneficial Uses, Groundwater (San Diego RWQCB 2021).

Table 4.8-2. Basin Plan Beneficial Uses, Groundwater
Water Body
Beneficial Uses
AGR IND REC1 REC2 BIOL WARM WILD RARE
San Diego River Valley
Groundwater Basin

X X X X X X X X
Source: Table 2-5 of San Diego RWQCB 2021.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-9
Flood Hazards
As illustrated in Figure 4.8-3, Flood Map, the northern boundary of the Project site is adjacent to a regulatory floodway (FEMA 2023). The Project site has been designed to match the existing contours along the San Diego River as to not impact the existing floodplain, and the Project building will be held more than one foot above the floodplain in accordance with City of Santee Flood Damage Prevention Ordinance, Chapter 11.36. The Project will not impact the FEMA floodplain.

4.8.2 Relevant Plans, Policies, and Ordinances
Federal
Clean Water Act
The Clean Water Act (CWA), as amended by the Water Quality Act of 1987, is the major federal legislation governing water quality (33 USC 1251 et seq.). The objective of the CWA is “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” The CWA establishes basic guidelines for regulating discharges of both point and non-point sources of pollutants into the waters of the United States. The CWA requires that states adopt water quality standards to protect public health, enhance the quality of water resources, and ensure implementation of the CWA. Relevant sections of the CWA are as follows:
▪ Sections 303 and 304 provide for water quality standards, criteria, and guidelines. Under Section 303(d) of the CWA, the State of California is required to develop a list of impaired water bodies that do not meet water quality standards and objectives. California is required to establish TMDLs for each pollutant/stressor. A TMDL defines how much of a specific pollutant/stressor a given water body can tolerate and still meet relevant water quality standards. Once a water body is placed on the Section 303(d) List of Water Quality Limited Segments, it remains on the list until a TMDL is adopted and the water quality standards are attained or there is sufficient data to demonstrate that water quality standards have been met and delisting from the Section 303(d) list should occur. ▪ Section 401 (Water Quality Certification) requires an applicant for any federal permit that proposes an activity that may result in a discharge to waters of the United States to obtain certification from the state that the discharge will comply with other provisions of the CWA. This process is known as the Water Quality Certification/Waste Discharge Requirements process.
▪ Section 402 (National Pollutant Discharge Elimination System) establishes the National Pollutant Discharge Elimination System (NPDES), a permitting system for the discharge of any pollutant (except for dredged or fill material) into waters of the United States. This permit program is administered by the SWRCB and the nine RWQCBs, which have several programs that implement individual and general permits related to construction activities, stormwater runoff quality, and various kinds of non-stormwater discharges. ▪ Section 404 (Discharge of Dredged or Fill Material into Waters of the United States) establishes a permit program for the discharge of dredged or fill material into waters of the United States. This permit program is jointly administered by the U.S. Army Corps of Engineers and the U.S. Environmental Protection Agency (EPA).

Numerous agencies have responsibilities for administration and enforcement of the CWA. At the federal level this includes EPA, the U.S. Army Corps of Engineers, the Bureau of Reclamation, and the major federal land management agencies, such as the U.S. Forest Service and the Bureau of Land Management. At the state level, with the exception of tribal lands, the California Environmental Protection Agency and its sub-agencies, including

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-10
the SWRCB, have been delegated primary responsibility for administering and enforcing the certain provisions of the CWA in California. At the local level, the San Diego RWQCB, municipalities, and special districts have implementation and enforcement responsibilities under the CWA.

Federal Antidegradation Policy
The federal Antidegradation Policy (40 CFR 131.12) is designed to protect water quality and water resources. The policy requires states to develop statewide antidegradation policies and identify methods for implementing those policies. State antidegradation policies and implementation measures must include the following provisions: (1) existing instream uses and the water quality necessary to protect those uses shall be maintained and protected; (2) where existing water quality is better than necessary to support fishing and swimming conditions, that quality shall be maintained and protected unless the state finds that allowing lower water quality is necessary for important local economic or social development; and (3) where high-quality waters constitute an outstanding national resource, such as waters of national and state parks, wildlife refuges, and waters of exceptional recreational or ecological significance, that water quality shall be maintained and protected. State permitting actions must be consistent with the federal Antidegradation Policy.

California Toxics Rule
The California Toxics Rule is a federal regulation issued by EPA providing water quality criteria for potentially toxic constituents in receiving waters with human health or aquatic life designated uses in the State of California. EPA adopted the California Toxics Rule in 2000 to create legally applicable water quality criteria for priority toxic pollutants for inland surface waters, enclosed bays, and estuaries to protect human health and the environment for all purposes and programs under the CWA. The California Toxics Rule aquatic life criterion were derived using a CWA Section 304(a) method that produces an estimate of the highest concentration of substances in water that do not present a significant risk to the aquatic organisms in the water and their uses. The California Toxics Rule water quality criteria provide a reasonable and adequate amount of protection with only a small possibility of substantial overprotection or under protection.

State
Porter-Cologne Water Quality Control Act
The Porter–Cologne Water Quality Control Act (codified in the California Water Code, Section 13000 et seq.) is the primary water quality control law for California. Whereas the CWA applies to all waters of the United States, the Porter–Cologne Act applies to waters of the state,1 which includes isolated wetlands and groundwater in addition to federal waters. The Porter-Cologne Act grants the SWRCB and the nine RWQCBs power to protect water quality and is the primary vehicle for implementation of California’s responsibilities under the federal CWA. The PorterCologne Act also grants the SWRCB and the nine RWQCBs authority and responsibility to adopt plans and policies, to regulate discharges of waste to surface and groundwater, to regulate waste disposal sites, and to require cleanup of discharges of hazardous materials and other pollutants. Further, the Porter–Cologne Act establishes reporting requirements for unintended discharges of any hazardous substance, sewage, or oil or petroleum product. 1 “Waters of the state” are defined in the Porter–Cologne Act as “any surface water or groundwater, including saline waters, within the boundaries of the state” (California Water Code, Section 13050[e]).

City of Santee
AE
AE AE
AE
AE
AE
AE
AE
AE
AE
X
X
Ä67
S a n D i e g o R i v e r
S a n
D i e g o
R i v e r
Flood Map
Palisade Santee Commerce Center Project
SOURCE: ESRI 2022, Open Street Maps 2019, FEMA 2023
Date: 5/14/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx 0 500 1,000 n Feet
Project Boundary
City Boundary
FEMA Flood Zones
Special Flood Hazard Areas
ZONE AE: 100-Year Flood Hazard
Area - Subject to Inundation by
the 1% Annual Chance Flood.

ZONE AE: Regulatory Floodway
Areas
Other Areas of Flood Hazard
ZONE X: 500-year Flood Hazard
Area - Areas of 0.2% annual
chance flood; areas of 1% annual
chance flood with depths of less
than 1 foot or with drainage areas
less than 1 square mile
ZONE X: Areas of Minimal Flood
Hazard; Areas determined to be
outside the 0.2% floodplan.

FIGURE 4.8-3

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-12

INTENTIONALLY LEFT BLANK

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-13
The act requires a “Report of Waste Discharge” for any discharge of waste (liquid, solid, or otherwise) to land or surface waters that may impair a beneficial use of surface or groundwater of the state. California Water Code Section 13260(a) requires that any person discharging waste or proposing to discharge waste, other than to a community sewer system, that could affect the quality of the waters of the state, to file a Report of Waste Discharge with the applicable RWQCB. For discharges directly to surface water (waters of the United States), an NPDES permit is required, which is issued under both state and federal law; for other types of discharges, such as waste discharges to land (e.g., spoils disposal and storage), erosion from soil disturbance, or discharges to waters of the state (such as groundwater and isolated wetlands), waste discharge requirements (WDRs) are required and are issued exclusively under state law. WDRs typically require many of the same best management practices (BMPs) and pollution control technologies as required by NPDES-derived permits.

California Antidegradation Policy
The California Antidegradation Policy, otherwise known as the Statement of Policy with Respect to Maintaining High Quality Water in California, was adopted by the SWRCB (State Board Resolution No. 68-16) in 1968. Unlike the federal Antidegradation Policy, the California Anti-Degradation Policy applies to all waters of the state, not just surface waters. The policy requires that, with limited exceptions, whenever the existing quality of a water body is better than the quality established in individual basin plans (see description below), such high quality must be maintained, and discharges to that water body must not unreasonably affect any present or anticipated beneficial use of the water resource.

Water Quality Control Plan for the San Diego Basin
The California legislature has assigned the primary responsibility to administer and enforce statutes for the protection and enhancement of water quality, including the Porter–Cologne Act and portions of the CWA, to the SWRCB and its nine RWQCBs. The San Diego RWQCB implements the Basin Plan (San Diego RWQCB 2021), which designates beneficial uses, establishes water quality objectives, and contains implementation programs and policies to achieve those objectives for all waters addressed through the plan (California Water Code, Sections 13240–13247). The Porter–Cologne Act also provides the RWQCBs with authority to include within their basin plan water discharge prohibitions applicable to particular conditions, areas, or types of waste. The Basin Plan is continually updated to include amendments related to implementation of TMDLs, revisions of programs and policies within the San Diego RWQCB Region, and changes to beneficial use designations and associated water quality objectives. The Basin Plan is the guiding document that establishes water quality standards for the region.

The basin plan for each region provides quantitative and narrative criteria for a range of water quality constituents applicable to certain receiving water bodies and groundwater basins within the region. Specific criteria are provided for the larger, designated water bodies within the region, as well as general criteria or guidelines for ocean waters, bays, and estuaries; inland surface waters; and groundwaters. In general, the narrative criteria require that degradation of water quality not occur due to increases in pollutant loads that will adversely impact the designated beneficial uses of a water body.

Construction General Permit
For stormwater discharges associated with construction activity in the State of California, the SWRCB has adopted the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit [CGP]) (Order No. 2022-0057-DWQ) to avoid and minimize water quality impacts attributable to such activities. The CGP applies to all projects in which construction activity disturbs 1 acre or more

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-14
of soil. Construction activity subject to this permit includes clearing, grading, and disturbances to the ground, such as stockpiling and excavation. The CGP requires the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP), which would specify water quality BMPs designed to reduce or eliminate pollutants in stormwater discharges and authorized non-stormwater discharges from the construction site. Routine inspection of all BMPs is required under the provisions of the CGP and the SWPPP must be prepared and implemented by qualified individuals as defined by the SWRCB.

To receive coverage under the CGP, a project applicant must submit a Notice of Intent and permit registration documents to the SWRCB. Permit registration documents include a construction site risk assessment to determine appropriate coverage level; detailed site maps showing disturbance area, drainage area, and BMP types/locations; the SWPPP; and, where applicable, post-construction water balance calculations and active treatment systems design documentation.

Phase II Small MS4 Permit
To enable efficient permitting under both the CWA and the Porter–Cologne Act, the SWRCB and the RWQCBs administer permit programs that group similar types of activities with similar threats to water quality. These “general permit” programs include the Phase II Small Municipal Separate Storm Sewer System (MS4) Permit,2 the CGP, and other general permits for low-threat discharges. The City of Santee is subject to Phase I MS4 Permits (Order No.

R9-2013-0001, as amended by Order Nos. R9-2015-0001 and R9-2015-0100, NPDES No. CAS019266).

The Small MS4 Permit consists of several program elements: Program Management, Public Involvement/ Participation, Illicit Discharge Detection and Elimination, Construction Site Storm Water Runoff Control, Pollution Prevention/Good Housekeeping for Permittee Operations, Post Construction Storm Water Management for New Development and Re-development, Water Quality Monitoring Requirements, Program Effectiveness Assessment, and Annual Reporting. Besides requiring implementation of construction site BMPs and performance criteria and design guidelines for development within the Small MS4’s service area, the Small MS4 Permit also requires operators to map their outfalls, properly maintain the storm drain system, educate the public on pollution prevention, and monitor and report on the quality of MS4 discharges to receiving waters so that the effectiveness of the program can be evaluated. Collectively, the program elements are designed to ensure discharges from the storm drain system do not contain pollutant loads at levels that violate water quality standards and Basin Plan objectives and policies (such as a TMDL for a CWA Section 303[d] impaired water body). Implementation of the program elements are the responsibility of the Small MS4 operator, in this case, the City.

Relevant to the proposed Project is that the Small MS4 Permit requires Priority Development Projects, or Regulated Projects3, to implement post-construction measures in the form of site design, source control, stormwater treatment measures, and baseline hydromodification management measures to reduce the discharge of pollutants in stormwater to the maximum extent practicable. Examples include the following:
▪ Source Control Measures: Source control measures seek to avoid introduction of water quality pollution/degradation. Source control strategies include covering refuse/trash areas, properly managing 2 A Small MS4 is defined as a conveyance or system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains) that serve populations of less than 100,000 persons. 3 Regulated Projects are defined in Section E.12.c of Water Quality Order 2013-0001-DWQ, and include all projects that create and/or replace 5,000 square feet or more of impervious surface, not including detached single-family home projects that are not part of a larger plan of development, interior remodels, routine maintenance or repair within the existing footprint, or linear underground/overhead projects.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-15
outdoor storage of equipment/materials, minimizing use of pesticides and fertilizers in landscaping, using sumps or special area drains to send non-stormwater discharges to the sewer, and ensuring regular grounds maintenance.
▪ Site Design Measures: Site design measures require early assessment and evaluation of how site conditions, such as soils, vegetation, and flow paths, will influence the placement of buildings and paved surfaces. The evaluation is used to meet the goals of capturing and treating runoff and maximizing opportunities to mimic natural hydrology. Options for site design measures include preserving trees, buffering natural water features, disconnecting impervious surfaces, and using green roofs or porous pavement. ▪ Treatment Control Measures: Treatment control measures retain, treat, and/or infiltrate the site runoff produced under normal circumstances, controlling both the quality and quantity of stormwater released to the stormwater conveyance system and natural receiving waters. In most situations, this means implementing structural BMPs (e.g., infiltration, bioretention, and/or rainfall harvest and re-use) to address the volume and rate of runoff produced by 85th percentile storm4 (i.e., design capture volume). The Small MS4 Permit requires Regulated Projects to prioritize stormwater capture (e.g., infiltration and/or harvest and re-use) unless site conditions (e.g., low-permeability soils) make it infeasible. ▪ Hydromodification Measures: Hydromodification measures are required for projects that create or replace 1 or more acres of impervious surfacing so that post-project runoff shall not exceed the estimated pre-project flow rate for the 2-year, 24-hour storm. If the project creates or replaces less than 1 acre of impervious surfaces and demonstrates that post-project flows from the site are less than pre-project flows, then no hydromodification measures from Section E.12.e.(ii)(f) from the Small MS4 Permit are required. ▪ Operation and Maintenance Requirements: The Small MS4 Permit requires that maintenance agreements stay in place with each property to ensure permanent treatment control measures developed on site are properly maintained and/or repaired in accordance with the stormwater quality control plan.

The aforementioned site design, treatment control, and hydromodification measures are often collectively referred to as “Low Impact Development” standards. The proposed Project meets the criteria as a Priority Development Project, or Regulated Project and, thus, is required to comply with the stormwater management requirements of the Small MS4 Permit.

The Small MS4 Permit is administered by the SWRCB, while other general WDRs are administered by the San Diego RWQCB. Point source discharges or other activities that threaten water quality that are not covered under a general permit must seek individual NPDES permits and/or WDRs, depending on the type, location, and destination of the discharge. For these type of discharges, the initial step in the process is to submit a “Report of Waste Discharge” to the San Diego RWQCB, which then determines the appropriate permitting pathway.

Local
City of Santee Clean Water Storm Water Program
Stormwater runoff in the City is regulated in accordance with the City of Santee Guidelines for Surface Water Pollution Prevention (City of Santee 2015). This stormwater guidance manual supports the City’s Storm Water Management and Discharge Control Ordinance (Storm Water Ordinance), codified as Santee Municipal Code Chapter 9.06. The manual also supports the water quality protection provisions of Municipal Code Chapters 11.40, 4 The 85th percentile storm represents a value of rainfall, in inches, such that 85% of the observed 24-hour rainfall totals within the historical record will be less than that value.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-16
Excavation and Grading. Moreover, the manual is not a stand-alone document but must be read with applicable parts of the aforementioned chapters of the Municipal Code (collectively, “Ordinances”). In general, this stormwater manual categorically and explicitly establishes how dischargers must comply with the ordinances and to receive permits for projects and activities that are subject to those ordinances. The stormwater manual and the ordinances have been prepared to provide the City with the respective legal authority and administrative actions necessary to comply with the requirements of the CGP (Order No. 2022-0057-DWQ).

City of Santee General Plan
Land Use Element
Objective 3.0 Provide and maintain the highest level of service possible for all community public services and facilities.

Policy 3.1 The City should ensure that land divisions and developments are approved within the City only when a project's improvements, dedications, fees and other revenues to the City and other agencies fully cover the project's incremental costs to the City and other agencies. These costs are for providing new or upgraded capital improvements and other public facilities and equipment resulting from, and attributable to the project, which are necessary to protect and promote the public's health, safety and welfare and to implement feasible mitigation measures. Such facilities include, but are not limited to: parks, bridges, major roads, traffic signals, street lights, drainage systems, sewers, water, flood control, fire, police, schools, hiking/bicycle trails and other related facilities. In calculating benefits of land divisions and developments, the City may consider other public objectives and goals including social, economic (job creation, secondary economic benefits, etc.) and environmental factors.

Objective 6.0 Ensure that natural and man-induced hazards are adequately address in the location and intensity of the development in the City.

Policy 6.1 The City shall utilize all mapped information, objectives and policies contained in the Safety and Conservation Elements during the development review process.

Policy 6.2 The City should promote the use of innovative site planning to avoid on-site hazards and minimize risk levels.

Conservation Element
Objective 2.0 Protect floodways to reduce flood hazards, protect biological resources and preserve the aesthetic quality along water corridors.

Policy 2.1 The City shall encourage the protection of the San Diego River Corridor and all other City water corridors to reduce flood hazards, protect significant biological resources and scenic values, and to provide for appropriate recreational uses.

Policy 2.6 The City encourages the development of appropriate flood control measures to assure public safety, which also prioritize maintenance of natural habitats and vegetation, and provision of community recreational opportunities as feasible and appropriate.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-17
Policy 2.7The City shall ensure that all development proposals are located outside of designated floodways and all development in the 100-year floodplain is consistent with the City’s Flood Damage Protection Ordinance.

Safety Element
Objective 1.0 Minimize injuries, loss of life and property damage resulting from flood hazards.

Policy 1.1 The City should encourage the use of innovative site design strategies within the floodplain which ensure minimizing of flood hazards, maintaining the natural character of waterways and maximize the use of water as a design feature.

Policy 1.2 All development proposed within a floodplain area shall be required by the City to utilize design and site planning techniques to ensure that structures are elevated at least one foot above the 100-year flood level.

Policy 1.6 The City should require a hydrologic study, including the analysis of effects on downstream and upstream properties and on the flood-carrying characteristics of the stream, for development proposed in the floodplain.

Policy 1.8 Development within the 100-year floodway shall be prohibited, subject to the provisions of the City’s Flood Damage Prevention Ordinance.

Community Enhancement Element
Objective 16.0 Utilize the natural design elements presented by the river/creek system within the City.

Policy 16.1 The City should encourage the strengthening of links between the San Diego River, Forester Creek, Woodglen Vista Creek and the Sycamore Creek/Santee Lakes.

Policy 16.2 The City should promote the introduction of water elements (fountains, streams/canals, ponds, etc.) and riparian plant materials (i.e., Sycamores, Oaks, etc.) into developments along watercourses.

Policy 16.3 The City should ensure that all development along the River corridor maximizes orientation towards the River and enhances the natural character of the River.

Policy 16.4 The City shall respect the natural stream processes of the San Diego River and its tributaries and ensure that flood control improvements along existing watercourses/channels avoid concrete channelization whenever possible and retain the natural character of the corridor through planting or preservation of native vegetation.

4.8.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to hydrology and water quality are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to hydrology and water quality would occur if the Project would:

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-18
Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.

Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin.

Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

I. result in substantial erosion or siltation on or off-site.

II. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off-site.

III. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

IV. impede or redirect flood flows.

In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.

Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

4.8.4 Impacts Analysis
A. Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
Short-Term Construction Impacts
Less-than-Significant Impact. The proposed Project includes the demolition of all existing on-site structures (see Section 3.2, Environmental Setting) and the construction of a 300,145 square foot industrial/warehousing building.

The Project would include 290,145 square feet of warehouse space and 10,000 square feet of office space, as well as associated improvements including loading docks, trailer stalls, passenger vehicle parking spaces, and street, sidewalk, and landscape improvements (Figure 3-7, Conceptual Site Plan). Demolition activities are anticipated to generate approximately 18,381 tons of debris that would be transported to a landfill permitted to accept inert construction and demolition materials. Grading would occur across the 13.43-acre Project site and result in approximately 28,304 cubic yards of cut and 28,304 cubic yards of fill. Underground utilities would be installed to maximum depth of 11 feet below grade.

In the absence of proper soil management, grading and construction could result in wind and water erosion and associated sediment transport into the adjacent San Diego River. Construction-related activities that primarily result in sediment releases are related to exposing previously stabilized soils to potential mobilization by rainfall/runoff and wind. Erosion and sedimentation affects water quality and interferes with photosynthesis; oxygen exchange; and the respiration, growth, and reproduction of aquatic species. Additionally, other pollutants, such as nutrients, trace metals, and hydrocarbons, can attach to sediment and be transported downstream, which could contribute to degradation of water quality.

Non-sediment-related pollutants that are also of concern during construction relate to construction materials and non-stormwater flows and include construction materials (e.g., paint); chemicals, liquid products, and petroleum products used in construction or the maintenance of heavy equipment; and concrete-related pollutants.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-19
Warehouse construction impacts would be minimized through compliance with the Small MS4 Permit and the SWRCB’s CGP. Because the proposed Project is greater than 1 acre in size, the applicant would be required to submit a Notice of Intent to the SWRCB in order to obtain approval to complete construction activities under the CGP. This permit requires the discharger to perform a risk assessment for the proposed development (with differing requirements based upon the determined level) and to prepare and implement a SWPPP. A Construction Site Monitoring Program that identifies monitoring and sampling requirements during construction is a required component of the SWPPP. The SWPPP is also required to include construction-phase BMPs to be implemented.

Typical BMPs that would be implemented during grading and construction of the proposed Project that would minimize degradation of surface water quality include the following:

Erosion Control
▪ Physical soil stabilization through hydraulic mulch, soil binders, straw mulch, bonded and stabilized fiber matrices, compost blankets, and erosion control blankets. ▪ Contain and securely protect stockpiled materials from wind and rain at all times, unless actively being used. ▪ Soil roughening of graded areas to slow runoff, enhance infiltration, and reduce erosion. ▪ Vegetative stabilization through temporary seeding and mulching to establish interim vegetation. ▪ Wind erosion (dust) control through the application of water or other dust palliatives as necessary to prevent and alleviate dust nuisance.

Sediment Control
▪ Perimeter protection to prevent sediment discharges (e.g., silt fences, fiber rolls, gravel bag berms, sand bag barriers, and compost socks).
▪ Storm drain inlet protection.
▪ Sediment capture and drainage control through sediment traps and sediment basins. ▪ Velocity reduction through check dams, sediment basins, and outlet protection/velocity dissipation devices. ▪ Reduction in off-site sediment tracking through stabilized construction entrance/exit, construction road stabilization, and/or entrance/exit tire wash.
▪ Slope interruption at prescribed intervals (e.g., fiber rolls, gravel bag berms, sand bag berms, compost socks, biofilter bags).

Waste and Materials Management
▪ Management of the following types of materials, products, and wastes: solid, liquid, sanitary, concrete, hazardous, and equipment-related wastes. Management measures include covered storage and secondary containment for material storage areas, secondary containment for portable toilets, covered dumpsters, dedicated and lined concrete washout/waste areas, proper application of chemicals, and proper disposal of all wastes.
▪ A spill response and prevention program will be incorporated as part of the SWPPP and spill response materials will be available and conspicuously located at all times on site.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-20
Non-Stormwater Management
▪ BMPs or good housekeeping practices to reduce or limit pollutants at their source before they are exposed to stormwater, including such measures as water conservation practices, vehicle and equipment cleaning and fueling practices, illicit connection/discharge elimination, and concrete curing and finishing. All such measures will be recorded and maintained as part of the Project SWPPP.

Training and Education
▪ Inclusion of CGP-defined Qualified SWPPP Developers and Qualified SWPPP Practitioners. These staff shall have required certifications and shall attend SWRCB sponsored training. ▪ Training of individuals responsible for SWPPP implementation and permit compliance, including contractors and subcontractors.
▪ Signage (bilingual, if appropriate) to address SWPPP-related issues (such as site cleanup policies, BMP protection, and washout locations).

Inspections, Maintenance, Monitoring, and Sampling
▪ Performing routine site inspections and inspections before, during (for storm events > 0.5 inches), and after storm events.
▪ Where applicable, preparing and implementing Rain Event Action Plans prior to any storm event with 50% probability of producing 0.5 inches of rainfall, including performing required preparatory procedures and site inspections.
▪ Implementing maintenance and repairs of BMPs as indicated by routine, storm-event, and Rain Event Action Plan inspections.
▪ Implementation of the Construction Site Monitoring Plan for non-visible pollutants if a leak or spill is detected. ▪ Where applicable, sampling of discharge points for turbidity and pH at minimum three times per qualifying storm event and recording and retention of results.

Through implementation of the requirements outlined in the CGP, construction-related impacts to surface water and groundwater quality would be minimized and impacts would be less than significant.

Long-Term Operational Impacts
Less-than-Significant Impact. Once operational, impervious surfaces such as the entrance driveway, parking areas, drive aisles, truck loading areas, walkways, trash enclosures, and the warehouse building would be a source of pollution from incidental spills of vehicle oils and other chemicals that can be conveyed by stormwater and landscape irrigation flows. The impervious surfaces would prevent polluted surface waters from absorbing into the ground surface, but in the absence of proper pollution control, would potentially flow into the adjacent San Diego River.

The on-site watersheds following grading are depicted on Figure 4.8-4, Proposed Hydrology Map (included in Appendix J-1). During storm events, pollutants from paved areas lacking in proper stormwater controls and BMPs could enter the San Diego River. The majority of pollutants entering the river in this manner would be dust, litter, and possibly residual petroleum products (e.g., motor oil, gasoline, diesel fuel). Certain metals, along with nutrients, organic compounds, bacteria/viruses, and pesticides from landscape areas could also be present in stormwater runoff during Project operations (Appendix J-2). Between periods of rainfall, surface pollutants tend to accumulate, and runoff from the first significant storm of the year (“first flush”) would likely have the largest concentration of pollutants.

Date: 5/14/2024 User: kholmes Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx Map: [empty] Layout: Figure 4.8-4 SOURCE: DRC Engineering 2024
Palisade Santee Commerce Center Project
Proposed Hydrology Map
FIGURE 4.8-4

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-22

INTENTIONALLY LEFT BLANK

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-23
Hydromodification management requirements do not apply to the proposed Project, as the Project would discharge stormwater directly into the San Diego River Watershed Management Area, which is defined as an exempt river reach per the “Receiving Waters and Conveyance Systems Exempt from Hydromodification Management Requirements” map. However, the proposed Project meets the criteria as a Priority Development Project, or Regulated Project, as the Project would result in the disturbance of 1 or more acres of land and would therefore be expected to generate pollutants post-construction. As a result, the Project is required to comply with the stormwater management requirements of the City of Santee BMP Design Manual (City of Santee 2016).

In addition, design, construction, and operation of projects in the City of Santee are subject to the Small MS4 Permit and the City of Santee Guidelines for Surface Water Pollution Prevention Manual. The City stormwater guidance manual, which supports the City’s Storm Water Ordinance, categorically and explicitly establishes how dischargers must comply with the ordinances and to receive permits for projects and activities that are subject to those ordinances. An objective of this stormwater manual is to reduce the discharge of pollutants from the stormwater conveyance system, to the maximum extent practicable, in order to achieve applicable water quality objectives for surface waters in San Diego County. Minimum post-construction BMP requirements are provided in the manual for industrial, commercial, and municipal projects, including eliminate illicit non-stormwater discharges; properly dispose of process and wash water; eliminate the discharge of vehicle and equipment wash water; eliminate irrigation runoff; eliminate air conditioning condensation discharges; direct runoff from pavement, rooftops, and other impervious surfaces to landscaped areas; and regularly clean and maintain structural BMPs, including Low Impact Development (LID) installations, to ensure proper performance (City of Santee 2015).

In compliance with the City of Santee BMP Design Manual and the City of Santee Guidelines for Surface Water Pollution Prevention manual, the proposed Project would include development of an on-site storm drain system that would accept flows from drain inlets at low spots throughout the site. Stormwater would continue to flow to the north of the site, around the building to an underground infiltration system located within the northern truck yard (Figure 4.8-4). The infiltration system has been sized to infiltrate the design capture volume, based on San Diego County LID requirements, with larger flows building up within the system and discharging to a headwall structure with downstream rip-rap (to dissipate energy and provide scour protection) located near the northern property line, and then draining into the San Diego River (Appendix J-1). The infiltration system would be designed to capture and treat stormwater pollutants, consistent with commercial/industrial developments and associated parking lots, and including oil, grease, metals, trash, and debris. As a result, operations-related water quality impacts would be less than significant.

B. Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin? Groundwater Recharge
No Impact. The Project site is currently paved and impervious to groundwater recharge. With the exception of relatively small areas of landscaping, the proposed Project would similarly result in impervious surfaces across the site. As a result, the potential for groundwater recharge would not change with respect to existing conditions and no impacts would occur.

Groundwater Supply
Less-than-Significant Impact. Domestic water service is provided to the Project area by the PDMWD, which primarily relies on imported surface water from the San Diego County Water Authority. The PDMWD’s water supplies

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-24
also include recycled water and a very small amount of groundwater from one well in the Santee Basin, which supplements the recycled water system. The well is unreliable; therefore, groundwater supplies from the well are assumed to not be available as a future supply and the PDMWD has no plans for other groundwater supplies in the future. In 2022, groundwater comprised 6% of the water supplies from the San Diego County Water Authority, and by 2045, groundwater is expected to comprise 4% of their water supply. Based on the minor amount of groundwater used by PDMWD as a water source, the water demand for the proposed Project would not substantially decrease groundwater supplies in the Santee Basin, such that the Project may impede sustainable groundwater management of the Santee Basin. Impacts would be less than significant.

C. Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on or off-site; Less-than-Significant Impact. As previously discussed, the Project site is currently paved and the amount of impervious surfaces would remain unchanged following grading and construction. The site would generally match the existing drainage conditions, as stormwater from the existing culvert and Woodside Avenue to the south would be accepted by the on-site storm drain and flow through the site. All flows would be routed to an underground infiltration chamber that is sized based on County of San Diego LID requirements. The infiltration chamber would have a system volume of approximately 26,891 cubic feet and consist of a total area of approximately 6,233 square feet. The infiltration chambers would pond to an elevation of 348.50 feet before stormwater would outlet to an overflow system. Six-inch outlet pipes would be connected 8 inches above the invert of the chambers. High flows would bypass the infiltration system and would overflow into a headwall structure with downstream rip-rap, located along the northern perimeter of the site along the banks of the San Diego River (Figure 4.8-4). The headwall and rip-rap design would dissipate runoff energy and provide scour protection. This system would replace the outlet currently accepting water from the site that has been eroded from a concentrated amount of stormwater in the past (Appendix J-1). Peak runoff rates were calculated for the 10-year, 50-year, and 100-year storm events, including on-site runoff and off-site run-on. Based on these calculations, post-construction runoff rates would be less than under existing conditions for each storm event (Appendix J-1). As a result, the potential for off-site erosion and siltation of the San Diego River would be decreased in comparison to existing conditions.

An additional 24-inch pipe would accept flows from the existing 24-inch culvert located under Interstate 67 outlets, at the entrance to the site off of Woodside Avenue. The proposed storm drain has been designed to route stormwater to the north underneath the Project site and outlet via a flared end section to prevent stormwater intrusion from larger storms within the San Diego River (Appendix J-1).

Because 1) the amount of impervious surfaces would not increase as a result of the project, 2) off-site stormwater runoff rates would decrease as a result of installation of the proposed drainage system and infiltration system, and 3) existing concentrated runoff and associated erosion would be eliminated along the northern project boundary, beneficial less than significant impacts would occur as a result of Project completion.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-25
ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
Less-than-Significant Impact. As previously discussed, stormwater runoff rates would decrease as a result of the Project. As a result, the Project would not result in flooding on- or off-site. Beneficial less than significant impacts would occur as a result of Project completion.
iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or Less-than-Significant Impact. As previously discussed, stormwater runoff rates would decrease as a result of the Project. As a result, the Project would not create or contribute runoff which would exceed the capacity of existing or planned stormwater drainage systems. Beneficial impacts would occur as a result of the proposed drainage system.

As previously discussed, during storm events, pollutants from paved areas lacking in proper stormwater controls and BMPs could enter the San Diego River. The majority of pollutants entering the river in this manner would be dust, litter, and possibly residual petroleum products (e.g., motor oil, gasoline, diesel fuel). Certain metals, along with nutrients, organic compounds, bacteria/viruses, and pesticides from landscape areas could also be present in stormwater runoff during Project operations. However, the proposed infiltration system would be designed to capture and treat stormwater pollutants, consistent with commercial/industrial developments and associated parking lots, and including oil, grease, metals, trash, and debris. As a result, operations-related water quality impacts would be less than significant.
iv) impede or redirect flood flows?
Less-than-Significant Impact. As illustrated in Figure 4.8-3, Flood Map, the northern boundary of the Project site is adjacent to a regulatory floodway (FEMA 2023). The Project site has been designed to match the existing contours along the San Diego River as to not impact the existing floodplain, and the Project building will be more than one foot above the floodplain in accordance with City of Santee Flood Damage Prevention Ordinance, Chapter 11.36.

The Project will not impact the FEMA floodplain.

DRC Engineering (Appendix J-1) used the City of Santee Citywide Drainage Study (BSI Consultants 1990) as the basis for reviewing 100-Year flood levels within the San Diego River relative to the Project site. While the City developed a Master Drainage Study Update in 2023, the 1990 study was used for the Project technical report because it is more relevant pertaining to the 100-year flood levels of the San Diego River. Based on this analysis, 100-year flood elevations at the Project site would be 351.73 feet, which would be more than 6 feet below proposed finished floor elevations of the proposed warehouse building (Figure 4.8-4). The Project site has been designed to match the existing contours along the San Diego River as not to impact the existing floodplain and the proposed building would be constructed greater than one foot above the floodplain, per City of Santee requirements. The Project would not require coordination with FEMA and/or preparation of FEMA no-rise certification, which is a formal engineering analysis process completed in conjunction with FEMA (Appendix J-3). As a result, the Project would not substantially alter the drainage patterns of the site, such that the Project would impede or redirect flood flows.

Impacts would be less than significant.

4.8 – HYDROLOGY AND WATER QUALITY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.8-26
D. Would the Project in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? Less-than-Significant Impact. The proposed Project is not in a tsunami or seiche zone. With respect to flood hazard, as described above, the finished floor elevations of the proposed warehouse building would be more than 6 feet above calculated 100-year flood levels. In addition, the top of the water quality filtration chambers would be at an elevation of 349.0, with the 6-inch perforated pipe outlet being at an elevation of 352.0, which is slightly above anticipated flood levels (Appendix J-1). As a result, the stormwater filtration system would continue to be operable during a flood event. Because the Project would be constructed above the 100-year flood elevation, the Project would not risk release of pollutants due to project inundation. Impacts would be less than significant.

E. Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
No Impact. The proposed Project would be required to prepare a SWPPP, in accordance with the CGP, which will include a risk determination and list the appropriate water quality BMPs that will be used to protect stormwater quality throughout the construction phase. Additionally, the SWPPP must contain a visual monitoring program and a chemical monitoring program for “non-visible” pollutants to monitor the effectiveness of the selected BMPs. The SWPPP will be required to demonstrate that the construction activities will not violate discharge prohibitions, effluent limitations, and water quality standards as outlined in the CGP. As such, with implementation of the SWPPP, construction of the proposed Project would not conflict with or obstruct implementation of the Basin Plan.

The proposed Project overlies the San Diego River Valley Groundwater Basin. Currently no significant withdrawals are conducted from this basin. Water required for soil compaction and dust control during construction would be provided by the PDMWD, which primarily relies on imported surface water from the San Diego County Water Authority. As a result, groundwater would likely not be used as a water source during construction and operations.

Therefore, the proposed Project would not conflict with or obstruct implementation of the Basin Plan. No impacts would occur.

4.8.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to hydrology and water quality would be less than significant. No mitigation is required.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-1

4.9 Land Use and Planning
This section describes the existing land use and planning conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to implementation of the Project. Information contained in this section is based on review of local, regional, and statewide policies and regulations encompassing the Project site, including:
▪ San Diego Association of Governments (SANDAG) Regional Plan/Sustainable Communities Plan (RP/SCS) ▪ City of Santee General Plan
▪ City of Santee Municipal Code
Other sources consulted are listed in Section 4.9.6, References Cited.

4.9.1 Existing Conditions
City-Wide Conditions
The City of Santee, California is located in the East County region of San Diego County, located between the Pacific Ocean and the Cleveland National Forest. The City of Santee encompasses about 17 square miles (approximately 10,615 acres) in eastern San Diego County. It is located approximately 18 miles east of downtown San Diego. The City is bordered on the east primarily by residential development in the unincorporated San Diego County communities of Lakeside and Eucalyptus Hills and to the northeast by vacant land and active mining operations in Slaughterhouse Canyon. To the south, Santee is bordered by the City of El Cajon, unincorporated areas of the County of San Diego and the Gillespie Field Airport and to the southwest by Mission Trails Regional Park property located in the City of San Diego (City of Santee 2003).

The City comprises a mix of different land use types and density. Single-family residential uses comprise the largest land use totaling approximately 2,418 acres (City of Santee 2003). The other residential use types occurring throughout the City include multifamily residential (apartments and condominiums), and mobile home parks, which are primarily located near the City's highly traveled roads including Mission Gorge Road, Magnolia Avenue and Prospect Avenue. The 650-acre Town Center district forms a downtown core comprised of business parks, highdensity residential and retail businesses that feed off the synergy of Santee Trolley Square shopping complex and the Metropolitan Transit System trolley station (City of Santee 2023). Industrial uses in the City are concentrated in the south-central part of the City along Prospect Avenue, Magnolia Avenue and Cuyamaca Street, and north of Woodside Avenue along the San Diego River corridor, within the vicinity of the Project site (City of Santee 2003).

Existing Project Site Conditions
The approximately 13.5-acre Project site is developed with a closed drive-in theatre that includes two movie screens, two ticket booths, and a building containing restrooms and a snack bar that are no longer in service. An Entrance Sign is located on the west side of the Project’s driveway entrance. Of metal and wood construction, the sign has neon tubing outlining a star and the word “Santee” at the top of the sign. The Project site boundary extends beyond the paved drive-in into the undeveloped area south of the San Diego River. The drive-in theatre has closed, but the site continues to be used for a swap meet.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-2
The Project site extends beyond the paved drive-in and includes a vacant strip of land bordering the San Diego River, north of the developed area of the Project site. There are no native vegetation communities within the Project boundary. Vegetation land coverages include Developed and Ornamental. There are no aquatic resources within the Project site boundary. The northern edge of the Project site boundary is next to stands of thick vegetation occurring along a chain link fence line. This vegetation is dominated by African sumac (Searsia lancea), a non-native low-growing tree species which is known to occupy disturbed areas.

Surrounding Land Uses
The Project site surrounding land uses consist of a mix of industrial, manufacturing, automotive, commercial, open space and residential uses (refer to Figure 3-3, Project Aerial and Existing Uses, within Chapter 3 of this Draft EIR).

4.9.2 Relevant Plans, Policies, and Ordinances
Federal
There are no federal plans, policies, or ordinances applicable to the land use considerations of the Project.

State
California Planning and Zoning Law
The legal framework under which California cities and counties exercise local planning and land use functions is set forth in California Planning and Zoning Law, Government Code Sections 65000-66499.58. Under State planning law, each city and county must adopt a comprehensive, long-term general plan. State law gives cities and counties wide latitude in how a jurisdiction may create a general plan, but there are fundamental requirements that must be met.

As stated in Section 65302 of the California Government Code, “The general plan shall consist of a statement of development policies and shall include a diagram or diagrams and text setting forth objectives, principle, standard, and plan proposals.” While a general plan will contain the community vision for future growth, California law also requires each plan to address the mandated elements listed in Section 65302. The mandatory elements for all jurisdictions are land use, circulation, housing, conservation, open space, noise, and safety. Each of the elements must contain text and descriptions setting forth objectives, principles, standards, policies, and plan proposals.

Regional
2021 Regional Plan/Sustainable Communities Strategy
San Diego Association of Governments (SANDAG) is the designated Metropolitan Planning Organization (MPO) for 18 city councils and County Board of Supervisors, and is federally mandated to develop plans for transportation, growth and development management, hazardous waste management, and air quality. The City of Santee is one of the many jurisdictions that fall under SANDAG.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-3
The 2021 Regional Plan/Sustainable Communities Strategy (RP/SCS) (2025 Regional Plan is currently being drafted) was adopted on December 21, 2021, and presents the land use and transportation vision for the region through the year 2050, providing a long-term investment framework for addressing the region’s challenges (SANDAG 2021). The RP/SCS explicitly lays out goals related to housing, transportation, equity and resilience in order to adequately reflect the increasing importance of these topics in the region, and where possible the goals have been developed to link to potential performance measures and targets. The RP/SCS development process involved working closely with local governments throughout the region to collect and compile data on land use and growth trends. The core vision of the RP/SCS is to build upon and expanded land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern.

SDAPCD - 2013 Air Quality Monitoring Quality Management Plan An Air Quality Monitoring Quality Management Plan (AQMP) is a plan for the regional improvement of air quality. The San Diego County 2013 AQMP is the applicable AQMP for the San Diego Air Pollution Control District (SDAPCD) and was approved by the SDAPCD Governing Board in December 2013 (SDAPCD 2013). The Project’s consistency with the 2013 AQMP was analyzed in detail in Section 4.2, Air Quality.

San Diego County Regional Transportation Congestion Improvement Program The San Diego County Regional Transportation Congestion Improvement Plan (RTCIP)/Regional Arterial System (RAS) was prepared by the San Diego Associated Governments (SANDAG) to more directly link land use, transportation, and air quality planning and to prompt reasonable growth management programs that would more effectively utilize new and existing transportation funds to alleviate traffic congestion and related impacts and improve air quality (SANDAG 2023). The San Diego County RTCIP was first adopted in May 2004 and has since been updated 12 times, with the most recent comprehensive update in September 2022. The Project’s consistency with the San Diego County RTCIP is discussed in detail in Section 4.12, Transportation.

Local
City of Santee General Plan
The City of Santee General Plan establishes the long-term vision for the City and fulfills the requirements of California Government Code Section 65302 requiring local preparation and adoption of General Plans. The General Plan includes the following mandated and optional elements: Land Use Element, Housing Element, Mobility Element, Recreation Element, Trails Element, Conservation Element, Noise Element, Safety Element, and Community Enhancement Element
City of Santee Zoning Ordinances
The Zoning Ordinance, Title 13 of the Santee Municipal Code, includes regulations concerning where and under what conditions various land uses may occur in the City. It also establishes zone-specific height limits, setback requirements, parking ratios, and other development standards, for residential, commercial, industrial, and all other types of sites. The Zoning Ordinance is a primary tool for implementing the City’s General Plan. The purpose of the Zoning Ordinances is to encourage, classify, designate, regulate, and restrict the highest and best locations and uses of buildings and structures, for residential, commercial, and industrial or other purposes.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-4

4.9.3 Thresholds of Significance
The following significance criteria, included for analysis in this EIR, is based on Appendix G of the State CEQA Guidelines (14 CCR 15000 et seq.), and will be used to determine the significance of potential land use and planning impacts. Impacts to land use and planning would be significant if the Project would:

Physically divide an established community.

Conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

4.9.4 Impacts Analysis
A. Would the Project divide an established community?
No Impact. The physical division of an established community typically refers to the construction of a linear feature (e.g., a major highway or railroad tracks) or removal of a means of access (e.g., a local road or bridge) that would impair mobility within an existing community or between a community and outlying area.

Under the existing condition, the Project site consists of approximately 13.43 acres of developed land with a twoscreen drive-in theatre and a building containing restrooms and a snack bar. The Project site boundary extends beyond the paved drive-in into the undeveloped area south of the San Diego River, however it is not used as a connection between established communities. Instead, connectivity within the area surrounding the Project site is facilitated via local roadways. As such, the Project would not impede movement within the Project area, within an established community, or from one established community to another. Therefore, no impacts would occur.

B. Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Less-than-Significant Impact. To evaluate the proposed Project’s impacts related to land use and planning, this analysis examines the Project’s consistency with both regional and local plans, policies, and regulations that regulate uses on the Project site. These plans are as follows:
▪ City of Santee General Plan and Zoning Code
▪ SANDAG 2021 RP/SCS
▪ SDCAPCD
▪ San Diego County RTCIP/RAS
As detailed below, the Project would result in a less-than-significant environmental impact due to a conflict with a land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

City of Santee General Plan and Zoning Code
The City’s General Plan designates the Project site for Light Industrial uses and the site is zoned for Light Industrial, per the City’s Zoning Code. The proposed Project would be consistent with Chapter 13.14 of the City’s Municipal Code, which states that allowed industrial and related uses including warehousing/distribution, assembly and light manufacturing, repair facilities, and business parks, including corporate offices. This zoning is consistent with the

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-5
Light Industrial land use designation of the General Plan (City of Santee 2003). Although the allowable building height in this zone is 40 feet, with the approval of the proposed Conditional Use Permit (CUP), the proposed warehouse building’s height of 50 feet would be allowable. Therefore, the Project would be consistent with the City’s General Plan and Zoning Code and impacts would be less than significant.

Table 4.9-1 outlines the applicable goals, objectives, and policies identified in the City’s General Plan and the Project’s consistency with each of these policies. In some cases, mitigation measures identified within this Draft EIR for the purposes of reducing impacts to other Appendix G CEQA environmental resource areas (i.e., air quality and noise) would assist the Project in maintaining consistency with applicable goals, objectives, and policies adopted for the purpose of avoiding or mitigating environmental effects. As shown below, with implementation of mitigation, the Project would be consistent with the applicable goals and policies of the General Plan.

Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
Land Use
Goal. Promote development of a well-balanced and
functional mix of residential, commercial, industrial,
open space, recreation, and civic uses that will create and maintain a high-quality environment
Consistent. The Project involves the development of a
warehouse/industrial use along the N Woodside
Avenue corridor, which is an established industrial
corridor within the City. The Project’s site plan,
architecture, and landscaping have been designed to
create a contemporary, unified, and high-quality
business park environment that would be compatible
with other industrial uses within the industrial
corridor.

Objective 5.0. Develop industrial uses which are
compatible with adjacent land uses.

Consistent. The Project would involve the construction
of an industrial warehouse, which would be consistent
with the adjacent industrial land uses as well as
existing zoning and the land use designation for the
site.

Policy 5.2. The City should promote consolidation of
industrial uses into comprehensively planned
industrial parks.

Consistent. As discussed above, the Project would
involve the construction of an industrial warehouse,
which would be consistent with the General Plan’s
land use designation and zoning for the site and
would be compatible with adjacent industrial uses.

Policy 5.3. The City shall ensure that industrial
development creates no significant off-site impacts
related to access and circulation, noise, dust, odors,
visual features and hazardous materials, that cannot
be adequately mitigated.

Consistent. As part of the Project's review process,
City staff have considered development of this
industrial Project in accordance with the General Plan
and the City’s Municipal Code. The Project’s off-site
effects with respect to access and circulation, noise,
dust and odors (air quality), visual features and
hazardous materials have been addressed in this EIR.

As discussed, the Project would have a less than
significant impact regarding these aspects.

Policy 5.4. The City shall promote a mix of industrial
uses that provide the City with a sound, diverse
industrial base.

Consistent. The Project involves the development of
an industrial warehouse to support warehousing and
distribution, manufacturing, assembly, and/or
research and development operations, and related
office uses, thereby providing a diverse industrial
base and enhancing the general character of the City.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-6
Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
Policy 5.5. The City should ensure that industrial
developments provide for business service needs and
the needs of employees.

Consistent. The Project would involve the
development of a high-quality industrial warehouse
that would employ approximately 185 persons,
thereby providing community stability and enhancing
the needs of the City.

Objective 6.0. Ensure that natural and man-induced
hazards are adequately addressed in the location and
intensity of development in the City.

Consistent. As discussed in Chapter 5, Effects Found
Not To Be Significant, Section 5.2 Geology and Soils,
natural and man-induced hazards impacts would be
less than significant. According to Figure 8-3 of the
City’s General Plan Safety Element, the Project site is located in area C3, which identifies liquefaction
potential as low to moderate (City of Santee 2003).

Therefore, impacts associated with potential seismicrelated ground failure, including liquefaction would be less than significant. In addition, the Project would
implement the City’s design and construction
standards that address safety in hazardous
conditions.

Policy 6.1. The City shall utilize all mapped
information, objectives and policies contained in the
Safety and Conservation Elements during the
development review process.

Consistent. The Project would implement all
objectives and policies discussed in the Safety and
Conservation Elements applicable to the Project. As
discussed in Section 4.7, Hazards and Hazardous
Materials, the Project would comply with all federal,
state, and local standards related to safety and
conservation of the public and environment.

Policy 6.2. The City should promote the use of
innovative site planning to avoid on-site hazards and
minimize risk levels.

Consistent. As discussed above, the Project would
comply with all federal, state, and local standards
related to safety and conservation of the public and
environment. As discussed in Section 4.7 Hazards
and Hazardous Materials, the Project is regulated by
Division 20, Chapter 6.95, of the California Health
and Safety Code, therefore, the Project would ensure
hazardous materials are handled, stored, transported,
and disposed of correctly.

Objective 11.0. Ensure that development in the City is
consistent with the overall community character and
contributes positively towards the City's image.

Consistent. The Project would be consistent with the
City’s General Plan, and zoning designations. As
discussed in Section 3, Project Description, the
Project’s architecture, landscaping, and lighting
improvements are all designed to create a
contemporary, unified, and high-quality business park
environment contributing a positive image to the
City’s image.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-7
Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
Policy 11.1. The City shall ensure that all
requirements set forth within the Community
Enhancement Element are implemented during the
development review process.

Consistent. As discussed above, the Project would be
consistent with the City’s General Plan, including the
Enhancement Element requirements. The Project
would create jobs for the residents of the City and
surrounding cities, improving the quality of life. In
addition, the Project would be designed by following
the City’s municipal codes, and design regulations as
discussed in Section 3, Project Description.

Objective 12.0. Maintain the Integrity and Consistency
of the General Plan.

Consistent. The Project would be consistent with the
City’s General Plan as well as maintain its integrity.

The Project would adhere to land use designations,
align with zoning regulations, and ensure public
engagement during the development process.

Community Enhancement
Objective 8.0. Improve the appearance and function
of existing and planned industrial areas.

Consistent. Under existing conditions, the theater (a
General Commercial land use) conflicts with the
Industrial zoning designation for the Project site. The proposed Project would resolve this conflict and
provide for a use that would be consistent with the
Light Industrial General Plan designation. The Project
would incorporate design principles and concepts
contained in the Community Enhancement Element to
create a contemporary, unified, and high-quality
warehouse/industrial park environment.

Policy 8.3. The City shall ensure through the
Development Review process that standards
established for the industrial areas are maintained.

Consistent. The Project is subject to a Development
Review permit to ensure industrial standards for the
site are established and maintained. Under existing
conditions, the theater (a General Commercial land
use) conflicts with the Industrial zoning designation
for the Project site. The proposed Project would
resolve this conflict and provide for a use that would
be consistent with the overall area. The Project would
incorporate design principles and concepts contained
in the Community Enhancement Element to create a
contemporary, unified, and high-quality
warehouse/industrial park environment.

Policy 8.4. The City shall ensure that all industrial
development is attractive and of high quality design to enhance the image of the City.

Consistent. Under existing conditions, the theater (a
General Commercial land use) conflicts with the
Industrial zoning designation for the Project site. The proposed Project would resolve these conflicts and
provide for a use that would be consistent with the
overall area. The Project would incorporate design
principles and concepts contained in the Community
Design Element to create a contemporary, unified,
and high-quality warehouse/industrial park
environment. For example, the proposed landscaping
materials include a mixture of trees, shrubs, and
groundcover that would be located along the Project
frontages to incorporate a layering concept and

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-8
Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
provide different height trees and border or accent
shrubs and low ground covers.

Policy 9.2. The City shall promote a Citywide street
tree and median planting program which enhances
views and is scaled in relationship to the function of
the roadway.

Consistent. The Project includes a landscape plan
which would involve the installation of landscaping
and trees along N. Woodside Avenue. The landscaping
materials along the Project frontages incorporate a
layering concept to provide different height trees and
border or accent shrubs and low ground covers.

Policy 9.3. The City shall ensure adequate landscaped
buffers are provided between trafficways and
sidewalks.

Noise
Goal. Improve the city's overall quality of life by
reducing harmful and annoying noise for existing and
future residents.

Consistent. As discussed in Section 4.10, Noise, the
Project would result in less than significant impacts to noise and groundborne vibration. Therefore, the
Project is consistent with this goal.

Objective 1.0. Control noise from sources adjacent to
residential, institutional and other noise-sensitive
receptors.

Consistent. As discussed in Section 4.10, Noise, the
nearest sensitive receptor to the site boundary is 310
feet from the Project site. The highest estimated
construction noise levels are predicted to stay below
67 dBA Leq over an 8-hour period at the nearest
existing residences (located south of North Woodside
Avenue and as close as 310 feet from the Project
driveway) when grading activities take place near the
Project driveway. Additional noise measurements
were conducted at residences further afield, such as
those to the north of the project site, and modeling
indicated that noise at these residences would stay
below 67 dBA Leq over an 8-hour period. Additionally,
the nearest existing residences to the south are
dominated by traffic noise from SR-67, and
intervening barriers and terrain were not considered
in the model. As a result, short-term construction
noise is predicted to be well below the FTA guidance
of 80 dBA Leq over an 8-hour period, and therefore is
less than significant.

Policy 1.1. The City shall support a coordinated
program to protect and improve the acoustical
environment of the City including development review
for new public and private development and code
compliance for existing development.

Consistent. The Project is subject to a Development
Review Permit to ensure code compliance. As part of
this Project, a Noise Technical Report was prepared
(included as Appendix K). Noise impacts are analyzed
within Section 4.10, Noise. Therefore, the Project is
consistent with this policy.

Policy 1.2. The City shall utilize noise studies and
noise contour maps when evaluating development
proposals during the discretionary review process.

Consistent. As part of this Project, a Noise Technical
Report was prepared (included as Appendix K). Noise

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-9
Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
impacts are analyzed in Section 4.10, Noise.

Therefore, the Project is consistent with this policy.

Policy 1.6. The City shall continue to monitor noise
throughout Santee and enforce the standards and
regulations of the City's Noise Ordinance.

Consistent. As discussed in Section 4.10, Noise, the
Project would comply with the City of Santee Noise
Ordinance. Therefore, the Project is consistent with
this policy.

Policy 1.16. The City shall ensure that appropriate
regulations and standards are incorporated into the
City's development policies and ordinances, including
the use of noise evaluations in Environmental Impact
Reports and statements, which take all aspects of
noise into consideration.

Consistent. As discussed in Section 4.10, Noise, the
Project prepared a Noise Technical Report (included
as Appendix K), which analyzed construction and
operation noise, as well as groundborne vibration. All
impacts were determined to be less than significant.

Therefore, the Project is consistent with this policy.

Objective 2.0. Ensure that future developments will be
constructed to minimize interior and exterior noise
levels.

As discussed in Section 4.10, Noise, the Project
prepared a Noise Technical Report (included as
Appendix K), which analyzed construction and
operation noise, as well as groundborne vibration. All
impacts were determined to be less than significant.

Therefore, the Project is consistent with this policy.

Policy 2.2. The City should require new development
to mitigate noise impacts to existing uses resulting
from new development when: 1) such development
adds traffic to existing City streets that necessitates the widening of the street; and 2) the additional traffic generated by the new development causes the noise
standard or significance thresholds to be exceeded.

Consistent. Within the Noise Technical Report
(included as Appendix K of this Draft EIR), predicted
traffic noise levels are included within Table 7.

Utilizing the traffic noise modeling worksheets, Table
7 shows that the highest predicted change in traffic
noise level (the project driveway) combined with the
roadways surrounding the immediate project site are
predicted to experience an aggregate total traffic
noise level of 84 dBA at 50 feet for the horizon year
2035 condition with a predicted increase of less than
1 dBA due to the project contribution. Additionally,
although the increase in noise level for the project
driveway is greater than 5 dBA and therefore higher
than the FICON thresholds and perceptible to the
average person, there are no noise-sensitive
receptors adjacent to the project driveway; the
nearest noise-sensitive receptors to the south of the
project are already dominated by much higher levels
of traffic noise from nearby adjacent roadways such
as SR-67, while noise-sensitive receptors to the north
of the project are occluded from the project driveway
by intervening buildings and terrain. Therefore,
potential impacts at existing off-site noise-sensitive
land uses along roadway segments identified in Table
7 and with respect to project-generated changes to
future traffic noise would be less than significant.

Therefore, the Project is consistent with this policy.

Policy 2.3. The City should not require new
development to mitigate noise impacts to existing
uses when the new development only adds traffic
already anticipated by the City’s General Plan to an
Consistent. As discussed in Section 4.10, Noise, all
impacts would be less than significant. Therefore, no
mitigation is required.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-10
Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
existing street, but does not necessitate widening of
that street.

Safety
Goal. The goal of the Safety Element is to minimize
injuries, loss of life, and property damages resulting
from natural and human-induced safety hazards.

Consistent. As discussed in Chapter 3, Project
Description, and Chapter 5, Effects Found Not To Be
Significant, the Project would be designed consistent
with applicable regulatory requirements that would
address potential impacts associated with flooding,
fire, seismic hazards, criminal activities, and
hazardous materials.

Objective 1.0. Minimize injuries, loss of life and
property damage resulting from flood hazards.

Consistent. As discussed above, compliance with the
California Building Code and incorporation of the
recommendations of the Geotechnical Investigation
would ensure the structural integrity of the Project.

Further, as part of the Project design process, a sitespecific hydrologic study was conducted for the Project site to detail the hydrology characteristics of the site and develop specific design
recommendations to ensure the finished floor
elevation of the proposed building is well above the
100-year flood level.

Policy 1.6. The City should require a hydrologic study, including the analysis of effects on downstream and
upstream properties and on the flood-carrying
characteristics of the stream, for development
proposed in the floodplain.

Consistent. As part of the Project design process, a
site-specific hydrologic study was conducted for the
Project site to detail the hydrology characteristics of the site and develop specific design
recommendations to ensure the finished floor
elevation of the proposed building is well above the
100-year flood level.

Objective 2.0. Minimize the loss of life and destruction of property in Santee caused by seismic and geologic
hazards.

Consistent. As part of the Project design process, a
site-specific Geotechnical Investigation was
conducted for the Project site to detail the
geotechnical characteristics of the site and develop
specific design recommendations to ensure the
structural integrity of the Project. As discussed in
Chapter 5, Effects Found Not To Be Significant, the
Project would be designed consistent with applicable
regulatory requirements that would address potential
impacts associated with seismic and geologic
hazards.

Policy 2.2. The City should ensure that if a project is proposed in an area identified herein as seismically
and/or geologically hazardous, the proposal shall
demonstrate through appropriate geologic studies
and investigations that either the unfavorable
conditions do not exist in the specific area in question or that they may be avoided or mitigated through
proper site planning, design and construction.

Consistent. As discussed in Chapter 5, Effects Found
Not To Be Significant, the Project would be designed
consistent with applicable regulatory requirements
that would address potential geologic and seismic
hazards. Further, as part of the Project design
process, a site-specific Geotechnical Investigation was conducted for the Project site to detail the
geotechnical characteristics of the site and develop

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-11
Table 4.9-1. Consistency with City of Santee General Plan Goals, Objectives, and Policies
Goals Response
specific design recommendations to ensure the
structural integrity of the Project.

Policy 2.3. The City shall require that all potential
geotechnical and soil hazards be fully investigated at
the environmental review stage prior to project
approval. Such investigations shall include those
identified by Table 8.1, Determination of Geotechnical
Studies Required, and such soil studies as may be
warranted by results of the Initial Environmental
Study.

Consistent. As discussed in Chapter 5, Effects Found
Not To Be Significant, the Project would be designed
consistent with applicable regulatory requirements
that would address potential geotechnical and soil
hazards. Further, as part of the Project design
process, a site-specific Geotechnical Investigation was conducted for the Project site to detail the
geotechnical and soil characteristics of the site and
develop specific design recommendations to ensure
the structural integrity of the Project.

Objective 3.0. Minimize the risk of damage to
persons, property and the environment caused by
hazardous materials.

Consistent. As discussed in Chapter 4.7, Hazards and
Hazardous Materials, all hazardous materials would
be transported and handled in accordance with all
federal, state, and local laws regulating the
management and use of hazardous materials.

Further, a Phase I study was prepared for the site and
vicinity. No hazardous materials were found onsite,
and any previously identified hazardous conditions in
the project vicinity have been cleaned up and cases
closed.

Policy 4.11. In order to minimize fire hazards, the
Santee Fire and Life Safety Department shall routinely
be involved in the review of development applications.

Considerations shall be given to adequate emergency
access, driveway widths, turning radii, fire hydrant
locations and needed fire flow requirements.

Consistent. As part of the Project’s plan review
process, the Project’s plans have been reviewed by
the Santee Fire Department. Adequate emergency
access, driveway widths, turning radii, fire hydrant
locations and fire flow requirements have been
incorporated into the proposed Project.

Mobility
Policy 2.1. The City shall encourage an automobile
Level of Service “D” on street segments and at
intersections throughout the circulation network while
also maintaining or improving the effectiveness of the
non-automotive components of the circulation system
(i.e. pedestrians, bicyclists, and public transit),
especially in the Town Center area. The City may
approve a lower automobile Level of Service if it finds that the effectiveness of non-automotive components
of the circulation system would be maintained or
improved as a result. In other cases, the City shall not approve any development that causes a drop in the
level of service at a street segment or an intersection to LOS "E" or "F", after feasible mitigation, without
overriding social, economic, or other benefits.

Consistent. As discussed in Section 4.12,
Transportation, and the Transportation Impact Study
(Appendix L), the applicant has prepared a detailed
memorandum (Appendix L of the TIS which is included
as Appendix L of this EIR) describing consistency of
the improvements proposed by the Project with the
City’s Mobility Element goals and policies.

As described in Table 4.9-1, the Project would be consistent with the applicable goals and policies set forth by the City’s General Plan. Therefore, impacts would be less than significant.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-12
SANDAG 2021 Regional Plan/Sustainable Communities Strategy The 2021 Regional Plan (RP)/Sustainable Communities Strategy (SCS) was adopted on December 10, 2021, and presents the land use and transportation vision for the region through the year 2050, providing a long-term investment framework for addressing the region’s challenges. The RP/SCS establishes goals for the region and identifies transportation investments that address the region’s growing population, as well as strategies to reduce traffic congestion, air pollution, and GHG emissions. In addition, the RP/SCS is supported by a combination of transportation and land use strategies that help the region achieve state GHG emission reduction goals and federal Clean Air Act requirements, preserve open space areas, improve public health and roadway safety, support the region’s vital goods movement industry, and utilize resources more efficiently (SANDAG 2021).

Consistency with the 2021 RP/SCS goals, below, demonstrates that the Project would not conflict with the applicable goals in the RP/SCS adopted for the purpose of avoiding or mitigating an environmental effect. Table 4.9-2 demonstrates how the Project promotes consistency with the guiding principles and policies of the RP/SCS.

Table 4.9-2. Consistency with 2021 RP/SCS Goals
RP/SCS Goal Project Applicable Component(s)
Goal 1
The efficient movement of
people and goods
Consistent. The Project would include construction and operation of an industrial warehouse that would be easily and efficiently accessible to SR67 and SR-52 which would help to facilitate regional goods movement throughout Southern California.

Goal 2
Access to affordable reliable,
and safe mobility options for
everyone
Consistent. The proposed Project site is located along a designated truck route within the City, and these truck routes extend to easily accessible freeway on and off-ramps to SR-67 and SR-52. Locating the proposed warehouse building at the subject site would allow for reliable and safe transport of goods.

Goal 3
Healthier air and reduced GHG
emissions regionwide
Consistent. The Project would involve development of a
warehouse/industrial use that inherently involves the emission of GHG and air contaminant emissions. As discussed in Section 4.2, Air Quality, and Section 4.6, Greenhouse Gas Emissions, the Project would implement mitigation measures to reduce air quality and greenhouse gas emissions to the maximum extent feasible. In addition, according to SANDAG’s Goods Movement Plan and the San Diego & Imperial Counties Sustainable Freight Implementation Strategy, the region will run out of suitably zoned vacant land designated for warehouse facilities in or around 2030. Thus, the Project would meet the growing demand warehousing space, and would do so in an area that is proximate to regional highways (i.e., SR-67 and SR-57), thereby reducing the need for longer distance trips which could result in additional air pollutant and GHG emissions.

Additionally, the Project will install 16 EV charging stations in accordance with CALGreen standards to support electric vehicle use thereby reducing toxic air contaminants and their effect on GHG. The project would also employ approximately 185 workers, helping the City better meet its jobs/housing balance (See existing setting and Project objectives discussion in Chapter 3, Project Description), which should shorten commute distances of City residents who choose to work on the Project site, which would have a direct positive effect on tailpipe GHG and air contaminant emissions.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-13
As described in Table 4.9-2, the Project would be consistent with the applicable goals set forth by SANDAG in the 2021 Regional Plan. Therefore, impacts would be less than significant.

SDAPCD
The Project’s consistency with the SDAPCD’s plan is addressed in detail in 4.2, Air Quality. As concluded in Section 4.2, the Project is consistent with the underlying land use and zoning for the Project site. Therefore, the Project source emissions are not anticipated to result in air quality impacts that were not previously envisioned in the growth projections and RAQS, and implementation of the Project would not result in development in excess of that anticipated in local plans or increases beyond those contemplated by SANDAG. Because the proposed land uses and associated vehicle trips are anticipated in local air quality plans, the Project would be consistent at a regional level with the underlying growth forecasts in the RAQS. Accordingly, the Project would not conflict with and would not obstruct implementation of applicable local and regional air quality plans; impacts would be less than significant.

San Diego County RTCIP/RAS
The Project’s consistency with the San Diego County RTCIP/RAS is addressed in Section 4.12, Transportation. As concluded in Section 4.12, the Project would not conflict with the San Diego County RTCIP/RAS LOS standards for the RTCIP arterial roadway and freeway network. Land use and planning impacts associated with RTCIP consistency would thus be less than significant.

4.9.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to land use and planning would be less than significant. No mitigation is required.

4.9 – LAND USE AND PLANNING
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.9-14

INTENTIONALLY LEFT BLANK

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-1

4.10 Noise
This section describes the existing noise conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7 of Chapter 2 of this EIR), the following analysis is based, in part, on the following sources:
▪ Noise Technical Report, prepared by Dudek in May 2024 (Appendix K)

4.10.1 Existing Conditions
Noise and Vibration Characteristics
Noise
Sound may be described in terms of level or amplitude (measured in decibels [dB]), frequency or pitch (measured in hertz [Hz] or cycles per second), and duration (measured in seconds or minutes). The standard unit of measurement of the amplitude of sound is the decibel. Because the human ear is not equally sensitive to sound at all frequencies, a special frequency-dependent rating scale is used to relate noise to human sensitivity. The Aweighted decibel scale (dBA) performs this compensation by discriminating against low and very high frequencies in a manner approximating the sensitivity of the human ear. Several descriptors of noise (noise metrics) exist to help predict average community reactions to the adverse effects of environmental noise, including trafficgenerated noise, on a community. These descriptors include the equivalent noise level over a given period (Leq), the statistical sound level (Ln), the day–night average noise level (Ldn), and the Community Noise Equivalent Level (CNEL). Each of these descriptors uses units of dBA. Table 4.10-1 provides examples of A-weighted noise levels from common sounds. In general, human sound perception is such that a change in sound level of 3 dB is barely noticeable; a change of 5 dB is clearly noticeable; and a change of 10 dB is perceived as doubling or halving of the sound level.

Leq is a sound energy level averaged over a specified period (typically no less than 15 minutes for environmental studies). Leq is a single numerical value that represents the amount of variable sound energy received by a receptor during a time interval. For example, a 1-hour Leq measurement would represent the average amount of energy contained in all the noise that occurred in that hour. Leq is an effective noise descriptor because of its ability to assess the total time-varying effects of noise on sensitive receptors (see below for definition of sensitive receptors).

Lmax is the greatest sound level measured during a designated time interval or event.

Unlike the Leq metrics, Ldn and CNEL metrics always represent 24-hour periods, usually on an annualized basis. Ldn and CNEL also differ from Leq because they apply a time-weighted factor designed to emphasize noise events that occur during the evening and nighttime hours (when speech and sleep disturbance is of more concern). “Time weighted” refers to the fact that Ldn and CNEL penalize noise that occurs during certain sensitive periods. In the case of CNEL, noise occurring during the daytime (7:00 a.m.–7:00 p.m.) receives no penalty. Noise during the evening (7:00 p.m.–10:00 p.m.) is penalized by adding 5 dB, while nighttime (10:00 p.m.–7:00 a.m.) noise is penalized by adding 10 dB. Ldn differs from CNEL in that the daytime period is defined as 7:00 a.m.–10:00 p.m., thus eliminating the evening period. Ldn and CNEL are the predominant criteria used to measure roadway noise

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-2
affecting residential receptors. These two metrics generally differ from one another by no more than 0.5 dB to 1 dB, and as such are often treated as equivalent to one another.

Table 4.10-1. Typical Sound Levels in the Environment and Industry Common Outdoor Activities
Noise Level
(dBA) Common Indoor Activities
— 110 Rock band
Jet flyover at 300 meters (1,000 feet) 100 —
Gas lawn mower at 1 meter (3 feet) 90 —
Diesel truck at 15 meters (50 feet), at 80 kph
(50 mph)
80 Food blender at 1 meter (3 feet)
Garbage disposal at 1 meter (3 feet)
Noisy urban area, daytime
gas lawn mower at 30 meters (100 feet)
70 Vacuum cleaner at 3 meters (10 feet)
Commercial area
Heavy traffic at 90 meters (300 feet)
60 Normal speech at 1 meter (3 feet)
Quiet urban daytime 50 Large business office
Dishwasher, next room
Quiet urban nighttime 40 Theater, large conference room (background)
Quiet suburban nighttime 30 Library
Quiet rural night time 20 Bedroom at night, concert hall (background)
— 10 Broadcast/recording studio
Lowest threshold of human hearing 0 Lowest threshold of human hearing Source: Caltrans 2013.

Notes: dBA = A-weighted decibels; kph = kilometers per hour; mph = miles per hour.

Vibration
Vibration is an oscillatory motion through a solid medium in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. Vibration can be a serious concern, causing buildings to shake and rumbling sounds to be heard. In contrast to noise, vibration is not a common environmental problem. It is unusual for vibration from sources such as buses and trucks to be perceptible, even in locations close to major roads. Some common sources of vibration are trains, buses on rough roads, and construction activities, such as blasting, pile driving, and heavy earthmoving equipment.

Several different methods are used to quantify vibration. Peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal. PPV is most frequently used to describe vibration impacts to buildings and is usually measured in inches per second. The root mean square amplitude is most frequently used to describe the effect of vibration on the human body and is defined as the average of the squared amplitude of the signal.

Decibel notation (VdB) is commonly used to measure root mean square. VdB acts to compress the range of numbers required to describe vibration.

High levels of vibration may cause physical personal injury or damage to buildings. However, vibration levels rarely affect human health. Instead, most people consider vibration to be an annoyance that can affect concentration or disturb sleep. In addition, high levels of vibration can damage fragile buildings or interfere with equipment that is highly sensitive to vibration (e.g., electron microscopes). Most perceptible indoor vibration is caused by sources

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-3
within buildings, such as operation of mechanical equipment, movement of people, or slamming of doors. Typical outdoor sources of perceptible vibration are construction equipment, steel-wheeled trains, and traffic on rough roads. If the roadway is smooth, the vibration from traffic is rarely perceptible.

Sensitive Receptors
Noise- and vibration-sensitive land uses are locations where people reside or where the presence of unwanted sound could adversely affect the use of the land. Residences, schools, hospitals, guest lodging, libraries, and some passive recreation areas would be considered noise and vibration sensitive and may warrant unique measures for protection from intruding noise.

The closest sensitive receptors to the Project site are the existing residences located approximately 310 feet from the Project driveway, south of North Woodside Avenue, and 650 feet north of the Project boundary, north of the San Diego River.

Existing Noise Conditions
Sound pressure level (SPL) measurements were conducted near the proposed project site on March 25, 2023, to quantify and characterize the existing outdoor ambient sound levels. Another set of SPL measurements were conducted near the proposed project site on March 18 and 19, 2024, to help further characterize the existing outdoor noise levels for the single-family residences located north of the San Diego River.

Table 4.10-2 provides the location and time period at which these baseline noise level measurements were performed by an attending Dudek field investigator. The March 2023 measurements were conducted using a Rionbranded Model NL-52 sound level meter (SLM) equipped with a 0.5-inch, pre-polarized condenser microphone with pre-amplifier. The SLM meets the current American National Standards Institute standard for a Type 1 (Precision Grade) sound level meter, while the March 2024 measurements were made using a SoftdB “Piccolo” model sound level meter equipped with a windscreen-protected, 0.5-inch diameter pre-polarized condenser microphone with preamplifier. The sound level meter meets the current American National Standards Institute (ANSI) standard for a Type 2 (General Use) sound level meter.

The accuracy of the SLM was verified using a field calibrator before and after the measurements, and the measurements were conducted with the microphone positioned approximately 5 feet above theground.

Five (5) short-term (ST) noise level measurement locations (ST1–ST5) that represent existing noise-sensitive receivers were selected on and near the proposed Project site. These locations are depicted as receivers ST1–ST5 on Figure 4.10-1. The measured Leq and Lmax noise levels are provided in Table 4-10-2. The primary noise sources at the sites identified in Table 4-10-2 consisted of traffic along adjacent roadways, aircraft, the sounds of leaves rustling, conversations, and birdsong during the daytime, and frog noise at night. As shown in Table 4-10-2, the measured daytime SPL ranged from 53.1 dBA Leq at ST4 to 76.8 dBA Leq at ST1, and the measured nighttime SPL ranged from 50.2 at ST2 to 51.2 at ST5. Beyond the summarized information presented in Table 4.10-2, detailed noise measurement data is included in Appendix K.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-4
Table 4.10-2. Measured Baseline Outdoor Ambient Noise Levels Site Location/Address Time Leq (dBA) Lmax (dBA)
ST1 East of Woodside Avenue at Shadow Hill
Apartments
2023-03-25,
9:01 AM to 9:06 AM

76.8 84.3
ST2 Cul-de-sac of Hillcreek Way 2023-03-25,
9:25 AM to 9:35 AM

55.6 66.8
South from the cul-de-sac of Hillcreek
Way, along Walker Preserve Trail
2024-03-19,
1:14 PM to 2:14 PM

53.8 75.5
2024-03-18,
8:21 PM to 9:21 PM

50.2 73.9
ST3 Southern project boundary 2023-03-25,
10:25 AM to 10:35 AM

60.3 75.5
ST4 Walker Preserve Trail, northwest of
project boundary
2023-03-25,
9:45 AM to 10:00 AM

53.1 71.2
2024-03-19,
1:22 PM to 2:22 PM

54.1 75.4
2024-03-18,
8:28 PM to 9:28 PM

50.5 64.1
ST5 Walker Preserve Trail, north of project
boundary
2024-03-19,
1:29 PM to 2:29 PM

55.2 75.9
2024-03-18,
8:40 PM to 9:40 PM

51.2 58.2
Source: Appendix K.

Notes: Leq = equivalent continuous sound level (time-averaged sound level); Lmax = maximum sound level during the measurement interval; dBA = A-weighted decibels; ST = short-term noise measurement locations.

Generally, the measured samples of daytime Leq agree with expectations: ST1 and ST3 Leq values are above 60 dBA due largely to their proximity to Highway 67. ST2, ST4, and ST5, however, are in residential and trail areas north of the proposed Project and are more distant from these sources of traffic noise, which results in a substantially lower sampled Leq value. Noise measurements were not conducted during time periods when the swap meet was operating. Therefore, the ambient noise level measurements conducted for the Project are likely lower than ambient noise levels when the swap meet is operational.

4.10.2 Relevant Plans, Policies, and Ordinances
Federal
Federal Transit Administration
In its Transit Noise and Vibration Impact Assessment guidance manual, the FTA recommends a daytime construction noise level threshold of 80 dBA Leq over an 8-hour period (FTA 2018) when detailed construction noise assessments are performed to evaluate potential impacts to community residences surrounding a project. Although this FTA guidance is not a regulation, it can serve as a quantified standard in the absence of such noise limits at the state and local jurisdictional levels.
0 #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! 1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
29 30
31 32
33 34
35 36
37 38
39 40
41 42
43 44
45 46
47 48
49 50
51 52
53 54
55 56
57 58
59 60
61 62
63 64
65 66
67 68
69 70
71 72
73 74
75 76
77 78
79 80
81 82
83 84
85 86
87 88
89 90
91 92
93 94
95 96
97 98
99 100
SOURCE: Google 2024; Dudek 2024
Palisades Santee Commerce Center Project
FIGURE 4.10-1
Noise Measurement Locations
ST3
ST1
ST2
March 2023
Project
Site
ST4
ST2
March 2024
ST5
March 2024
San Diego River

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-6

INTENTIONALLY LEFT BLANK

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-7
Federal Interagency Committee on Noise
Some guidance regarding the determination of a substantial permanent increase in ambient noise levels in the project vicinity above existing levels is provided by the 1992 findings of the Federal Interagency Committee on Noise (FICON 1992), which assessed the annoyance effects of changes in ambient noise levels resulting from aircraft operations. The FICON recommendations are based upon studies that relate aircraft and traffic noise levels to the percentage of persons highly annoyed by the noise. Annoyance is a qualitative measure of the adverse reaction of people to noise that generates speech interference, sleep disturbance, or interference with the desire for a tranquil environment.

The rationale for the FICON recommendations is that it is possible to consistently describe the annoyance of people exposed to transportation noise in terms of Ldn. The changes in noise exposure that are shown below are expected to result in equal changes in annoyance at sensitive land uses. Although the FICON recommendations were specifically developed to address aircraft noise impacts, they are used in this analysis to define a substantial increase in community noise levels related to all transportation noise sources and permanent non-transportation noise sources.
▪ Outdoor ambient sound level without the project is less than 60 dBA Ldn, then a project-attributed increase of 5 dBA or more would be considered significant;
▪ Outdoor ambient sound level without the project is between 60 and 65 dBA Ldn, project-attributed increase of 3 dBA or more would be considered significant; and
▪ Outdoor ambient sound level without the project is greater than 65 dBA Ldn, then project-attributed increase of 1.5 dBA or more would be considered significant.

State
California Code of Regulations, Title 24
Title 24 of the California Code of Regulations sets standards that new developments in California must meet.

According to Title 24, interior noise levels are not to exceed 45 dBA CNEL in any habitable room (ICC 2019).

California Department of Health Services Guidelines
The California Department of Health Services has developed guidelines of community noise acceptability for use by local agencies (OPR 2017). Selected relevant levels are listed here:
▪ Below 60 dBA CNEL: normally acceptable for low-density residential use ▪ 50 to 70 dBA CNEL: conditionally acceptable for low-density residential use ▪ Below 65 dBA CNEL: normally acceptable for high-density residential use and transient lodging ▪ 60 to 70 dBA CNEL: conditionally acceptable for high-density residential, transient lodging, churches, educational, and medical facilities
The normally acceptable exterior noise level for high-density residential use is up to 65 dBA CNEL. Additionally, this exterior noise level limit is consistent with the City of Santee General Plan Noise Element, which considers multifamily unit noise-sensitive land uses.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-8
California Department of Transportation
In its Transportation and Construction Vibration Guidance Manual (Caltrans 2020), the California Department of Transportation (Caltrans) recommends 0.5 ips PPV as a threshold for the avoidance of structural damage to typical newer residential buildings exposed to continuous or frequent intermittent sources of groundborne vibration. For transient vibration events, such as blasting, the damage risk threshold would be 1.0 ips PPV (Caltrans 2020) at the same type of newer residential structures. For older structures, these guidance thresholds would be more stringent:

0.3 ips PPV for continuous/intermittent vibration sources, and 0.5 ips PPV for transient vibration events. With respect to human annoyance, Caltrans guidance indicates that building occupants exposed to continuous groundborne vibration in the range of 0.2-0.6 ips PPV would find it “unpleasant or “annoying” and thus a likely significant impact. Although these Caltrans guidance thresholds are not regulations, they can serve as quantified standards in the absence of such limits at the local jurisdictional level.

Local
City of Santee Noise Level Compatibility Standards
The Noise Element of the City’s General Plan (City of Santee 2003) establishes target maximum noise levels in the City, categorized by land use. The Noise Element sets the following limitations on noise levels for receiving properties adjacent to the project site. Figure 4.10-2 contains the Noise / Land Use Compatibility Guide from the General Plan Noise Element, which establishes a maximum noise level of 65 dBA Ldn for noise-sensitive land uses and 75 dBA Ldn for industrial land uses.

Transportation-Related Noise Standards
The City’s Noise Element establishes a policy for exterior sensitive areas to be protected from high traffic noise levels. The Noise Element sets 65 dBA Ldn for exterior noise levels and 45 dBA Ldn for interior noise levels as the “normally acceptable” level.

For interior noise, the Noise Element also establishes 45 dBA Ldn as the maximum acceptable level for habitable rooms when exterior predicted noise levels due to traffic are 65 dBA Ldn or more. If windows and doors are required to be closed to meet this standard, then mechanical ventilation (i.e., air conditioning) shall be included in the project design.

Figure 4.10-2 City of Santee Noise / Land Use CompaƟbility Guide

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-10

INTENTIONALLY LEFT BLANK

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-11
City of Santee General Plan
Noise Element
The Noise Element contains a section on the noise abatement and control objectives and policies for the City, a selection of which is presented here.

Objective 1.0 Control noise from sources adjacent to residential, institutional and other noise-sensitive receptors.

Policy 1.1 The City shall support a coordinated program to protect and improve the acoustical environment of the City including development review for new public and private development and code compliance for existing development.

Policy 1.2 The City shall utilize noise studies and noise contour maps when evaluating development proposals during the discretionary review process.

Policy 1.3 The City shall enforce motor vehicle laws and standards as appropriate, related to traffic flow and speed, in an effort to reduce noise along roadways experiencing high noise levels.

Policy 1.4 The City shall promote alternative sound attenuation measures rather than traditional wall barriers wherever feasible; these may include glass or polycarbonate walls, berms, landscaping, and the siting of noise-sensitive uses on a parcel away from the roadway or other noise source.

Policy 1.5 The City shall review future projects with particular scrutiny regarding the reduction of unnecessary noise near noise-sensitive areas such as hospitals, schools, parks, etc.

Policy 1.6 The City shall continue to monitor noise throughout Santee and enforce the standards and regulations of the City's Noise Ordinance.

Policy 1.15 The City shall encourage Caltrans to recognize and implement the City’s noise standards for planned and future freeway projects in the City.

Policy 1.16 The City shall ensure that appropriate regulations and standards are incorporated into the City's development policies and ordinances, including the use of noise evaluations in Environmental Impact Reports and statements, which take all aspects of noise into consideration.

Policy 1.17 The City shall officially support the control of noise through legal regulations and cooperative government efforts.

Objective 2.0 Ensure that future developments will be constructed to minimize interior and exterior noise levels.

Policy 2.1 The City shall adhere to planning guidelines and building codes which include noise control for the exterior and interior living space of all new residential developments within noise impacted areas.

Policy 2.2 The City should require new development to mitigate noise impacts to existing uses resulting from new development when: 1) such development adds traffic to existing City streets that necessitates the widening of the street; and 2) the additional traffic generated by the new development causes the noise standard or significance thresholds to be exceeded.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-12
Policy 2.3 The City should not require new development to mitigate noise impacts to existing uses when the new development only adds traffic already anticipated by the City’s General Plan to an existing street, but does not necessitate widening of that street.

City of Santee Noise Ordinance
Construction activities are subject to Section 5.04.090 of the City’s Noise Ordinance, which specifically prohibits the operation of any single or combination of powered construction equipment at any construction site on Mondays through Thursday except between the hours of 7:00 a.m. and 7:00 p.m. Further, construction equipment with a manufacturer's noise rating of 85 dBA Lmax or greater may only operate at a specific location for 10 consecutive workdays. A notice must be provided to all property owners within 300 feet if work is scheduled for more than 10 days and must be provided no later than 10 days prior to the start of the construction.

The Project would include loading and unloading activities as part of Project operation. Therefore, Project operations would be subject to Municipal Code Section 5.04.130 which makes it unlawful for any person to engage in loading, unloading, opening, idling of trucks, closing or other handling of boxes, crates, containers, building materials, garbage cans, dumpsters or similar objects between the hours of 10:00 p.m. and 7:00 a.m. in such a manner as to cause a noise disturbance within or adjacent to a residential district.

Municipal Code Section 5.04.160 applies to any noise source not specifically addressed in this chapter, except where exempted or excluded by Section 5.04.170. This Section states that it is unlawful for any person to generate any noise on the public way that is louder than average conversational level at a distance of 50 feet or more, vertically or horizontally, from the source between 10:00 p.m. and 7:00 a.m. Also, between 10:00 p.m. and 7:00 a.m., no person is permitted to generate any noise on any private open space that is louder than average conversational level at a distance of 50 feet or more, measured from the property line of the property from which the noise is being generated.

4.10.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts related to noise are based on California Environmental Quality Act (CEQA) Appendix G. According to CEQA Guidelines Appendix G, a significant impact related to noise would occur if the Project would:

A. Result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

B. Result in generation of excessive groundborne vibration or groundborne noise levels.

C. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the Project area to excessive noise levels.

In light of these above significance criteria, this analysis uses the following standards to evaluate potential noise and vibration impacts.
▪ Construction noise –The apparent proximity of existing residential receptors located south of North Woodside Avenue suggests that source-to-receiver distances are a minimum of approximately 310 feet. Additionally, most construction equipment and vehicles on a project site do not operate

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-13
continuously. Therefore, consistent with the FTA guidance mentioned in Section 4.10.2, this analysis will use 80 dBA Leq over an 8-hour period as the construction noise impact criterion during daytime hours (7:00 a.m. to 7:00 p.m.).
▪ Off-site project-attributed transportation noise – For purposes of this analysis, a noise impact due to transportation noise would be considered significant if predicted noise levels exceeded the FICON thresholds noted in Section 4.10.2. More specifically, an impact due to the project contribution to existing and future predicted ambient noise levels would be considered significant if it meets the following criteria:
- Outdoor ambient sound level without the project is less than 60 dBA Ldn, then a project-attributed increase of 5 dBA or more would be considered significant; - Outdoor ambient sound level without the project is between 60 and 65 dBA Ldn, project-attributed increase of 3 dBA or more would be considered significant; and - Outdoor ambient sound level without the project is greater than 65 dBA Ldn, then project-attributed increase of 1.5 dBA or more would be considered significant. ▪ Off-site project-attributed stationary noise – For purposes of this analysis, a noise impact would be considered significant if noise from typical operation of heating, ventilation, and air conditioning (HVAC), truck movements, and other electro-mechanical systems associated with the proposed project exceeded 75 dBA Ldn at the property line. Note that these are the City’s thresholds for the industrial zones that characterize the proposed project site. For residential land uses near the project site, a noise impact would be considered significant if noise from typical operations exceeds 65 dBA L dn. ▪ Construction vibration – Guidance from Caltrans indicates that a vibration velocity level of 0.2 ips PPV received at a structure would be considered annoying by occupants within (Caltrans 2013. As for the receiving structure itself, aforementioned Caltrans guidance from Section 4.10.2 recommends that a vibration level of 0.3 ips PPV would represent the threshold for building damage risk.

4.10.4 Impacts Analysis
A. Would the Project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Short-Term Construction Impacts
Less-than-Significant Impact. Construction noise and vibration are temporary phenomena, with emission levels varying from hour to hour and day to day, depending on the equipment in use, the operations performed, and the distance between the source and receptor. Equipment that would be in use during construction would include, in part, graders, backhoes, rubber-tired dozers, loaders, cranes, forklifts, pavers, rollers, and air compressors. The typical maximum noise levels at a distance of 50 feet from various pieces of construction equipment and activities anticipated for use on the proposed project site are presented in Table 4.10-3. Note that the equipment noise levels presented in Table 4.10-3 are maximum noise levels. Usually, construction equipment operates in alternating cycles of full power and low power, producing average noise levels over time that are less than the maximum noise level.

The average sound level of construction activity also depends on the amount of time that the equipment operates and the intensity of construction activities during that time.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-14
Table 4.10-3. Typical Construction Equipment Maximum Noise Levels Equipment Type Typical Equipment (Lmax, dBA at 50 Feet) All Other Equipment > 5 HP 85
Backhoe 78
Compressor (air) 78
Concrete Saw 90
Crane 81
Dozer 82
Excavator 81
Flat Bed Truck 74
Front End Loader 79
Generator 72
Grader 85
Man Lift 75
Paver 77
Roller 80
Scraper 84
Welder / Torch 73
Source: DOT 2006.

Note: Lmax = maximum sound level; dBA = A-weighted decibels.

Aggregate noise emission from proposed Project construction activities, broken down by sequential phase, was predicted at two evaluation distances to the nearest existing noise-sensitive receptor: 1) from the nearest position of the construction site boundary and 2) from the geographic center of the construction site, which serves as the time-averaged location or geographic acoustical centroid of active construction equipment for the phase under study. The intent of the former distance is to help evaluate anticipated construction noise from equipment or vehicle activity expected to be at the boundary for some period of time, which would be most appropriate for phases such as site preparation, grading, and paving. The latter distance is used in a manner similar to the general assessment technique as described in the FTA guidance for construction noise assessment, when the location of individual equipment for a given construction phase is uncertain over some extent of (or the entirety of) the construction site area. In this studied scenario, because of the equipment location uncertainty, all the equipment for a construction phase is assumed to operate—on average—from the acoustical centroid position. Table 4.10-4 summarizes these two distances to the apparent closest noise-sensitive receptor for each of the six sequential construction phases.

At the site boundary, this analysis assumes that all equipment of each listed type per phase will be involved in the construction activity for the full 8-hour period. For the acoustical centroid case, which intends to be a geographic average position for all equipment during the indicated phase, this analysis assumes that the equipment may be operating up to eight hours per day.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-15
Table 4.10-4. Estimated Distances between Construction Activities and the Nearest Noise-Sensitive Receptors
Construction Phase
(and Equipment
Types Involved)
Distance from Nearest NoiseSensitive Receptor to Construction Site Boundary (Feet)
Distance from Nearest NoiseSensitive Receptor to Acoustical Centroid of Site (Feet)
Demolition (concrete saw,
excavator, dozer)
310 990
Site Preparation (dozer,
front end loader)
310 990
Grading (excavator,
grader, dozer, scraper
backhoe)
310 990
Building construction
(crane, man-lift,
generator,
backhoe, welder)
310 990
Paving (paver, roller,
concrete mixer truck)
310 990
Architectural Coating
(compressor)
310 990
A Microsoft Excel–based noise prediction model emulating and using reference data from the Federal Highway Administration Roadway Construction Noise Model (RCNM) (FHWA 2008) was used to estimate construction noise levels at the nearest occupied noise-sensitive land use. Although the RCNM was funded and promulgated by the Federal Highway Administration, it is often used for non-roadway projects, because the same types of construction equipment used for roadway projects are often used for other types of construction. Input variables for the predictive modeling consist of the equipment type and number of each (e.g., two graders, a loader, a tractor), the duty cycle for each piece of equipment (e.g., percentage of time within a specific time period, such as an hour, when the equipment is expected to operate at full power or capacity and thus make noise at a level comparable to what is presented in Table 4.10-3), and the distance from the noise-sensitive receiver. The predictive model also considers how many hours that equipment may be on-site and operating (or idling) within an established work shift.

Conservatively, no topographical or structural shielding was assumed in the modeling. The RCNM has default dutycycle values for the various pieces of equipment, which were derived from an extensive study of typical construction activity patterns. Those default duty-cycle values were used for this noise analysis, which is detailed in Appendix K, and produced the predicted results displayed in Table 4.10-5.

Table 4.10-5. Predicted Construction Noise Levels per Activity Phase Construction Phase (and
Equipment Types
Involved)
8-Hour Leq at Nearest NoiseSensitive Receptor to Construction Site Boundary (dBA)
8-Hour Leq at Nearest NoiseSensitive Receptor to Acoustical Centroid of Site (dBA)
Demolition (concrete saw,
excavator, dozer)

66.5 55.3
Site Preparation (dozer,
front end loader)

64.3 53.1
Grading (excavator, grader,
dozer, scraper backhoe)

67.0 55.8

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-16
Table 4.10-5. Predicted Construction Noise Levels per Activity Phase Construction Phase (and
Equipment Types
Involved)
8-Hour Leq at Nearest NoiseSensitive Receptor to Construction Site Boundary (dBA)
8-Hour Leq at Nearest NoiseSensitive Receptor to Acoustical Centroid of Site (dBA)
Building construction
(crane, man-lift, generator,
backhoe, welder)

60.8 49.5
Paving (paver, roller,
concrete mixer truck)

60.6 49.3
Architectural Coating
(compressor)

52.5 41.2
Notes: Leq = equivalent noise level; dBA = A-weighted decibels.

As presented in Table 4.10-5, the highest estimated construction noise levels are predicted to stay below 67 dBA Leq over an 8-hour period at the nearest existing residences (located south of North Woodside Avenue and as close as 310 feet from the project driveway) when grading activities take place near the project driveway. Residences further afield, such as those to the north of the project site, would be predicted to have lower construction noise levels than those shown in Table 4.10-5. Additionally, the nearest existing residences to the south are dominated by traffic noise from SR-67, and intervening barriers and terrain were not considered in the model. As a result, shortterm construction noise is predicted to be well below the FTA guidance of 80 dBA Leq over an 8-hour period, and therefore is less than significant.

Short-Term Off-Site Construction Noise
Less-than-Significant Impact. The Project would result in local, short-term increases in roadway noise as a result of construction traffic. Based on information developed as part of the Project’s air quality analysis, Project-related traffic would include workers commuting to and from the Project site as well as vendor and haul trucks bringing or removing materials. The highest number of average daily worker trips would be 122 trips, occurring during the building construction phase. The highest number of average daily vendor truck trips would be 48 trips, also occurring during the building construction phase. The highest number of total haul truck trips would be 6,675 trips, occurring during the demolition phase over a period of 25 days. Based upon available data provided in the Transportation Impact Study (TIS) (Appendix L), existing Average Daily Traffic (ADT) volumes were combined with the construction truck haul trips (an average of 275 haul trucks per day) and truck percentages found in the Project’s TIS were derived to include the increase in heavy trucks and applied to all of the studied roadway ADTs to determine the potential noise level increase due to construction noise. Aside from the Project driveway, it is not known which roadways will be used to route construction traffic.

Therefore, applying the average of 275 haul trucks per day to all studied Project roadway ADTs represents an extremely conservative prediction methodology.

The change in roadway noise levels was predicted for two conditions: existing and existing plus average daily haul truck construction traffic. Traffic noise levels were calculated for roadway segments bounded by intersections within the Project area and are listed as follows:
▪ Project Driveway – From N. Woodside Avenue to the Project; ▪ Wheatlands Avenue – From N. Woodside Avenue to Wheatlands Road; ▪ N. Woodside Avenue – From Wheatlands Avenue to Woodside Avenue (combined north/south split);

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-17
▪ Woodside Avenue – From Magnolia Avenue to the Woodside Avenue north/south split; ▪ Magnolia Avenue – From Woodside Avenue to SR-52; and
▪ SR-67.

Based upon the FICON thresholds presented above, an increase of less than 5 dBA when the ambient sound level is less than 60 dBA Ldn/CNEL, less than 3 dBA when the ambient sound level is between 60 and 65 dBA Ldn/CNEL, or less than 1.5 dBA when the ambient sound level is greater than 65 dBA Ldn/CNEL would not be significant.

Utilizing the traffic noise modeling worksheets found in Appendix K, Table 4.10-6 shows that the highest predicted change in traffic noise level (the Project driveway) combined with the roadways surrounding the immediate Project site are predicted to experience an aggregate total traffic noise level of 85 dBA at 50 feet for the existing condition with a predicted increase of less than 1 dBA due to the Project contribution. Although the aggregate predicted “with Project construction traffic” condition is greater than the City limit as summarized in Section 4.10.2, the predicted “without Project construction traffic” level at the nearest sensitive receivers is also greater than the City limit, with a predicted “with Project” increase of less than 1 dBA, which is less than the FICON 1.5 dBA threshold when the ambient sound level is greater than 65 dBA Ldn/CNEL, and would be considered imperceptible to the average person. Additionally, although the increase in noise level for the Project driveway is greater than 5 dBA and therefore higher than the FICON thresholds and perceptible to the average person, there are no noise-sensitive receptors adjacent to the Project driveway; the nearest noise-sensitive receptors to the south of the Project are already dominated by much higher levels of traffic noise from nearby adjacent roadways such as SR-67. Therefore, potential impacts at existing off-site noise-sensitive land uses along roadway segments identified in Table 4.10-6 and with respect to Project-generated temporary construction traffic to existing traffic noise would be less than significant.

Table 4.10-6. Predicted Construction Traffic Noise Levels Modeled
Roadway
Segment From To
Existing
(dBA CNEL)
Existing Plus
Project
Construction
Traffic (dBA
CNEL)
Delta
(dBA)
Project Driveway N. Woodside
Avenue Project 50.38 60.26 9.88
Wheatlands
Avenue
N. Woodside
Avenue
Wheatlands Road 61.82 63.93 2.11
N. Woodside
Avenue
Wheatlands
Avenue
Woodside Avenue -
Combined

67.76 68.70 0.95
Woodside
Avenue
Magnolia Avenue Woodside Avenue -
Combined

77.40 77.54 0.14
Magnolia Avenue Woodside Avenue SR-52 77.15 77.27 0.12
SR-67 83.50 83.55 0.05
Aggregate Total @ 50 Feet 85.29 85.41 0.12
Project Driveway, Wheatlands Avenue, SR-67 Segment Aggregate Total @ 50 Feet

83.64 83.76 0.11

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-18
Best Practices for Limiting Construction Noise
Despite the construction noise analysis above showing that the impact to noise-sensitive receivers would be less than significant, the following is a list of best practices for limiting construction noise that should be implemented by the contractor:
▪ The Project contractor shall, to the extent feasible, schedule construction activities to avoid concurrent operation of several pieces of construction equipment proximate to an offsite noise-sensitive receptor. ▪ All construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers.
▪ Construction noise reduction methods such as shutting off idling equipment, maximizing the distance between construction equipment staging areas and adjacent residences, and use of electric air compressors and similar power tools, rather than diesel equipment, shall be used where feasible. ▪ Construction hours, allowable workdays, and the phone number of the job superintendent shall be clearly posted at all construction entrances to allow surrounding property owners to contact the job superintendent if necessary. In the event the City receives a complaint, appropriate corrective actions shall be implemented, and a report of the action provided to the reporting party.

Long-Term Operational Impacts
Off-Site Traffic Noise Exposure
Less-than-Significant Impact. The project is expected to generate an additional 1,440 average daily trips to the roadway system, as shown in Table 4.12-1 within Section 4.12, Transportation. During the afternoon (PM) peakhour (the highest of the AM and PM peak hours), approximately 148 passenger car equivalent vehicles are estimated to enter or exit the Project site. Utilizing this information as well as additional traffic data provided in Appendix K, the Federal Highway Administration’s Highway Traffic Noise Prediction Model RD-77-108 was used to estimate potential noise impacts at adjacent noise-sensitive uses. Information used in the model included Average Daily Traffic (ADT), posted traffic speeds, truck mix percentage, and day/evening/night mix percentage.

Consistent with Caltrans guidance (Caltrans 2013), this analysis assumes 80% of the ADT occurs during daytime hours (7:00 a.m. to 7:00 p.m.), 5% during the evening (7:00 p.m. to 10:00 p.m.), and 15% during the nighttime (10:00 p.m. to 7:00 a.m.). The future modeled traffic speed was assumed to be the anticipated speed limit for the studied future roads, which is 45 miles per hour (mph) for Woodside Avenue, 40 mph for N. Woodside Avenue and Magnolia Avenue, and 25 mph for Wheatlands Avenue and the Project driveway. The truck percentages used in the noise model were 4.6% medium trucks and 22.9% heavy trucks. This truck mix is based on the Project trip truck percentages from Table 4.12-1 within Section 4.12, Transportation, of this Draft EIR.

The change in roadway noise levels was predicted for two conditions: existing, near-term, and horizon year 2035 plus Project. Traffic noise levels were calculated for roadway segments bounded by intersections within the Project area and are listed as follows:
▪ Project Driveway – From N. Woodside Avenue to the Project; ▪ Wheatlands Avenue – From N. Woodside Avenue to Wheatlands Road; ▪ N. Woodside Avenue – From Wheatlands Avenue to Woodside Avenue (combined north/south split); ▪ Woodside Avenue – From Magnolia Avenue to the Woodside Avenue north/south split;

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-19
▪ Magnolia Avenue – From Woodside Avenue to SR-52; and
▪ SR-67 (project trip traffic was not available for this roadway).

Based upon the FICON thresholds presented in Section 4.10.2 above, an increase of less than 5 dBA when the ambient sound level is less than 60 dBA Ldn/CNEL, less than 3 dBA when the ambient sound level is between 60 and 65 dBA Ldn/CNEL, or less than 1.5 dBA when the ambient sound level is greater than 65 dBA Ldn/CNEL would not be significant. Utilizing the traffic noise modeling worksheets found in Appendix K, Table 4.10-7 shows that the highest predicted change in traffic noise level (the Project driveway) combined with the roadways surrounding the immediate Project site are predicted to experience an aggregate total traffic noise level of 84 dBA at 50 feet for the horizon year 2035 condition with a predicted increase of less than 1 dBA due to the Project contribution. Although the aggregate predicted “with Project” condition is greater than the City limit as summarized in Section 4.10.2, the predicted “without Project” level at the nearest sensitive receivers is also greater than the City limit, with a predicted “with Project” increase of less than 1 dBA, which is less than the FICON 1.5 dBA threshold when the ambient sound level is greater than 65 dBA Ldn/CNEL, and would be considered imperceptible to the average person. Additionally, although the increase in noise level for the Project driveway is greater than 5 dBA and therefore higher than the FICON thresholds and perceptible to the average person, there are no noise-sensitive receptors adjacent to the Project driveway; the nearest noise-sensitive receptors to the south of the Project are already dominated by much higher levels of traffic noise from nearby adjacent roadways such as SR-67, while noise-sensitive receptors to the north of the Project are occluded from the Project driveway by intervening buildings and terrain. Therefore, potential impacts at existing off-site noise-sensitive land uses along roadway segments identified in Table 4.10-7 and with respect to Project-generated changes to future traffic noise would be less than significant.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-20
Table 4.10-7. Predicted Traffic Noise Levels
Modeled
Roadway
Segment From To
Existing
(dBA
CNEL)
Existing
Plus
Project
(dBA
CNEL)
Delta
(dBA)
NearTerm
(dBA
CNEL)
NearTerm
Plus
Project
(dBA
CNEL)
Delta
(dBA)
Horizon
2035
(dBA
CNEL)
Horizon
2035
Plus
Project
(dBA
CNEL)
Delta
(dBA)
Project
Driveway
N. Woodside
Avenue Project 50.38 61.62 11.24 50.38 61.62 11.24 50.38 61.62 11.24 Wheatlands
Avenue
N. Woodside
Avenue
Wheatlands
Road

61.82 61.82 0.00 61.82 61.82 0.00 67.10 67.10 0.00
N. Woodside
Avenue
Wheatlands
Avenue
Woodside
Avenue -
Combined

67.76 69.05 1.29 68.46 69.58 1.12 73.19 73.33 0.14
Woodside
Avenue
Magnolia
Avenue
Woodside
Avenue -
Combined

77.4 77.60 0.20 77.50 77.70 0.20 78.70 78.75 0.05
Magnolia
Avenue
Woodside
Avenue
SR-52 77.15 77.27 0.12 77.34 77.46 0.12 77.72 77.76 0.04 SR-67 83.50 82.5 0.00 84.15 84.15 0.00 84.39 84.39 0.00 Aggregate Total @ 50 Feet 85.29 85.39 0.10 85.79 85.87 0.09 86.38 86.41 0.03 Project Driveway, Wheatlands Avenue, SR-67
Segment Aggregate Total @ 50 Feet

83.64 83.71 0.06 84.29 84.35 0.05 84.78 84.81 0.03
Source: Appendix K.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-21
Project Sound Sources
On-site Outdoor Mechanical Equipment
The completion of the building will add a variety of noise-producing mechanical equipment that are presented and discussed in the following paragraphs. Most of the noise-producing equipment or sound sources would be considered stationary or limited in mobility to a defined area.

Methodology and Parameters
The aggregate noise emission from these outdoor-exposed sound sources has been calculated with the Datakustik CadnaA sound propagation program. CadnaA is a commercially available software program for the calculation, presentation, assessment, and prediction of environmental noise based on algorithms and reference data per International Organization of Standardization (ISO) Standard 9613-2, “Attenuation of Sound During Propagation Outdoors, Part 2: General Method of Calculation” (ISO 1996). The CadnaA computer software allows one to position sources of sound emission in a simulated 3D space having heights and footprints consistent with project architectural plans and elevations. In addition to the above-mentioned sound source inputs and building-block structures that define the three-dimensional sound propagation model space, the following assumptions and parameters are included in this CadnaA-supported stationary noise source assessment:
▪ Ground effect acoustical absorption coefficient equal to 0.5, which intends to represent an average or blending of ground covers that are characterized largely by hard reflective pavements and existing building surfaces across the project site and the surroundings;
▪ Reflection order of 1, which allows for a single reflection of sound paths on encountered structural surfaces such as the modeled building masses;
▪ Off-site residential structures and buildings have not been rendered in the model; ▪ An eight-foot-tall, 568-foot-long overlapped barrier was modeled on the northern perimeter of the project site (PDF-NOI-1);
▪ Calm meteorological conditions (i.e., no wind) with 68 degrees Fahrenheit and 50% relative humidity; and ▪ All of the modeled noise sources are operating concurrently and continuously for a minimum period of 1 hour.

Based on the available plans and other design information, the proposed Project building would be served by roofmounted air-conditioning equipment that includes outdoor-exposed packaged air-handling units and air-cooled condensers that provide the expected cooling demand (expressed as refrigeration “tonnage”) for a building. The following are descriptions of modeled sound sources, with Table 4.10-8 exhibiting modeled sound power level data at octave-band center frequency (OBCF) resolution. Detailed information supporting these summary descriptions and quantities appear in Appendix K.

Table 4.10-8. Modeled Sound Power Levels (PWL) for Stationary Sources (HVAC) Building Sound Source
Overall
Leq
(dBA)
A-Weighted dB at Octave Band Center Frequency (OBCF, Hz)

32.5 63 125 250 500 1000 2000 4000 8000
1 Air Handling 93 74 74 86 87 88 85 78 72 67
Air Conditioning 98 74 74 81 88 92 91 91 89 80

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-22
The HVAC reference sound levels were calculated from a combination of inputs that include square footage values for the proposed Project’s proposed office spaces, Project applicant response to data requests, and manufacturer sound power level data. For the analysis of noise from HVAC equipment operation, eight air conditioning units were modeled on the roofs of the project building.

Other Stationary Noise Sources
The proposed Project building may feature other noise emitters, but their contributions would tend to be sporadic or otherwise occur infrequently and thus be expected to have no greater acoustic contribution to an hourly Leq than the continuous-type HVAC noise studied herein.

Loading Dock Noise Sources
The proposed Project building also features loading dock areas for the loading and unloading of heavy trucks. Onsite loading dock noise was calculated for a single heavy truck pass by (Salter 2014) and extrapolated based upon the number of heavy trucks entering or exiting the facility during the peak hour. Backup alarms are also included in the truck noise level calculations. Loading dock data were subsequently entered into the CadnaA model for the prediction of stationary operations noise levels. Detailed information supporting the calculation of daytime and nighttime loading dock noise be found in Appendix K.

Modeling Results
An operational scenario of the proposed Project was modeled that assumes all the HVAC equipment is operating simultaneously for a minimum period of one hour along with peak hour truck movements in the loading dock areas.

Figure 4.10-3, Predicted Daytime Onsite Operations Noise Contours, displays the predicted noise contours associated with aggregate sound propagation from operating HVAC and peak daytime loading dock sound sources.

An additional operational scenario of the proposed Project was modeled to predict a hypothetical nighttime scenario, where all the HVAC equipment is operating simultaneously for a minimum period of one hour, but the peak hour truck movement is reduced to 25% of the peak for each docking area. Figure 4.10-4, Predicted Nighttime Onsite Operations Noise Contours, displays the predicted noise contours associated with aggregate sound propagation from operating HVAC and nighttime loading dock sound sources.

Figures 4.10-3 and 4.10-4 illustrate predicted aggregate SPL propagation solely from operation of the proposed Project stationary sound sources as described herein. The color-coded annular bands of SPL are calculated across a field parallel with and five (5) feet above local grade.

Based on the noise level contours appearing in Figures 4.10-3 and 4.10-4, the proposed Project is predicted to be up to 67 dBA Leq in the daytime and 60 dBA Leq in the nighttime for a calculated Ldn of 68 dBA at the adjacent industrial land uses and is therefore expected to be lower than and thus comply with the City’s 75 dBA Ldn threshold for industrial land uses. Further, the proposed Project is predicted to be up to 40 dBA Leq in the daytime and 35 dBA Leq in the nighttime for a calculated Ldn of 43 dBA at the noise-sensitive receptors to the north of the Project site and up to 43 dBA Leq in the daytime and 38 dBA Leq in the nighttime for a calculated Ldn of 46 dBA at the noisesensitive receptors to the south of the Project site, both of which are therefore predicted to be lower than and thus comply with the City’s 65 dBA Ldn threshold for residential land uses. Throughout operation of the Project, all activities shall adhere to Sections 5.04-130 and 5.04.160 of the City’s municipal code which limits nighttime noise. 0 #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! 1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
29 30
31 32
33 34
35 36
37 38
39 40
41 42
43 44
45 46
47 48
49 50
51 52
53 54
55 56
57 58
59 60
61 62
63 64
65 66
67 68
69 70
71 72
73 74
75 76
77 78
79 80
81 82
83 84
85 86
87 88
89 90
91 92
93 94
95 96
97 98
99 100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
SOURCE: Microsoft 2024; Dudek 2024
300 feet
Project
Building
Truck
Route
8'
Barrier
Truck
Route 55 dBA
A-weighted
Project
Operations
Sound Pressure
Level (SPL)

30.0 dB
FIGURE 4.10-3
Predicted Daytime Onsite Operations Noise Contours (Leq) Palisade Santee Commerce Center Project

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-24

INTENTIONALLY LEFT BLANK
0 #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! #REF! 1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
29 30
31 32
33 34
35 36
37 38
39 40
41 42
43 44
45 46
47 48
49 50
51 52
53 54
55 56
57 58
59 60
61 62
63 64
65 66
67 68
69 70
71 72
73 74
75 76
77 78
79 80
81 82
83 84
85 86
87 88
89 90
91 92
93 94
95 96
97 98
99 100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
SOURCE: Microsoft 2024; Dudek 2024
300 feet
A-weighted
Project
Operations
Sound Pressure
Level (SPL)

30.0 dB
35 dBA
Project
Building
Truck
Route
8'
Barrier
Truck
Route 50 dBA
FIGURE 4.10-4
Predicted Nighttime Onsite Operations Noise Contours (Leq) Palisade Santee Commerce Center Project

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-26

INTENTIONALLY LEFT BLANK

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-27
On-site Parking Activity
Less-than-Significant Impact. A comprehensive study of noise levels associated with surface parking lots was published in the Journal of Environmental Engineering and Landscape Management (Baltrënas et al. 2004). The study found that average noise levels for parking lots of similar size during the peak period of use of the parking lot (generally in the morning with arrival of commuters, and in the evening with the departure of commuters), was 47 dBA Leq at 1 meter (3.28 feet) from the outside boundary of the parking lot. The parking areas would function as point sources for noise, which means that noise would attenuate at a rate of 6 dBA with each doubling of distance.

Employee parking spaces are proposed to be distributed throughout the Project site adjacent to the warehouse/office building, no closer than 700 feet from the edge of the closest parking space to the nearest residences to the north. At a distance of 700 feet, parking space noise levels would not be audible to the human ear at the nearest residences. The combination of the parking space noise (<2 dBA Leq) and the predicted stationary operation level (43 dBA Leq at the nearest receptor) would be 43 dBA Leq1, which would be well below the applicable limits (i.e. 65 dBA Ldn for residential receptors). Therefore, impacts associated with parking noise would be less than significant.

B. Would the Project result in generation of excessive groundborne vibration or groundborne noise levels? Less-than-Significant Impact. Construction activities may expose persons to excessive groundborne vibration or groundborne noise, causing a potentially significant impact. Caltrans has collected groundborne vibration information related to construction activities (Caltrans 2020). Information from Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips are considered annoying. For context, heavier pieces of construction equipment, such as a bulldozer that may be expected on the Project site, have peak particle velocities of approximately 0.089 ips or less at a reference distance of 25 feet.

Groundborne vibration attenuates rapidly, even over short distances. The attenuation of groundborne vibration as it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions found in FTA and Caltrans guidance. By way of example, for a bulldozer operating on-site and as close as the northern Project boundary (i.e., 310 feet from the nearest occupied property), the estimated vibration velocity would be 0.0006 ips per the equation as follows (FTA 2018):

PPVrcvr = PPVref * (25/D)1.5 = 0.002 = 0.089 * (25/310)1.5 In the above equation, PPVrcvr is the predicted vibration velocity at the receiver position, PPVref is the reference value at 25 feet from the vibration source (the bulldozer), and D is the actual horizontal distance to the receiver. Therefore, at this predicted PPV, the impact of vibration-induced annoyance to occupants of nearby existing homes would be less than significant.

Construction vibration, at sufficiently high levels, can also present a building damage risk. However, anticipated construction vibration associated with the proposed project would yield a maximum amplitude of 0.002 ips, which does not surpass the guidance limit of 0.2 to 0.3 ips PPV for preventing damage to residential structures (Caltrans 2020). Because the predicted vibration level at 310 feet is less than this guidance limit, the risk of vibration damage to nearby structures is considered less than significant. 1 Because noise levels are summed in the energy (that is, the logarithmic) domain, a noise level that is 10 decibels or more lower than another noise level becomes negligible, because the sound energy from the higher noise source is completely dominant.

4.10 – NOISE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.10-28
Once operational, the proposed Project would not be expected to feature major producers of groundborne vibration.

Anticipated mechanical systems like heating, ventilation, and air-conditioning units are designed and manufactured to feature rotating (fans, motors) and reciprocating (compressors) components that are well-balanced with isolated vibration within or external to the equipment casings. On this basis, potential vibration impacts due to proposed Project operation would be less than significant.

C. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the Project expose people residing or working in the Project area to excessive noise levels.

Less-than-Significant Impact. There are no private airstrips within the vicinity of the Project site. The closest airport to the proposed Project site is the Gillespie Field regional airport, approximately 1.5 miles west of the Project boundary. According to the Gillespie Field Community Relations Traffic Pattern Review Appendix C: Noise Analysis, the Project site falls outside the studied noise contours. Impacts would be less than significant.

4.10.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to noise and vibration would be less than significant. No mitigation is required.

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-1

4.11 Public Services
This section describes the existing public services conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to the implementation of the Project.

4.11.1 Existing Conditions
Fire Protection and Emergency Medical Services
Fire prevention, suppression, inspection, rescue, and emergency medical services for the Project site and Santee are provided by the Santee Fire Department (SFD). In addition, the City contracts with San Diego County, State of California Master Mutual Aid Agreements, and California Department of Forestry and U.S. Forest Service (CAL FIRE) to provide a full range of fire protection services.

The Santee-Lakeside Emergency Medical Services Authority (SLEMSA) is a Joint Exercise of Powers Agreement between the City of Santee, a California charter city and municipal corporation, and Lakeside Fire Protection District (City of Santee 2023). If needed, fire stations within the Lakeside Fire Protection District may respond to emergency calls in Santee. Numerous other local, state, and federal agencies are available to assist the SFD as needed, depending on the type of incident. Emergency response in every jurisdiction in the State of California is handled in accordance with the Statewide Emergency Management System (SEMS) that requires the City to routinely update its emergency operations plan to maintain compliance (City of Santee 2003).

Effective fire response and suppression relies on the ability to meet peak load water supply and pressure. The City requires all new development to install adequate water conveyance facilities to meet this requirement to ensure adequate fire suppression capabilities. The City is served by the Padre Dam Municipal Water District (PDMWD) who is able to provide water services to the proposed Project and existing customers in the City (City of Santee 2023).

As listed in Table 4.11-1, the SFD operates two fire stations within the City, with the closest being Station No. 4 (8950 Cottonwood Avenue), located approximately 1.5 miles northwest of the Project site (City of Santee 2023).

Station No. 4 operates one battalion chief’s vehicle and four response units: one fire engine, one fire truck, one brush engine, and one paramedic ambulance. In addition, the station houses two reserve fire engines and two reserve ambulances. Daily staffing consists of a minimum of nine personnel including two captains, two engineers, four firefighter-paramedics, and one battalion chief.

Table 4.11-1. Fire Stations in City of Santee
Fire Station No. Address Distance to Project Site (approx.) Station No. 4 8950 Cottonwood Avenue 1.5 miles
Station No. 5 9130 Carlton Oaks Drive 4.6 miles
Note: See Figure 4.11-1, Fire Stations in the City of Santee. Distances were calculated using roadway miles.

SFD has achieved a Class 1 Public Protection Classification rating, or Insurance Services Office Rating. In 2019, the City’s Fire and Life Safety Department documented 5,791 total incidents (City of Santee 2022). According to the City’s General Plan SFD aims to provide an average maximum initial response time of no more than 6 minutes for fire, rescue and emergency medical services with an average maximum response time of no more than 10

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-2
minutes for supporting paramedic transport units, 90 percent of the time (City of Santee 2003). The average SFD response times (from unit notification until unit arrives on scene, averaged) for emergency and non-emergency calls are 6 minutes and 18 seconds for fire and explosions; 5 minutes and 43 seconds for rescue and emergency medical; and 6 minutes and 40 seconds for service and non-emergency calls (City of Santee 2022).

Police Protection
The City is patrolled by the Santee Sheriff which is under the San Diego County Sheriff’s Department. The Santee Sheriff serves a population of approximately 59,000 people in the area of 16- square miles. The Santee Sheriff Station is located at 8811 Cuyamaca Street, approximately 2.1-miles southwest of the Project site (SDCSD 2024).

In 2023, the Santee Sheriff received 13,837 calls for service (SDCSD 2023). Generally, the Santee Sheriff has quicker response times to emergency calls than the County average. The average priority call response time for general crimes within the City is 8.2 minutes and the average for traffic law is 7.5 minutes.

With over 60 employees, the Santee Sheriff provides a full range of law enforcement services including patrol, traffic, investigations, parking enforcement, emergency services, crime prevention programs, crime analysis, and narcotics enforcement (SDCSD 2024). The Patrol Division is under the command of the Patrol Captain and is responsible for responding to all calls for service within the community. This task is accomplished by having a centralized location answering point for all 911 calls as well as all non-emergency sheriff department calls. The Traffic Division is responsible for enforcing vehicle codes, as well as traffic control as well as handling most accidents. The California Highway Patrol is responsible for traffic enforcement in the unincorporated areas. The Detective’s Division is responsible for investigating theft cases, physical assaults (excluding homicides), sexual assaults, vandalism, burglaries, annoying phone calls, and other crimes. The Crime Prevention Division provide the Santee Station with information and presentations regarding safety and crime preventions. In addition, the Community Oriented Policing and Problem Solving (COPPS) / School Resources Officers, including the Senior Volunteers Division are responsible for the investigating the quality-of-life issues within the community (SDCSD 2024).

Schools
There are two school districts that provide public education throughout the City, the Santee School District (SSD) for kindergarten through 8th grades and the Grossmont Union High School District (GUHSD) for 9th through 12th grades. Nearby there are two higher education facilities, which are San Diego State University and Grossmont Community College. The Project site is located within the boundary of the SSD and the GUHSD (SSD 2023; GUHSD 2024). The school closest to the Project is Hill Creek School, which serves sixth grade through eighth-grade students and is located approximately 0.22-miles northwest of the Project site (SSD 2023).

Parks
The City of Santee Parks and Recreation Department has ten park facilities within the City that are available to the residents. These include Mast, Woodglen Vista, Shadow Hill, Town Center Community Park- East, Town Center Community Park – West, Sky Ranch, Big Rock, Deputy Ken Collier Neighborhood, Weston, and West Hills parks. The City parks also includes the Santee Sportsplex USA, a field complex that hosts regional and national sports tournaments such as softball, baseball, and soccer. Of these, Shadow Hill Park (9161 Shadow Hill Road) is the closest park to the Project site which is located approximately 1.1 miles south of the Project site. Most City parks consist of picnic shelters, a playground area, walking paths, grass area, restrooms, and ample parking spaces (City of Santee 2023).

Date: 1/23/2024 - Last saved by: mmcginnis - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Figure4_11_1_FireStations.mxd Navajo Rd
Fletcher Pkwy
Mission Gorge Rd
Broadway
Ballantyne St
N
Cuyamaca St
Lake Murray Blvd
N
Magnolia Ave
Mast Blvd Woodside Ave
Fanita Dr
Prospect Ave
Weld Blvd
Riverside Dr
N 2ndSt
El Nopal
Ha lberns Blvd
N Mollison Ave
E Bradley Ave
Gr oss mont C ollegeDr
Greenfield Dr
N Johnson Ave
GolfcrestDr
Graves Ave
Pepper Dr
N MarshallAve
Oli ve Ln
Mesa Rd
Cuyamaca St
Carlton Oaks Dr
LakeCanyon Rd
Fanita Pkwy
W Bradley Ave
H acienda
Dr
Cowles Mountain Blvd
N Woodside Ave
125
67 52
8 SOURCE: SANGIS 2022
0 2,800 1,400 Feet
Fire Stations
Project Boundary
City of Santee
FIGURE 4.11-1
Fire Stations in the City of Santee
Palisade Santee Commerce Center Project

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-4

INTENTIONALLY LEFT BLANK

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-5
Other Public Facilities
Libraries
The San Diego County Library System serves all of the San Diego County and the City of Santee. The closest library branch to the Project is the Santee Public Library located at 9225 Carlton Hills Blvd #107 (San Diego County Library System), approximately 3.1 miles west of the Project site.

4.11.2 Relevant Plans, Policies, and Ordinances
The following regulatory framework discussion focuses on state and local regulations because there are no relevant public services-related federal laws.

State
California Occupational Safety and Health Administration In accordance with California Code of Regulations Title 8 Sections 1270 “Fire Prevention” and 6773 “Fire Protection and Fire Equipment”, the California Occupational Safety and Health Administration (Cal/OSHA) has established minimum standards for fire suppression and emergency medical services. The standards include, but are not limited to, guidelines on the handling of highly combustible materials, fire hose sizing requirements, restrictions on the use of compressed air, access roads, and the testing, maintenance and use of all firefighting and emergency medical equipment.

California Fire Code
California Code of Regulations (CCR), Title 24, Part 9, incorporates adoption of the 2015 International Fire Code of the International Code Council with necessary California amendments. The California Fire Code and Office of the State Fire Marshal provides regulations and guidance for local agencies in the development and enforcement of fire safety standards. The California Fire Code also establishes minimum requirements that would provide a reasonable degree of safety from fire, panic, and explosion. The California Fire Code applies to construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal, and demolition of every building or structure within the State of California. The California Fire Code includes a mandate for automatic sprinkler systems in new buildings and structures, including floors of buildings where the fire area exceeds 5,000 square feet, has an occupant load of 100 or more, or is located on a floor other than the level of exit discharge1 (Cal. Code Regs. tit. 24 Part 9). Part 2 of Title 24 of the CCR refers to the California Building Code, which contains complete regulations and general construction building standards of state adopting agencies, including administrative, fire and life safety, and field inspection provisions. Part 2 was updated in 2019 to reflect changes in the base document from the Uniform Building Code to the International Building Code.

California Government Code 66000
According to California Government Code 66000, a qualified agency, such as a local school district, may impose fees on developers to compensate for the impact that the project will have on existing facilities or services. The State of California legislature passed SB 50 in 1998 that inserted new language into the Government Code 1 Exit discharge refers to the part of the exit route that leads directly outside.

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-6
(Sections 65995.5-65995.7), which authorized school districts to impose fees on developers of new residential construction in excess of mitigation fees authorized by Government Code 66000. School districts must meet a list of specific criteria, including the completion and annual update of School Facility Needs Analysis, in order to be legally able to impose the additional fees.

Local
The following local regulations pertaining to public services would apply to the Project.

City of Santee General Plan
Public services are protected through policies in the City’s General Plan Land Use, Conservation, and Safety Elements. The goals and policies in the City’s General Plan for public services applicable to the Project are provided below. The General Plan contains additional goals and policies that are more general in nature and not specific to development such as the Project. Therefore, they are not listed below, but as stated in Chapter 2, Introduction, all goals and policies in the City’s General Plan are incorporated by reference.

Land Use Element
Objective 3.0 Provide and maintain the highest level of service possible for all community public services and facilities.

Safety Element
Objective-4.0 Minimize injuries, loss of life and property damage resulting from fire hazards.

Policy 4.1 Proposed development should be approved only after it is determined that there will be adequate water pressure to maintain the required fire flow at the time of development.

Policy 4.2 The City should ensure that all new development meets established response time standards for fire and life safety services.

Policy 4.8 Encourage and support the delivery of a high level of emergency services through cooperation with other agencies and use of available financial opportunities.

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-7
Policy4.10 Encourage the continued development, implementation, and public awareness of fire prevention programs.

Policy4.11 Police and Fire Department Review In order to minimize fire hazards, the Santee Fire and Life Safety Department shall routinely be involved in the review of development applications.

Considerations shall be given to adequate emergency access, driveway widths, turning radii, fire hydrant locations and needed fire flow requirements.

Policy 4.12 The timing of additional fire station construction or renovation, or new services shall relate to the rise of service demand in the City and surrounding areas.

Policy 4.13 Support mutual aid agreements and communications links with County and the other municipalities participating in the Unified San Diego County Emergency Service Organization.

Objective 5.0 Minimize injuries, loss of life and property damage and losses from criminal activities.

Policy 5.4 The City shall involve law enforcement personnel in the review of new development applications through participation in the development review process.

Policy 5.5 All structures shall be adequately identified by street address and be lighted sufficiently to deter criminal activity.

City of Santee Municipal Code
Chapter 11.18 of the Santee Municipal Code adopts the 2019 California Fire Code, Part 9, Title 24, of the California Code of Regulations. The code includes but is not limited to regulations requiring all new development to install sprinkler systems; the minimum required unobstructed street widths for fire apparatus access; and requirements, which include preparation of a fire protection plan, for development in wildland-urban interface areas.

Chapter 12.30 (Development Impact Fee) of the Municipal Code imposes development fees on all new projects and is collected at the time of issuance of building permits by the City. The charges imposed by this regulation serves as a means to finance fire, police, library, parks and other services. As such, the proposed Project would be required to comply with this regulation.

4.11.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to public services and recreation are based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact would occur if the Project would:

Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a. Fire protection.
b. Police protection.

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-8
c. Schools.
d. Parks.
e. Other public facilities.

4.11.4 Impacts Analysis
A. Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
i. Fire protection?
Less-than-Significant Impact. Fire protection requirements are based on the number of residents and workers in the SFD service areas. Service demand is primarily tied to population, not building size, because emergency medical calls typically make up the majority of responses provided by the SFD. As the number of residents and workers increases, so does the number of emergency medical calls. The proposed Project is a light industrial development.

Therefore, employees would occupy the Project site full-time during Project operation and there would be an increase in demand for fire protection services.

Service demands during Project construction activities could increase. However, the presence of construction workers on site would be temporary and would cease after construction of the Project is complete. It would therefore not substantially increase the service demand for fire protection services in the City.

In addition, the proposed Project would be designed and constructed in accordance with all applicable provisions of the California Fire Code, which includes requirements for adequate fire flows, width of emergency access routes, turning radii for equipment, automatic sprinkler systems, fire alarms, and floor to sky height limits along emergency access routes. As part of the standard development practices, Project plans would be reviewed by the City and Fire Department, prior to construction. Compliance with fire code standards would reduce the potential demand for fire services by decreasing the likelihood and/or severity of a fire emergency at the site.

As previously discussed, the nearest fire station to the Project site is Fire Station No. 4 (8950 Cottonwood Avenue), located approximately 1.5 miles northwest. The SFD’s response times vary within the City, with the current goal being able to provide an average maximum initial response time of no more than six minutes, with an average maximum response time of no more than ten minutes for supporting paramedic transport units 90% of the time (City of Santee 2003). In the event that Fire Station No. 4 could not meet the immediate needs of a call for services independently or does not have capability to address the full extent of a larger incident, the second closest station, Fire Station No. 5, is located approximately 4.6 miles from the Project site or other fire stations within the SanteeLakeside joint exercise of powers agreement as well as the County’s mutual aid agreement, as well as CAL FIRE, could respond or provide support (City of Santee 2023).

The proposed Project would be subject to the payment of a Development Impact Fees (DIF), per Chapter 12.30 (Development Impact Fees) of the City’s Municipal Code. This fee would be used for future facility improvements necessary to ensure that the development contributes its fair share of the cost of facilities and equipment determined to be necessary to adequately accommodate new development in the City. The DIF amount is determined through evaluation of the need for new public service facilities as it relates to the level of service

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-9
demanded by new development, which varies in proportion to specific land uses. A portion of the DIF would be used exclusively toward fire protection services.

In addition, the Safety Element of the General Plan contains several policies to ensure adequate fire protection is maintained. Policy 4.2 requires that all new development meets established response time standards for fire and life safety services, and Policy 4.12 requires the timing of additional fire station construction or renovation, or new services to be related to the rise of service demands. Policy 4.1 further states that proposed developments should be approved only after it is determined that there will be adequate water pressure to maintain the required fire flow at the time of development. Similarly, in effort to minimize fire hazards, Policy 4.11 allows for the SFD to be routinely involved in the review of development applications. The policy states that consideration shall be given to adequate emergency access, driveway widths, turning radii, fire hydrant locations and needed fire flow requirements. The proposed Project would be subject to all General Plan policies states herein, including SFD review of the Project’s development application.

Therefore, because the Project would be located within the SFD’s response area, with nearby services of Fire Station No. 5, as well as fire stations in neighboring jurisdictions, the Project would be served by sufficient fire protection services, and it is not anticipated that the Project would hinder the SFD from meeting its response time targets.

Furthermore, required payment of DIFs would ensure the Project contributes its fair share towards future facility improvements and equipment. The revenues and taxes generated from Project development would contribute to funding for facilities and services that have been identified by the SFD as needed for services in the future. Because the Project would not be anticipated to result in an increase to the City’s population and required payment of DIFs would ensure the Project contributes its fair share towards SFD facility improvements and equipment, the Project would not result in the need for new or expanded fire protection facilities, and impacts would be less than significant. ii. Police protection?
Less-than-Significant Impact. As described above in Section 4.11.1, Existing Conditions, police protection services are provided by the Santee Sheriff. The Santee Sheriff’s station is located at 8811 Cuyamaca Street, approximately

2.1 miles southwest of the Project site.

The Project site is located near the San Diego River and is surrounded by industrial development. The City has a low crime rate and the Project site is unlikely to attract attention that would make the Project susceptible to crime (SDCSD 2023).

Construction activities may temporarily increase traffic volumes along N. Woodside Avenue and other nearby roadways during the construction period. The added traffic associated with workers commuting to the Project site, haul routes, deliveries, and other Project-related activities may increase the need for law enforcement services during construction activities. During construction, it is anticipated temporary security measures including security fencing and lighting would be installed to deter criminal activity. However, construction would be temporary and would not have a significant adverse effect on the SDCSD’s ability to service the site.

As discussed in Chapter 5, Effects Found Not To Be Significant, the generation of 185 jobs would not significantly increase the population of the City or surrounding areas. While the Project would potentially result in a slight, incremental increase in calls to the SDCSD for service to the Project site in comparison to the existing conditions, this increase is expected to be nominal and would not result in the need for new SDCSD facilities. In addition, the Project site is already located within SDCSD’s service area and would not require an expansion of service area, which could otherwise result in longer response time. Overall, it is anticipated that the Project would be adequately

4.11 – PUBLIC SERVICES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.11-10
served by existing SDCSD facilities, equipment, and personnel. Nonetheless, similar to other development projects in the City, the Project applicant would still be required to pay their fair share of development impact fees to help offset incremental impacts to police protection services. Therefore, impacts associated with SDCSD facilities and response times would be less than significant.

Additionally, the proposed Project would be consistent with or would not hinder implementation of the City General Plan goals and policies pertaining to police protection services listed in Section 4.11.1, Existing Conditions. The project would comply with Safety Element Policy 4.2, which requires that all new development meet established response time standards for fire and life safety services, as well as Policy 5.4 which requires the involvement of law enforcement personnel in the review of new development applications through participation in the Development Review process. The proposed Project is not anticipated to adversely affect service ratios or response times for police services such that new or expanded police facilities would be required. Therefore, the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police facilities, or the need for new or physically altered police facilities; impacts would be less than significant. iii. Schools?
No Impact. The Project site is located within the SSD and the GUHSD (SSD 2023; GUHSD 2024). However, it is not anticipated that implementation of the Project would result in the relocation of a significant number of people to the City, and an increase in school-age children requiring public education is not expected to occur as a result of the Project (see Chapter 5, Effects Found Not To Be Significant). Nonetheless, all residential and non-residential development projects are subject to SB 50, which requires payment of mandatory impact fees to offset any impact to school services or facilities. The provisions of SB 50 are deemed to provide full and complete mitigation of school facilities impacts, notwithstanding any contrary provisions in CEQA or other state or local laws (Government Code Section 65996). In accordance with SB 50, the project applicant would pay its fair share of impacts fees based on the number/type of dwelling units. These impact fees are required of most residential, commercial, and industrial development projects in the City. Therefore, no impacts associated with school facilities would occur. iv. Parks?
No Impact. Given the nominal population growth that may result from Project implementation, neither construction nor operation of the Project would generate new residents to the extent that new or expanded park facilities would be required. Therefore, no impacts associated with park facilities would occur. v. Other public facilities?
No Impact. The Project would not directly or indirectly induce substantial population growth in the City. As such, it is unlikely that the Project would increase the use of other public facilities such as libraries. Therefore, no impacts associated with libraries and other public facilities would occur.

4.11.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to public services and recreation would be less than significant. No mitigation is required.

4.12 – TRANSPORTATION
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.12-1

4.12 Transportation
This section describes the existing transportation conditions of the Palisade Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential transportation impacts, and identifies mitigation measures, if necessary to reduce or avoid significant impacts, related to implementation of the Project.

In addition to the documents incorporated by reference (see Section 2.7, Documents Incorporated by Reference, of Chapter 2, Introduction, of this EIR), the following analysis is based, in part, on the following sources:
▪ Transportation Impact Study, prepared by Dudek in March 2025 (Appendix L) ▪ Other sources consulted are listed in Section 4.12.6, References.

4.12.1 Existing Conditions
Regional access to the Project site would be provided by SR-52 and SR-67. Local access to the Project site would be provided by Magnolia Avenue and Mission Gorge Road-Woodside Avenue. Both of these roadways are designated truck routes within the City.

Roadways
Characteristics of the adjacent existing street system roadways within the study area are described below.

Woodside Avenue
Woodside Avenue is an east-west roadway from Magnolia Avenue (where Mission Gorge Road ends) to Chestnut Street in Lakeside. Between Magnolia Avenue and SR-67 southbound-off ramp-Woodside Avenue intersection, Woodside Avenue is a Major Arterial, with four lanes and a center-two-way-left-turn lane (TWLTL). There are Class II bike lanes are provided on both sides of Woodside Avenue. The posted speed limit is 45 miles per hour (MPH).

Woodside Avenue splits into N. Woodside Avenue and Woodside Avenue east of the intersection with the SR-67 southbound off-ramp with N. Woodside Avenue paralleling SR-67 on the north side and Woodside Avenue paralleling SR-67 on the south side. N. Woodside Avenue is the segment between SR-67 southbound off-rampWoodside Avenue intersection to Riverford Road in the Lakeside community of San Diego County, and is designated as a Collector Road with a TWLTL. It is currently constructed with one lane in each direction with a center TWLTL and dedicated left-turn lanes at its intersections with Harley Road and Wheatlands Avenue. North of Wheatlands Avenue, the roadway is one lane in each direction without a TWLTL or dedicated left-turn lanes at intersections.

There are Class II bike lanes on both sides of the N. Woodside Avenue. On-street parking is permitted along north side of N. Woodside Avenue. There are intermittent sidewalks along the roadway. The posted speed limit in the vicinity of the Project is 40 MPH.

Magnolia Avenue
Magnolia Avenue is a north-south roadway. It is classified as a Major Arterial north of Mission Gorge Road and Prime Arterial from Mission Gorge Road to Prospect Avenue. On-street parking is not permitted along the roadway from Mission Gorge Road to Prospect Avenue. There is paved sidewalk along Magnolia Avenue. The posted speed limit along the roadway is 45 MPH.

4.12 – TRANSPORTATION
15138

4.12-2
Existing Public Transit Services
The San Diego Metropolitan Transit System (MTS) provides public transportation throughout Santee and northern San Diego County. Figure 4.12-1 illustrates the transit facilities in the vicinity of the proposed Project. The nearest MTS bus routes serving the Project are described below. ▪ Route 832 runs clockwise from Santee Town Center to northern Santee and back to Santee Town Center via Cuyamaca Street, and Magnolia Avenue. The route operates between 6:17am and 6:56pm on weekdays, with 30-minute headways, and between 8:25am and 4:45pm on weekends with 60-minute headways. The nearest bus stop is located west of the Magnolia Avenue and Mission Gorge Road – Woodside Avenue intersection, approximately 0.90 miles from the Project site. ▪ Route 833 runs from the Santee Transit Center to the El Cajon Transit Center, via Mission Gorge Road, Magnolia Avenue, and Graves Avenue. The route operates between 5:52am and 6:12pm on weekdays, with 45-minute headways, and between 8:53am and 5:10pm on weekends, with 60-minute headways. The nearest bus stop is located west of Magnolia Avenue and Mission Gorge Road – Woodside Avenue intersection, approximately 0.90 miles from the Project site. ▪ Route 834 runs in a loop, connecting the Santee Transit Center to the West Hills Parkway area, via Prospect Avenue and Carlton Oaks. The route operates only on weekdays from 6:33am to 3:30pm with 60-minuite headways. The nearest bus stop to the Project site is approximately 2 miles away.

The City of Santee is served by the Green Line Trolley (Route 530), with the sole station within the City located at the Santee Transit Center. The Green Line connects Santee to the larger San Diego region and provides service into Downtown San Diego. The route operates from 5:00am to 1:00am with 15-minute headways on weekdays, and 30-minute headways on weekends. MTS ACCESS provides complementary, on-demand paratransit service to fulfill the unmet needs of residents such as seniors and persons with disabilities.

Existing Pedestrian and Bicycle Facilities
The General Plan Circulation Element identifies the following bicycle facility classifications, as defined by Caltrans:
▪ Class I Bikeway (Bike Path) provide a completely separated right-of-way designated for the exclusive use of bicycles and pedestrians with crossflows by motor vehicles minimized. ▪ Class II Bikeway (Bike Lane) provides a striped lane designed for the exclusive or semi-exclusive use of bicycles with through travel by motor vehicles or pedestrians prohibited, but with pedestrian and motor vehicle crossflows permitted.
▪ Class III Bikeway (Bike Route) provides shared use of traffic lanes with cyclists and motor vehicles, identified by signage and street marking such as sharrows.
▪ Class IV Bikeway (Cycle Track) are separated bikeways that provide right-of-way designated exclusively for bicycle travel within the roadway and physically protected from vehicular traffic.

A Class II Bike Lane runs along Woodside Avenue; the bike lane along Woodside Avenue connects to bike route along Shadow Hill Road and Northcote Road, however, it does not connect to any other bicycle facility in the City.

The Planned Bicycle Network in the Mobility Element is based on Active Santee Plan (2021). It recommends Class II bike lanes along Mission Gorge Road between Riverview Parkway and Magnolia Avenue and along Magnolia Avenue between Mast Boulevard and Mission Gorge Road. Figure 4.12-2 illustrates the existing and proposed bike facilities near the Project.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
Cuyamaca St
Gillespie
Way
Cuyamaca St
San Diego River
N Magnolia Ave
Beck Dr
Cuyamaca St
Oak Creek Dr
Len St
Susie Pl
Carreta Dr
Pa ml Row Dr
Vista Camino
Woodglen Vista Dr
Woodpark Dr
2nd St
Northcote Rd
Ironwood Ave
N
M
a
g
n
olia
Av
e
Mast Blvd Mast Blvd Mast Blvd
Riverside Dr
Riverford Rd
El Nopal
San Vicente
Fwy
Town Center
Community Park
- East
Santana High
Santee
Buena Vista Ave
Kenney St
Vulcan St
Airport Dr
Mission Gorge Rd
N Magnolia Ave
Pepper Dr
Prospect Ave
C
uya
maca
St
San Vicente Fwy
San Vicente Fwy
State Route 52
Gillespie Field
Sky Ranch
Valle
Vista
Rd
Riverview
Ave
Willowbrook
Golf Course
Winter
Gardens
City of El Cajon
City of Santee
City of Santee
S a n D i e g o R i v e r
S a n
D i e g o R i v e r
Project Boundary
City Boundary
Trolley Stops
NCTD Bus Stops
San Diego MTS Route
832
833
834
Green Line Trolley Route
53 Transit Facilities
Palisade Santee Commerce Center Project
SOURCE: SanGIS 2019; Open Street Maps; SanGIS 2023
Date: 5/14/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Transportaion_figures.aprx 0 500 1,000 n Feet
FIGURE 4.12-1

4.12 – TRANSPORTATION
15138

4.12-4

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
City of El Cajon
City of Santee
City of Santee
S a n D iego River
San Di ego Riv e r
Project Boundary
City Boundary
Existing Bicycle Facilities
Class I Bike Path
Class II Bike Lane
Class III Bike Route
Proposed Bicycle Facilities
Class I Bike Path
Class II Bike Lane
Class III Bike Route
Class IV Cycle Tracks
Buffered Bike Lane
SOURCE: SanGIS 2019; Open Street Maps; SanGIS 2023; City of Santee 2017 Date: 9/29/2023 - Last saved by: kbarrow - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Transportation\Transportation_figures.aprx 0 1,000500
Feet
FIGURE 4.12-2
Bike Facilities
Palisade Santee Commerce Center Project

4.12 – TRANSPORTATION
15138

4.12-6

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-7
Sidewalks and pedestrian facilities are provided along one side of Woodside Avenue, and adjacent roadways within one-half mile of the Project site. While pedestrian facilities such are crosswalks are missing within the immediate Project area, the Santee Active Transportation Plan has identified this area as in need and is committed to improve the area by installing missing segments of sidewalks, adding pedestrian ramps and crosswalks, and relocating utility facilities as needed.

4.12.2 Relevant Plans, Policies, and Ordinances
State
California Department of Transportation
Caltrans is the primary state agency responsible for the state transportation system. One of its duties is the construction and maintenance of the state highway system. Caltrans has established standards for roadway traffic flow and has developed procedures to determine if intersections require improvements. For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. For projects that would not physically affect facilities but may influence traffic flow and Level of Service (LOS) at such facilities, Caltrans may recommend measures to mitigate the traffic impacts.

Caltrans Transportation Impact Study Guide, May 20, 2020, provides that Caltrans’ primary review focus is Vehicle Miles Traveled (VMT), replacing LOS as the metric used in CEQA transportation analyses (Caltrans 2020). Caltrans recommends use of OPR’s recommended thresholds and guidance on methods of VMT assessment found in OPR’s Technical Advisory (OPR 2018) for land use projects. In addition to VMT, the 2020 Transportation Impact Study Guide states that it may request a targeted operational and safety analysis to address a specific geometric or operational issue related to the state highway system and connections with the state highway system.

Assembly Bill 1358 – California Complete Streets Act of 2008 The California Complete Streets Act of 2008 (Assembly Bill 1358) requires circulation elements as of January 1, 2011 to accommodate the transportation system from a multi-modal perspective, including public transit, walking and biking, which have traditionally been marginalized in comparison to autos in contemporary American urban planning.

Senate Bill 743, California Environmental Quality Act Guidelines Update In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package, including Guidelines Section 15063.4, which implements SB 743. SB 743 required new metrics for analyzing transportation impacts under CEQA to provide an alternative to LOS. Measurements of transportation impacts may include VMT, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated. In most cases, a project’s effect on automobile delay will no longer constitute a significant environmental impact.1
The justification for this paradigm shift is that when significant impacts are identified under LOS and delay-based analyses, the mitigation is often to provide road improvements, which increase roadway capacity that inherently accommodates more vehicular traffic, resulting in additional greenhouse gas emissions. By contrast, under a VMT1 SB 743 also amends congestion management law to allow cities and counties to opt out of LOS standards within certain infill areas (OPR 2018).

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-8
based analysis, mitigation typically takes the form of strategies to reduce rather than accommodate traffic, thereby reducing vehicle emissions. Lead agencies were required to transition to the guidelines and establish VMT thresholds for transportation impacts no later than July 1, 2020. The City of Santee adopted its VMT Guidelines on April 27, 2022.

Local
SANDAG’s San Diego Forward: The Regional Plan
SANDAG’s San Diego Forward: The Regional Plan (Regional Plan) combines the region’s two most important existing planning documents—the Regional Comprehensive Plan and the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). The Regional Comprehensive Plan, adopted in 2004, laid out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covered eight policy areas, including urban form, transportation, housing, healthy environment, economic prosperity, public facilities, our borders, and social equity. These policy areas were addressed in the 2050 RTP/SCS and are now fully integrated into the Regional Plan.

The SANDAG Board of Directors adopted the 2021 Regional Plan on December 10, 2021. The 2021 Regional Plan is a 30-year plan that considers growth, movement, and residential location around the region. The 2021 Regional Plan combines the RTP/SCS and Regional Comprehensive Plan. As such, the 2021 Regional Plan must comply with specific state and federal mandates. These include an SCS, per California SB 375, that achieves greenhouse gas emissions reduction targets set by the California Air Resources Board, compliance with federal civil rights requirements (Title VI); environmental justice considerations; air quality conformity; and public participation (SANDAG 2021).

Congestion Management Program
The 2008 Congestion Management Program for San Diego County was developed to meet the requirements of Section 65089 of the California Government Code. Since that time, the local agencies within San Diego County elected to opt out of the Congestion Management Program requirements, as allowed within the Government Code.

As such, there are no Congestion Management Program-specific requirements associated with this Project.

However, to ensure the region’s continued compliance with the federal congestion management process, SANDAG has prepared The Regional Plan in compliance with Federal requirements to prepare a Regional Transportation Plan. The Regional Plan incorporates performance monitoring and measurement of the regional transportation system, multimodal alternatives to single-occupancy vehicles, land use impact analysis, congestion management tools, and Integration with the Regional Transportation Improvement Program process.

City of Santee General Plan Mobility Element
The goal of the mobility element is to create a balanced, interconnected multimodal transportation network that allows for the efficient and safe movement of all people and goods, and that supports the current and future needs of Santee community members and travel generated by planned land uses. The following are applicable objectives and goals stated in the Mobility Element:

Objective 1.0 Ensure that the existing and future transportation system is accessible, safe, reliable, efficient, integrated, convenient, well‐connected and multimodal. The system will accommodate active transportation, and accommodate people of all ages and abilities, including pedestrians, disabled,

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-9
bicyclists, users of mass transit, motorists, emergency responders, freight providers and adjacent land uses.

Policy 1.3 The City shall ensure that the entire right‐of‐way is designed to accommodate appropriate modes of transportation.

Objective 2.0 Develop an efficient, safe and multi-modal transportation network, consisting of local roads, collectors, arterials, freeways and transit services, in a manner that promotes the health and mobility of Santee residents and that meets future circulation needs, provides access to all sectors of the City, and supports established and planned land uses.

Policy 2.1 The City shall encourage an automobile Level of Service “D” on street segments and at intersections throughout the circulation network while also maintaining or improving the effectiveness of the non-automotive components of the circulation system (i.e. pedestrians, bicyclists, and public transit), especially in the Town Center area. The City may approve a lower automobile Level of Service if it finds that the effectiveness of non-automotive components of the circulation system would be maintained or improved as a result. In other cases, the City shall not approve any development that causes a drop in the level of service at a street segment or an intersection to LOS “E” or “F”, after feasible mitigation, without overriding social, economic, or other benefits.

Policy 2.3 The City shall establish minimum design standards for streets, which include grade, widths, alignment and public improvement requirements in a City design manual.

Policy 2.4 The City shall manage the existing truck route network for use by City serving heavy commercial and industrial traffic to provide for a safe circulation system for all drivers.

Policy 2.5 The City should not allow city streets to be used for through-City truck traffic.

Policy 2.6 The City should encourage traffic circulation improvements such as, but not limited to, enhanced roadway markings, synchronized traffic signals, and Intelligent Transportation System (ITS) network management.

Policy 2.7 The City should coordinate with Caltrans, SANDAG, MTS, and other responsible agencies to identify, plan, and implement needed transportation improvements.

Objective 3.0 Upgrade and maintain Santee transportation corridors to meet the safety needs of all roadway users – including youth and elderly and travelers of varying physical abilities – and to provide a well-connected system throughout the City.

Policy 3.1 The City shall encourage the development of improved signalization and intersection design while taking into consideration the safety of all modes.

Policy 3.2 The City should encourage the utilization of traffic control devices, such as center medians and/or left-turn pockets where appropriate and that do not conflict with safety, and discourage the installation of median cuts where traffic safety cannot be assured.

Policy 3.3 The City shall ensure that newly constructed roadways are designed to permit rapid access for emergency vehicles.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-10
Policy 3.4 The City shall provide adequate traffic control devices throughout the City to ensure safe and efficient mobility.

Policy 3.5: The City shall encourage the use of innovative methods for traffic control (such as roundabouts, curb extensions, and traffic circles) where appropriate that add character, slow vehicle speeds, and create opportunity for improved aesthetics while effectively managing traffic.

Objective 4.0 Maximize the utilization of site planning techniques to improve traffic safety.

Policy 4.3 The City shall promote design standards that allow for safe and efficient transport, delivery, loading and unloading of goods from service vehicles within commercial and industrial areas.

Policy 4.5 The City should establish and implement appropriate setback and off-street parking requirements.

Objective 7.0 Develop, maintain, and support a safe, comprehensive and integrated bikeway system that encourages bicycling, as documented in the City’s Bicycle Master Plan (BMP) Policy 7.4 The City should require new development and redevelopment to provide connections to existing and proposed bicycle routes, where appropriate.

Objective 8.0 Develop and maintain an accessible, safe, complete, and convenient pedestrian system that encourages walking.

Policy 8.1 The City should require the incorporation of pedestrian-friendly design concepts where feasible including separated sidewalks and bikeways, landscaped parkways, traffic calming measures, safe intersection designs and access to transit facilities and services into both public and private developments.

Policy 8.2 The City should provide for the connectivity of wide, well-lit sidewalks and environments with safety buffers between pedestrians and vehicular traffic, where feasible.

Policy 8.4 The City shall require non-contiguous sidewalks on all streets with a residential collector classification or higher, as appropriate.

Policy 8.6 The City should promote walking and improve the pedestrian experience by requiring pedestrian facilities along all classified streets designated on the Circulation Plan; by implementing streetscape improvements along pedestrian routes that incorporate such elements as shade trees, street furniture, and lighting; by orienting development towards the street; by employing traffic calming measures; and by enforcing vehicle speeds on both residential and arterial streets.

Policy 8.8 The City should improve pedestrian safety at intersections and mid-block crossings, where appropriate.

Objective 9.0 Increased use of alternative modes of travel to reduce peak hour vehicular trips, save energy, and improve air quality.

Policy 9.1 The City shall encourage and provide for Ride Sharing, Park ‘n Ride, and other similar commuter programs that eliminate vehicles from freeways and arterials.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-11
Policy 9.2 The City should encourage businesses to provide flexible work schedules for employees.

Policy 9.3 The City should encourage employers to offer shared commute programs and/or incentives for employees to use transit.

Policy 9.4 The City should encourage the use of alternative transportation modes, such as walking, cycling and public transit. The City should maintain and implement the policies and recommendations of the Bicycle Master Plan and Safe Routes to School Plan to improve safe bicycle and pedestrian access to major destinations.

4.12.3 Thresholds of Significance
The significance criteria used to evaluate the Project’s impacts to transportation are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to transportation would occur if the Project would:

Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Result in inadequate emergency access.

Methodology
In December 2018, the CEQA Guidelines were updated to include a threshold for evaluating traffic impacts using a VMT methodology. This new methodology was required to be used statewide beginning on July 1, 2020. This section summarizes the methodologies used to perform the VMT analysis. The methodologies described are consistent with OPR and City of Santee VMT Analysis Guidelines (April 13, 2022), Guidelines for Transportation Impact Studies in the San Diego Region (May 2019) and the City of Santee Mobility Element (October 2017).

Project Trip Generation
Trip generation represents the amount of traffic that is attracted and produced by a development and is based upon the specific land uses planned for a given project. Based on driveway traffic counts conducted and trip generation observed at three similar industrial land use site, (see Appendix A of Appendix L of this EIR), the City approved the use of the ITE trip generation rate for the Industrial Park use (ITE Code 130) to estimate the Project’s daily, AM peak hour, and PM peak hour trip generation. The ITE daily trip rate (3.37 trips/TSF) is higher than the first site (Site 1) which had the highest surveyed empirical rate (3.15 trips/TSF). Additionally, to provide a conservative estimate of truck trips, the warehouse truck fleet mix from the South Coast Air Quality Management District’s (SCAQMD) Warehouse Truck Trip Study Data Results and Usage (2014) was used to estimate Projectrelated truck traffic. Based on the SCAQMD data, passenger cars would account for 72.5% trips of the total trips generated by a warehouse facility, and truck trips would account for approximately 27.5% of the total trips. The ITE and SCAQMD trip generation data are widely used for other industrial projects in southern California.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-12
The total percentage of truck trips were further divided by 2-axle, 3-axle, and 4+ axle trucks per the SCAQMD study.

These truck trips generated by the Project are provided in passenger car equivalence (PCE) trips by using appropriate PCE factors. PCE factors consistent with the standard practice were used to estimate the total PCE trips for the Project.

Using the trip rate for an Industrial Park contained in the ITE Trip Generation Manual, the Project’s daily, AM peak hour, and PM peak hour trips were estimated. As shown in Table 4.12-1, the proposed Project would generate approximately 1,011 daily non-PCE trips, 102 AM peak hour trips (83 inbound and 19 outbound), and 103 PM peak hour trips (23 inbound and 80 outbound). Adjusting for PCE, the proposed Project would generate approximately 1,440 daily PCE trips, 148 AM PCE peak hour trips (121 inbound and 27 outbound), and 146 PM PCE peak hour trips (30 inbound and 116 outbound).

Table 4.12-1. Project Trip Generation Summary
Land Use Daily Trip Rate/Unit
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Trip Rates and Trip Generation
Industrial Park1 3.37 trips/TSF 0.28 0.06 0.34 0.07 0.27 0.34 Land Use Units Daily
Project (300.145 TSF) Total Trips (non-PCE) 1,011 83 19 102 23 80 103 Passenger Cars 733 60 14 74 16 58 74
Trucks (non-PCE) 278 24 5 29 6 23 29
Trip Generation (Non-PCE)
Vehicle Mix2 Passenger Cars (72.5%) 733 60 14 74 16 58 74 2-axle Trucks (4.6%) 46 4 1 5 1 4 5
3-axle Trucks (5.7%) 58 5 1 6 1 5 6
4+axle Trucks (17.2%) 174 15 3 18 4 14 18
Non - PCE Trips 1,011 83 19 102 23 80 103
Trip Generation (PCE)
PCE Factor3 and PCE
Trips
Passenger Cars (72.5%) 733 60 14 74 16 58 74
2-axle Trucks (4.6%) 70 6 1 7 1 6 7
3-axle Trucks (5.7%) 115 10 2 12 2 10 12
4+axle Trucks (17.2%) 522 45 9 54 11 42 53
PCE Trips 1,440 121 27 148 30 116 146
Notes: TSF = thousand square feet, PCE = passenger car equivalent Some of the totals may not match exactly due to rounding. 1 Trip rates from the ITE.
2 Vehicle Mix from the SCAQMD 2014
3 Passenger Car Equivalent (PCE) factors are assumed to be 1.0 for passenger vehicles, 1.5 for 2-axle trucks, 2.0 for 3-axle trucks, and 3.0 for 4-axle trucks.

Project Trip Distribution and Assignment
Project trip distribution percentages are based on logical travel paths to and from the Project site, review of traffic studies conducted for nearby projects, and consideration of the traffic distribution patterns in the area.

Figure 4.12-3 illustrates the proposed Project trip distribution. As shown in the figure, approximately 80% of the passenger cars would travel west and 20% would travel east along Woodside Avenue from the Project site. A

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-13
majority of Project-related trucks (approximately 90%) would travel west on Woodside Avenue to access the SR-52 ramps from Magnolia Avenue. The remaining, 10% of the Project trucks would travel east on Woodside Avenue.

Based on the distribution percentage, Figures 4.12-4, 4.12-5, and 4.12-6 illustrate the Project trip assignment for cars, trucks, and total trips (in PCE), respectively.

Vehicle Miles Traveled Analysis Methodology
On September 27, 2013, SB 743 was signed into law, which creates a process to change the way that transportation impacts are analyzed under CEQA. SB 743 required the Governor’s Office of Planning and Research (OPR) to amend the CEQA Guidelines to provide an alternative to LOS for evaluating transportation impacts. Under the new transportation guidelines, LOS, or vehicle delay, will no longer be considered an environmental impact under CEQA. The updates to the CEQA Guidelines required under SB 743 were approved on December 28, 2018.

These guidelines identify VMT as the most appropriate measure of transportation impacts under CEQA and were required to be implemented on July 1, 2020.

The requirements to prepare a detailed transportation VMT analysis apply to all discretionary land development projects that are not exempt from CEQA, except those that meet at least one of the transportation screening criteria.

A project that meets at least one of the screening criteria below would be presumed to have a less than significant VMT impact due to project characteristics and/or location.

Per the City’s VMT Analysis Guidelines, for projects that do not screen out VMT should include analysis using the SANDAG Regional Travel Demand Model. The model outputs can be used to produce VMT/capita, VMT/employee, and Total VMT. For employment projects (Industrial/Non-industrial), the City’s VMT guidelines the following criteria:
▪ For projects that generate fewer than 2,400 daily unadjusted driveway trips: Identify the location of the project on the City’s VMT/employee map. The project’s VMT/employee will be considered the same as the VMT/capita of the TAZ as shown on the VMT/employee map. Compare the project’s VMT/employee to the threshold to determine if the impact is significant, or, if desired or requested by the City, input the project into the SANDAG Regional Travel Demand Model to determine the project’s VMT/employee. ▪ For projects that generate 2,400 or greater daily unadjusted driveway trips: Larger projects will typically be analyzed using a custom model run by inputting the project into the SANDAG Regional Travel Demand Model. To perform the analysis, all project land uses should be inputted, and the VMT/employee should be determined using the same method/scripts that SANDAG utilizes to calculate the VMT/employee threshold.

There may be some circumstances where the use of screening maps or other sketch modeling tools are appropriate for larger projects, especially if the project has the same characteristics of the land uses that are already contained in the TAZ where the project is located or if the project is unique in nature and project specific travel behavior information is available.

As shown in above with Table 4.12-1, the Project would generate less than 2,400 daily trips. As shown above, the proposed Project would not meet any VMT screening criteria, therefore, the Project’s VMT evaluation has been conducted using the SANDAG SB 743 VMT maps.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-14

4.12.4 Impacts Analysis
A. Would the Project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
Less than Significant Impact. The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities, as discussed below.

SANDAG’s San Diego Forward: The Regional Plan
The Project would be consistent with the 2021 Regional Plan (RP)/Sustainable Communities Strategy (SCS) as analyzed in Table 4.9-2, Consistency with 2021 RP/SCS Goals, in Section 4.9, Land Use and Planning.

City of Santee Mobility Element
The General Plan Mobility Element outlines the City’s goals and implementation policies to provide a safe and efficient transportation system strategy. These goals and implementation policies are provided in detail in Section 4.12.2, Relevant Plans, Policies, and Policies.

Project generated traffic would travel along arterials and major roadways to access the site and cut through traffic on residential streets is not anticipated. The truck traffic from the Project would primarily travel along truck routes to access SR-52. The Project would also include improvements along N. Woodside Avenue, including frontage landscape and pedestrian improvements.

The Project would construct a dedicated eastbound left turn lane at the Project Access Driveway along N. Woodside Avenue and parking would be provided entirely on site. Although the roadway segment of N. Woodside Avenue near Project Driveway is forecast to operate at unacceptable LOS, with the frontage and Project access improvements, the operation of the Project Access Driveway/N. Woodside Avenue would facilitate traffic flow and truck turn movement along Woodside Avenue near the Project site. Since the roadway segment is constructed at buildout classification per the City’s Mobility Element, no further improvements to this roadway segment are recommended.

Santee City CouncilAugust 27, 2025

Santee City Council
August 27, 2025